Lee M. Tillman, President and CEO

Ethical Business Practices

We have a commitment to being responsible, safe and ethical. Marathon Oil holds all employees, officers, directors and other parties who represent the Company responsible for adhering to our high standards of ethics and for doing business with integrity.

Our commitment to ethical business practices is reinforced in our Code of Business Conduct, which we updated in 2017. Every active Marathon Oil employee received the Code, along with a supplemental reference guide, and was required to complete Code training in 2017. The revised Code includes new or enhanced language on a variety of risks, including bribery and corruption, anti-money laundering, data privacy and other matters. Our Code states that treating each other with dignity, respect and fairness is central to how Marathon Oil conducts business, and it prohibits harassment in the workplace.  

Marathon Oil’s ethics and integrity efforts, which are overseen by the board’s independent Audit and Finance Committee, include:

  • Policies and procedures related to compliance
  • Reporting mechanisms
  • Annual internal compliance audits
  • Annual Code of Business Conduct Questionnaire and Certification for all active employees
  • Enterprise Risk Management compliance assessment 
Discussion between two men

Preventing Corruption and Bribery

Marathon Oil complies with all applicable anti-corruption and commercial bribery laws in the countries where we operate, including the U.S. Foreign Corrupt Practices Act (FCPA) and U.K. Bribery Act. Our anti-corruption compliance program aligns with U.S. Department of Justice recommendations for effectiveness. In 2017, we developed a new Anti-Corruption Compliance Policy that strengthened our efforts to prevent corruption and bribery. The Anti-Corruption Compliance Policy replaces the previous governing policy document.

We require designated employees with certain job responsibilities and/or working in certain locations to complete annual anti-corruption compliance training. We also have an international compliance audit program for our operations outside the U.S. and outside-operated interests in countries not in the Organization for Economic Cooperation and Development (OECD).

We have well-established processes for transparent reporting of revenue flows from oil and gas production to prevent bribery and corruption. Our internal monitoring systems to detect corruption include the Integrity Helpline, audits and investigations. In addition, most interactions with foreign government officials require the approval of our Law Department. While we ended our participation in the Extractive Industries Transparency Initiative (EITI) because our business strategy shifted to focus on U.S. unconventional resource plays, we continue to engage in industry discussions regarding transparency of payments.


Supply Chain Monitoring

Marathon Oil will not do business with third parties that have a record of violating the law or applicable regulations related to employment, the environment, safety, anti-slavery measures and other matters. Our approach to preventing bribery by our business partners is governed by our Procurement and Contracting Standard and Anti-Corruption Compliance Policy. The board-approved policy makes our Global Supply Chain function responsible for conducting all contracting and procurement activities in an objective, ethical manner in accordance with the standard and applicable anti-corruption laws.

The Anti-Corruption Compliance Policy requires potential business partners that may pose a bribery risk to successfully complete due diligence and be approved by Marathon Oil’s Law function before engagement by Global Supply Chain. If the high-risk third party is approved for use, Global Supply Chain and Law will either use Marathon Oil’s standard anti-bribery and trade compliance contracting language or negotiate specific compliance language.

A high-risk third party with which we work may be required to participate in Marathon Oil anti-bribery training and/or undergo a contracts and compliance audit conducted by our Internal Audit function. In addition, all third parties, including those considered high risk, may report business ethics concerns to our Integrity Helpline

We recognize that slavery is a significant global human rights issue. To ensure that slavery and human trafficking do not exist in our supply chain, Marathon Oil conducts our operations in the U.K. in accordance with the U.K.’s Modern Slavery Act

Reporting Mechanisms

We want our employees to collaborate, take ownership, be bold and deliver results. To make this possible, Marathon Oil is committed to providing a safe workplace where everyone is treated with dignity, respect and fairness. We believe a diversity of people and ideas gives us a business advantage, and fosters openness and inclusion to allow diversity to flourish.

We prohibit all forms of harassment, including any actions or words that could reasonably be considered harassing or threatening to a fellow employee or person with whom we do business. Marathon Oil also prohibits discrimination against any employee or business partner on the basis of a legally protected status as detailed in our Code.

To avoid grievances, we encourage employees to work with their supervisors and management to resolve issues. Employees may report questions or concerns through Human Resources, Audit, HES&S, Law, the Corporate Compliance function and other internal resources.

We also offer employees and third parties the Integrity Helpline for anonymous, confidential reporting of ethics and compliance questions and concerns at all times, by phone and online. Our Corporate Compliance and Ethics organization reviews submissions to the Helpline and takes action as necessary. Our Code and Reporting Business Ethics Concerns Policy forbid retaliation for good faith reporting of these concerns.


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