Anti-corruption Laws

Marathon will comply with all anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (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.

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.