Controls & Procedures

Management concluded that ConocoPhillips' disclosure controls and procedures were operating effectively as of December 31, 2024.

Material Weaknesses/Significant Deficiencies:
No material weaknesses or significant deficiencies in internal control over financial reporting were identified during the period covered by this report.

Changes to Internal Controls & Noteworthy Procedures:
The company is undergoing a noteworthy and ongoing multi-year implementation of an updated global enterprise resource planning (ERP) system, which began in the third quarter of 2023. This ERP rollout has necessitated corresponding changes to business processes and information systems, leading to updates in applicable internal controls over financial reporting. Management anticipates that as the phased ERP implementation continues, there may be further modifications or changes to certain processes and procedures, potentially resulting in additional ICFR changes.

Remediation Efforts:
Current remediation efforts are focused on updating and modifying business processes and information systems to align with the integration of the new global ERP system.

Item 9A. Controls and Procedures

We maintain disclosure controls and procedures designed to ensure information required to be disclosed in reports we file or submit under the Securities Exchange Act of 1934, as amended (the Act), is recorded, processed, summarized and reported within the time periods specified in Securities and Exchange Commission rules and forms, and that such information is accumulated and communicated to management, including our principal executive and principal financial officers, as appropriate, to allow timely decisions regarding required disclosure. As of December 31, 2024, with the participation of our management, our Chairman and Chief Executive Officer (principal executive officer) and our Executive Vice President and Chief Financial Officer (principal financial officer) carried out an evaluation, pursuant to Rule 13a-15(b) of the Act, of ConocoPhillips' disclosure controls and procedures (as defined in Rule 13a-15(e) of the Act). Based upon that evaluation, our Chairman and Chief Executive Officer and our Executive Vice President and Chief Financial Officer concluded our disclosure controls and procedures were operating effectively as of December 31, 2024.

In the third quarter of 2023, we began a multi-year implementation of an updated global enterprise resource planning system (ERP). As a result, we have made corresponding changes to our business processes and information systems, updating applicable internal controls over financial reporting where necessary. As the phased implementation of the ERP system progresses, we expect to continue to modify or change certain processes and procedures which may result in further changes to our internal controls over financial reporting.

There have been no other changes in our internal control over financial reporting, as defined in Rule 13a-15(f) of the Act, in the period covered by this report that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.

Management's Annual Report on Internal Control Over Financial Reporting

This report is included in Item 8 on page 71 and is incorporated herein by reference.

Report of Independent Registered Public Accounting Firm

This report is included in Item 8 on page 72 and is incorporated herein by reference.

Conocophillips Controls & Procedures Analysis

Controls & Procedures