Ethical Business Practices

Our board of directors and its Audit and Finance Committee oversee business ethics, and our chief executive officer has oversight for Marathon Oil’s anti-bribery and anti-corruption program. Marathon Oil updated our publicly available Code of Business Conduct (Code) and associated Code training in 2021. The Code is also placed on company-issued laptops and phones, and hard copies of the Code summary are available in Marathon Oil offices.

Every new Marathon Oil employee receives a communication summarizing their roles and responsibilities under the Code, including ways they can raise Code-related questions and concerns. All active employees, including new hires, are required to complete an annual Code Questionnaire and Certification, and additional online Code training annually, with modules on anti-corruption, harassment, security and protecting information and reporting concerns. We regularly assess our business environment and update our compliance programs to address current and emerging risks and to strengthen compliance and mitigations through various mechanisms.

Marathon Oil maintains a framework of requirements and procedures to detect, prevent and address potential violations of applicable anti-corruption and commercial bribery (collectively, anti-corruption) laws and to support our commitment to conducting business honestly and ethically.

This framework includes an Anti-Corruption Compliance Policy (ACCP) and supporting Anti-Corruption Standard (ACS) and well-established processes to address potential anti-corruption risk areas. Our ACCP outlines clear expectations and specific prohibitions, including the prohibition of facilitation payments, as well as processes for addressing anti-corruption risk areas. We regularly conduct anti-corruption training for designated personnel and conduct compliance audits.

• Contacting a direct manager or another member of management within Marathon Oil.
• Contacting the Marathon Oil organization(s) referenced in each section of the Code.
• Contacting Marathon Oil’s Corporate Compliance & Ethics organization at Integrity@marathonoil.com.
• Utilizing Marathon Oil’s Integrity Helpline via 877-713-8314 or www.integrity-helpline.com/MarathonOil.jsp.

Marathon Oil does not tolerate retaliation for good faith reporting of actual or potential Code violations, and we consider retaliation for good faith reporting a violation of the Code.