All gifts of a value of more than £100 and hospitality of a value more than £200 (other than business meals) given must be recorded within the ABC Register, as defined within the U.K. Bribery Act Annex to the ConocoPhillips Policy on the Foreign Corrupt Practices Act and Anti-Corruption Law Compliance (as amended). Central to the giving of gifts and hospitality will be the diligent recording of such activities and expenditures in the ABC Register. The ABC Register will be monitored and assessed on a regular basis by the ConocoPhillips UK Legal Department and matters investigated as considered appropriate.
The Travel Expense system in SAP should continue to be utilised for claiming of expenses. All expenditures for gifts, travel and hospitalities (i.e. meals and entertainment) provided to any recipient must be properly recorded in an expense report and in the appropriate books and records of the company.
This form is intended to capture gifts or hospitality given.
A second form is available for gifts or hospitality received. You may access that form here.