Business Ethics
A reputation for integrity and ethical business conduct is one of the most
valuable assets an individual or company can possess. Marathon is committed
to upholding high standards of ethical behavior.
The vice president of Corporate Compliance and Ethics oversees the Company's compliance and ethics efforts. This officer is a member of the Business Integrity (BI) Advisory Committee, along with representatives from Law, Audit, Human Resources and Operations. This committee influences policies on integrity, provides guidance and advice on the Code of Business Conduct, and promotes training and compliance. A subject matter expert in ethics from the University of St. Thomas in Houston attends the committee's meetings to provide an independent perspective.
The BI Office directs the Company's emphasis on ethical standards, maintains the Code of Business Conduct, administers the Integrity Helpline, develops and implements ethics education programs, and communicates internally and externally about ethical business conduct. It also coordinates with the Law, Audit and Human Resources organizations to ensure program compliance.
All employees, except SSA employees and union members, must complete mandatory ethics training every three years. In 2007, mandatory training addressed employee questions and concerns about potential retaliation for reporting unethical behavior. The training emphasized that retaliation for good faith reporting is itself a violation of the Code. SSA conducted its biannual ethics training in 2007, using face-to-face sessions for all headquarters employees and Operations employees at the level of district manager and higher. Computer-based training (CBT) on ethics is provided for store managers annually and for all newly hired store associates.
The Integrity Helpline is a confidential, 24-hour global telephone resource for anonymously reporting suspected unethical or illegal activity and for seeking guidance for Code of Business Conduct compliance. There were 238 calls to the Helpline in 2007, compared to 203 calls in 2006. Of these, 211 were closed in 2007 following internal investigation. Some calls received late in the year were not closed in 2007. Approximately 90 percent of all Helpline callers received a response or action was taken within one business day.
Approximately 38 percent of calls were inquiries and 62 percent
were allegations. Allegations in 2007 increased by 96 percent from 2006. The BI Office believes the increase resulted from heightened awareness that the Code prohibits retaliation for reporting in good faith.
Designated employees known as Business Integrity Partners assist the BI Office with communication and training initiatives. Approximately 50 BI Partners in organizations and locations worldwide raise awareness among co-workers about Marathon's commitment to being an ethical organization and how to access related resources. They also provide feedback to the BI Office on employees' understanding of ethics messages and issues.
Marathon strives to be recognized as a company that applies best practices in business ethics. BI personnel network with ethics officer peers, partner with professors of business ethics at universities, and in 2007 made presentations at national conferences, ethics association meetings and business school graduate classes. The Company also participates in the Ethics Resource Center Fellows Program in the U.S.
Code of Business Conduct
The Code of Business Conduct articulates Marathon's commitment to comply with the law
and to conduct its business ethically. The Code reinforces the values that underpin
good business decisions: trust, respect, dignity and honesty. It applies to every
person who works for or represents Marathon.
The Code covers accountability and responsibility; individual responsibilities to one another, the public, shareholders, business partners, governments and the law; and resources for assistance and reporting. It is available to employees in English, Spanish, French and Arabic. The English, Spanish and French versions are available on Marathon's external Web site.
Marathon takes steps to ensure Code compliance and allow employees to disclose situations or concerns related to their personal compliance, particularly conflicts of interest. Most employees and many contractors based outside of the U.S. are required to complete an annual questionnaire and certification statement. The Law and Audit departments review all responses. Approximately 8,000 Marathon employees received the questionnaire covering calendar year 2007 and all completed it as required. Employees made approximately 350 disclosures. The BI Office addresses disclosures that require follow-up or response.
