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Preventing Corruption

Marathon opposes corruption in any form. Wherever we do business, Marathon and our majority-owned subsidiaries comply with all applicable laws aimed at preventing corruption, including the U.S. Foreign Corrupt Practices Act (FCPA). The FCPA, like laws of other nations, forbids bribing foreign officials or representatives of foreign governments. Our Law Organization oversees anti-corruption compliance, with guidance from the chief compliance officer.

Annual FCPA and anti-corruption training is mandatory for all employees whose job responsibilities include operations in designated locations or otherwise involve anti-corruption compliance. Employees who transfer outside the U.S. receive additional training.

In 2010, 1,637 employees worldwide attended FCPA training. This includes more than 98.5 percent of employees required to take the training. Employees who require training must also certify annually that they complied with Marathon's Anti-Corruption Compliance Guidelines.

Marathon's comprehensive annual anti-corruption compliance audit program covers our operations and outside-operated interests in countries that are not in the Organisation for Economic Co-operation and Development (OECD).

To prevent corruption involving third parties, Marathon has established compliance guidelines applicable to vendors, contractors, joint venture partners and employee recruitment. The guidelines mandate selection processes, oversight, contract language and, depending on the level of risk, due diligence.