Anti-corruption Laws

Marathon will comply with all anti-corruption laws, including the U.S. Foreign Corrupt Practices Act or (FCPA), wherever we do business. These laws generally forbid bribes to government officials or their representatives. While the U.S., like nearly all nations, outlaws bribing its own government officials, the FCPA also makes it a crime to bribe "foreign governmental officials," a term that is broadly defined.

In recent years, many countries have passed similar legislation. While the FCPA permits minor "facilitating" payments to expedite routine governmental action, you should consult, if possible, with the Law Organization before making or authorizing any such payment. You must consult with the Law Organization as soon as possible if you are concerned that a payment might be improper.

The FCPA also requires the Company to keep books, records and accounts which, in reasonable detail, accurately and fairly reflect its foreign and domestic transactions. You must consult with the Accounting Organization as soon as possible if you are concerned that the Company's books, records and accounts do not accurately reflect the Company's transactions.

The Company requires comprehensive FCPA and anti-corruption compliance training for all employees whose job responsibilities involve FCPA and anticorruption compliance.