The case for CSR/ Sustainability Reporting Done Responsibly


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Home / case studies / Case study: How ConocoPhillips promotes ethical business conduct

Case study: How ConocoPhillips promotes ethical business conduct

ConocoPhillips is a multinational corporation engaged in hydrocarbon exploration, based in the Energy Corridor district of Houston, Texas, with operations in 17 countries. Led by its Chief Compliance Officer, ConocoPhillips’ Global Compliance and Ethics team was established to ensure adherence with applicable laws and the highest ethical standards  Tweet This!, promote a positive corporate reputation, prevent criminal and civil liability, and set the tone for an ethical work environment.

This case study is based on the 2019 Sustainability Report by ConocoPhillips published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.

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ConocoPhillips’ reputation and integrity depend on each employee, officer, director and those working on its behalf assuming a personal responsibility for its business conduct. In order to promote ethical business conduct ConocoPhillips took action to:

  • implement a Code of Business Ethics and Conduct
  • encourage employees and contractors to raise concerns

What are the material issues the company has identified?

In its 2019 Sustainability Report ConocoPhillips identified a range of material issues, such as energy efficiency, community impacts, water sourcing, human rights, safety and health. Among these, promoting ethical business conduct stands out as a key material issue for ConocoPhillips.

Stakeholder engagement in accordance with the GRI Standards              

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups ConocoPhillips engages with:

Stakeholder Group                Method of engagement
Financial Sector


·      Investor presentations and conferences

·      Analyst calls

·      Annual Shareholder Meeting

·      SEC filings

·      Socially Responsible Investor meetings and conferences

·      Tours



·      Advocacy

·      Policy development

·      Industry and trade association representation

·      Regulatory compliance

·      Permit reviews

·      Regulatory audits

·      Regional development

·      Tours

·      Collaboration on community investment projects

·      Town halls

·      Multi-stakeholder initiatives



·      Websites, media and social media

·      Community investment programmes

·      Royalty relations

·      Community consultations

·      Local procurement

·      Employment

·      Landowner meetings

·      Town halls

·      Volunteering




·      Performance management

·      Training and development

·      Internal communications

·      Code of Conduct

·      Employee surveys

·      Participation on trade and industry association committees

·      Safety meetings

·      Ethics Helpline

·      Volunteering

·      Leadership town halls

·      Employee network groups

·      Talent Management Teams

·      Global wellness programmes

·      360-feedback tool





·      Bid process

·      Contract negotiations

·      Project management

·      Supplier forums

·      Annual performance reviews

How stakeholder engagement was made to identify material issues

To identify and prioritise material topics ConocoPhillips engaged with its key stakeholders through meetings and discussions.

What actions were taken by ConocoPhillips to promote ethical business conduct?

In its 2019 Sustainability Report ConocoPhillips reports that it took the following actions for promoting ethical business conduct:

  • Implementing a Code of Business Ethics and Conduct
  • ConocoPhillips’ Code of Business Ethics and Conduct explains ConocoPhillips’ standards as well as its legal and ethical responsibilities and provides concrete guidance for expected behaviours. It covers a range of topics including business ethics, anti-trust, anti-corruption, gifts and entertainment, and political involvement. New employees receive training on the Code of Business Ethics and Conduct and all employees receive web-based training periodically. All employees are also required to read the code annually and confirm compliance. Employees who are most exposed to legal risks, like corruption, take part in web-based training and other targeted training. In addition to corruption training, ConocoPhillips also teaches employees how to deal with situations that may involve laws or regulations regarding political activities, antitrust, economic sanctions or export controls.
  • Encouraging employees and contractors to raise concerns
  • ConocoPhillips encourages employees and contractors to ask questions and seek guidance about ethical concerns and gives them tools to guide ethical decision-making so they can understand their responsibility to report actual or suspected misconduct. ConocoPhillips has several confidential reporting mechanisms, including speaking to a trusted manager, supervisor, human resource representative or a Global Compliance and Ethics representative. Additionally, there is an anonymous option. Any stakeholder, whether employee, contractor, shareholder or the general public may report an actual or suspected violation anonymously through ConocoPhillips’ 24-hour Ethics Helpline. The Ethics Helpline is hosted by a third party to ensure anonymity and is available worldwide via the web or phone in multiple languages. ConocoPhillips prohibits retaliation of any kind against employees for raising an ethical or legal concern. In 2019, Global Compliance and Ethics received questions, concerns and requests for advice from employees and stakeholders across ConocoPhillips’ ConocoPhillips investigated workplace conduct, conflicts of interest, financial and business integrity matters, misuse of company assets and other allegations. Depending on the scale and type of concern, issues were elevated to provide appropriate management oversight. Additionally, appropriate remedial and disciplinary action was taken when necessary. Senior management and the Audit and Finance Committee of the board are also provided regular updates on ConocoPhillips’ compliance and ethics programme, so they can ensure that the programme promotes ConocoPhillips’ SPIRIT values, addresses the compliance and ethics risks in its business and works effectively.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standards addressed in this case are:

1) Disclosure 205-1 Operations assessed for risks related to corruption

2) Disclosure 205-2 Communication and training about anti-corruption policies and procedures


Disclosure 205-1 Operations assessed for risks related to corruption corresponds to:

Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:


80% of the world’s 250 largest companies report in accordance with the GRI Standards

SustainCase was primarily created to demonstrate, through case studies, the importance of dealing with a company’s most important impacts in a structured way, with use of the GRI Standards. To show how today’s best-run companies are achieving economic, social and environmental success – and how you can too.

Research by well-recognised institutions is clearly proving that responsible companies can look to the future with optimism.

FBRH GRI Standards Certified, IEMA & CIM recognised Sustainability Course | Venue: London LSE

By registering for the next 2-day FBRH GRI Standards Certified, IEMA & CIM recognised course you will be taking the first step in gaining the many benefits of sustainability reporting.

Most importantly, you will gain the knowledge to use the GRI Standards, project manage your own first-class sustainability report and:

  • Identify your most important impacts on the Environment, Economy and Society
  • Begin taking solid, focused, all-round sustainability action ASAP



1) This case study is based on published information by ConocoPhillips, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:


Note to ConocoPhillips: With each case study we send out an email requesting a comment on this case study. If you have not received such an email please contact us.