ConocoPhillips is reviewing the proposed U.S. Securities & Exchange Commission rule to implement Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. We endorse transparency in the extractive industries to ensure that natural resource wealth is an engine for economic growth that contributes to sustainable development and poverty reduction. We believe any mechanism for payment transparency should be accomplished in a manner that:

• Does not require companies to violate existing contractual and legal obligations.
• Is fair to all participants in the extractive industries.
• Does not place unreasonable administrative burdens and expenses on reporting companies.
• Does not place reporting companies at a strategic disadvantage as compared with nonreporting companies.