Ethical Business Practices

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. New employees are also required to complete online Code of Business Conduct (Code) training, which includes a cybersecurity module, as well as disclose potential conflicts of interest. Active employees are required to complete an annual Code Questionnaire and Certification, and additional Code training on a scheduled basis.

We regularly assess our business environment and update our compliance programs to address current and emerging risks, and to strengthen compliance and mitigations. Our assessment mechanisms include, but are not limited to:

• Internal monitoring through the Marathon Oil audit and compliance functions.
• Inclusion in the annual enterprise risk assessment.
• External monitoring through peer and industry benchmarking.
• Discussions with external experts.

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.

In addition, we regularly conduct anti-corruption training for designated personnel and conduct compliance audits to test the effectiveness of our ACCP.

Marathon Oil publicizes, both publically and internally, resources for those individuals who want to ask a question about the Code or to report an actual or potential Code violation. These resources include:

• Members of management.
• Marathon Oil organization(s) referenced in each section of the Code.
• Marathon Oil’s Corporate Compliance & Ethics organization at Integrity@marathonoil.com.
• Marathon Oil’s Integrity Helpline, which allows for anonymous reporting by telephone (877-713-8314) or via the internet (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.