CONOCOPHILLIPS · FY 2025 

Controls & Procedures

Management concluded that its disclosure controls and procedures were operating effectively as of December 31, 2025, and did not identify any material weaknesses or significant deficiencies in internal controls over financial reporting. The most significant change reported during the period was the completion of a multi-year global enterprise resource planning (ERP) system implementation in the first quarter of 2025. This major system upgrade necessitated corresponding updates to applicable internal controls and business processes.

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Conocophillips Controls & Procedures Analysis

Summary of Disclosure Controls and Internal Controls Over Financial Reporting (ICFR)

Management's Conclusion on Effectiveness:
As of December 31, 2025, management concluded that the company's disclosure controls and procedures were operating effectively.

Material Weaknesses or Significant Deficiencies:
The filing does not identify any material weaknesses or significant deficiencies in the company's internal controls over financial reporting.

Changes to Internal Controls During the Reporting Period:
The most significant change reported was the completion of the final phase of a multi-year implementation of an updated global enterprise resource planning (ERP) system during the first quarter of 2025. This required corresponding changes to business processes and information systems, necessitating updates to applicable internal controls over financial reporting.

Remediation Efforts:
The remediation efforts were tied directly to the ERP system implementation, resulting in the updating of business processes and internal controls over financial reporting.

Noteworthy New Controls or Procedures:
The multi-year implementation and completion of the updated global enterprise resource planning system is the primary noteworthy change. The company explicitly stated that there were no other changes in internal control over financial reporting during the period that materially affected or were reasonably likely to materially affect the controls.