Marathon Oil (MRO)

SEC Investigation Relating to Equatorial Guinea

By letter dated July 15, 2004, the SEC notified us that it was conducting an inquiry into payments made to the government of Equatorial Guinea, or to officials and persons affiliated with officials of the government of Equatorial Guinea. By letter dated February 13, 2009, the SEC further notified us that they completed their investigation and did not intend to recommend any enforcement action in this matter.

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Table of Contents

Index to Financial Statements

None.

SEC Investigation Relating to Equatorial Guinea

By letter dated July 15, 2004, the SEC notified us that it was conducting an inquiry into payments made to the government of Equatorial Guinea, or to officials and persons affiliated with officials of the government of Equatorial Guinea. By letter dated February 13, 2009, the SEC further notified us that they completed their investigation and did not intend to recommend any enforcement action in this matter.

35

Table of Contents

Index to Financial Statements

None.

SEC Investigation Relating to Equatorial Guinea

FACE="Times New Roman" SIZE="2">By letter dated July 15, 2004, the SEC notified us that it was conducting an inquiry into payments made to the government of Equatorial Guinea, or to officials and persons affiliated with officials of the
government of Equatorial Guinea. By letter dated February 13, 2009, the SEC further notified us that they completed their investigation and did not intend to recommend any enforcement action in this matter.

SEC Investigation Relating to Equatorial Guinea

By letter dated July 15, 2004, the SEC notified Marathon that it was conducting an inquiry into payments made to the government of Equatorial Guinea, or to officials and persons affiliated with officials of the government of Equatorial Guinea. This inquiry followed an investigation and public hearing conducted by the U.S. Senate Permanent Subcommittee on Investigations, which reviewed the transactions of various foreign governments, including those of Equatorial Guinea, with Riggs Bank. The investigation and hearing also reviewed the operations of U.S. oil and gas companies, including Marathon, in Equatorial Guinea. There was no finding in the Subcommittee’s report that Marathon violated the U.S. Foreign Corrupt Practices Act or any other applicable laws or regulations. Marathon voluntarily produced documents requested by the SEC in that inquiry. On August 1, 2005, Marathon received a subpoena issued by the SEC pursuant to a formal order of investigation requiring the production of the documents that had already been produced or that were in the process of being identified and produced in response to the SEC’s prior requests, and requesting the production of additional materials. Marathon has been and intends to continue cooperating with the SEC in this investigation.

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Table of Contents

Index to Financial Statements

Not applicable.

SEC Investigation Relating to Equatorial Guinea

As previously disclosed, during 2004 the United States Securities and Exchange Commission (“SEC”) commenced an inquiry into payments made to the government of Equatorial Guinea, or to officials and persons affiliated with officials of the government of Equatorial Guinea.  Marathon has been voluntarily producing documents requested by the SEC in that inquiry.  On August 1, 2005, Marathon received a subpoena issued by the SEC pursuant to a formal order of investigation requiring the production of the documents that have already been produced or that are in the process of being identified and produced in response to the SEC’s prior requests, and requesting additional materials.  Marathon has been and intends to continue cooperating with the SEC in this investigation.