Responsible

Marathon Oil Company (Marathon Oil) requires Contractors to comply with its Health, Environment, Safety, and Security (HES&S) policies, standards, and guidelines, and monitors HES performance on the job. Contractors are responsible for having HES&S programs that meet or exceed Marathon Oil, federal, state, and local regulation, rules, and laws. Stipulated below are the minimum basic HES&S requirements for contractors performing Safety Sensitive Work for Marathon Oil.

Safety Sensitive Work is defined as any position or activity which requires a worker to execute any duties which are related to the safe operation or security of a facility or a piece of equipment which, if not performed properly, could result in a serious safety risk or environmental hazard to workers, the equipment or the general public. Examples of safety sensitive positions or activities include:

• Engaging in or supporting any worksite activities such as drilling, completions, production, construction, maintenance, workover, or flowback
• Performing the installation, maintenance or inspection of equipment used to contain, produce, process, control, or transport hydrocarbon liquids or gases or other hazardous chemicals.
• Operation, maintenance or repair of industrial trucks, construction equipment or maintenance equipment
• Control of detection instruments used for measuring toxic or flammable substances or any other operational, maintenance or safety-related substance or parameter. This includes control room operators.
• Direct supervisors of workers who perform any of the positions or activities listed above are considered safety-sensitive

Note: Routine operation of a motor vehicle for the purposes of transportation does not constitute a position or activity to be deemed safety sensitive.

Ethics and Accountability Matter

Marathon Oil is dedicated to upholding high ethical standards and principles throughout our operations worldwide, both in letter and in spirit. In keeping with the Company’s commitment to high ethical standards, it is important that Marathon Oil’s suppliers and other third-party business partners understand and share Marathon Oil’s commitment to ethical business conduct as described in our Code of Business Conduct.

Marathon Oil expects suppliers and other third-party business partners to understand and adhere to the standards and principles in Marathon Oil’s Code of Business Conduct when conducting business with Marathon Oil or on our behalf.

When engaging Marathon Oil personnel, all third-parties must comply with Marathon Oil’s Meals, Gifts and Entertainment Policy, which is more specific than the general guidelines contained in the Code of Business Conduct.

If you have questions or concerns about Marathon Oil’s Code of Business Conduct or Meals, Gifts and Entertainment Policy, please contact Marathon Oil's Compliance and Ethics Office via email.

Contact Marathon Oil's Compliance and Ethics Office with any questions, or to report any issues you served at 877-713-8314.

Visit the integrity helpline website for more information.

Responsible Operations Management System (ROMS) and Marathon Oil HES&S Contractor Safety Website

ROMS

We require contractors to comply with our health, environment and safety (HES) policies, standards and guidelines, and monitor their HES performance on the job. Together, Marathon Oil and our contractors strive for excellence.

Marathon Oil's HES vision is aligned with our values, including those relating to corporate governance, ethics and integrity, diversity and philanthropy. Business decisions affecting HES are guided by our Code of Business Conduct. This HES vision is applicable to Marathon Oil Corporation and all majority-owned subsidiaries. Meeting this commitment is a responsibility shared by everyone, including all employees, contractors and third parties. To realize this vision, we pursue continuous HES improvement using our Responsible Operations Management System (ROMS) to assess risks, set targets, and measure progress.

Contractor Website

This website allows Contractor to access important Marathon policies. These policies include Marathon's Drug and Alcohol Policy, Internet Use Policy, Weapons Policy, and other policies that provide Marathon's guidelines and expectations on how Contractors should act while working at Marathon locations. Please review these policies periodically with your employees and sub-contractors as they may change over time.

Contractor Personnel shall successfully complete:

1) Marathon Oil Contractor HES&S Orientation

In-person HES&S Orientation is required prior to performing safety sensitive work for Marathon Oil, and remains valid for a three year period upon completion. If a contractor is unable to attend an in-person orientation, they may complete an online orientation, which will be valid for only 30 days. The contractor must then attend an in-person orientation within 30 days of completing the online orientation. Effective January 1, 2024, contractors will only be allowed to take the online 30-day HES orientation once in a 12-month period.

In Person Orientation: Please sign up for a session based on your location:

Midland, TX

Carlsbad, NM

Oklahoma City, OK

Lindsay, OK

Watonga, OK

Kenedy, TX

Dickinson, ND

Dunn Center, ND

Dunn Center, ND (en Español)

New Town, ND

Online Orientation:

English online orientation

Spanish online orientation

2) Industry Safety Orientation

Safeland,™ Safegulf™ and IADC's HSE Rig Pass™ orientation is accepted by Company as meeting the industry safety orientation requirement. The OSHA 10 Hour orientation orientation is acceptable provided that the elective and optional components address the key job hazards. Contractor’s equivalent, in-house safety orientation program may be acceptable if they include the topics covered in the Safeland™ syllabus and the program has been reviewed by Company in advance of the work.

• Incident Reporting and Investigation
• Accident Prevention Signs and Tags
• Hand Safety
• Material Handling
• Behavioral Safety
• First aid/CPR/AED Considerations
• Confined Space
• Lockout/Tagout
• Drug and Alcohol/Substance Abuse
• Hazcom
• Electrical Safety (non-qualified)
• Intervention/Stop Work Authority
• Site Specific Hazards and Emergency Evacuation
• Fire Prevention and Portable Fire Extinguishers
• Walking Working Surfaces
• Job Safety Analysis/Prejob Planning
• Personal Protective Equipment
• Respiratory Protection
• Prevention of Workplace violence
• Working at Heights
• Permit to Work
• Driver Safety / Transportation Safety
• Environmental
• Excavation - Trenching and Shoring
• Industrial Hygiene/Occupational Health

Note: If the orientation does not include H2S Safety Awareness, Contractor Personnel shall successfully complete an acceptable H2S Awareness Training program (i.e. ANSI Z390.1-2017: Accepted Practices for Hydrogen Sulfide Safety Training).

3) Contractor Safety Orientation

Contractor is expected to provide a formal orientation to new Contractor Personnel before they start work. The orientation should cover Contractor’s HES&S policies, programs, procedures, and rules. Contractor’s safety orientations shall be verified by Company during planned audits. However, at any time, Company may request written verification of such training regarding a particular Contractor’s employee.

Drug and Alcohol

Marathon is committed to maintaining a drug and alcohol free workplace and requires that Safety Sensitive Contractors have and implement a written Drug and Alcohol (D&A) program that complies with Marathon Oil, all federal, state, and local laws regarding drug and alcohol policies including, but not limited to, having and enforcing drug and alcohol policies as required by the U.S. Department of Transportation. At minimum, the D&A policy provide for pre-employment, random, reasonable suspicion, and post-incident testing.

Marathon retains the right to audit your D&A program and require any non-conformances to be addressed in order to continue providing services.

Please be aware that Marathon, in conjunction with local law enforcement, actively conducts unannounced D&A searches and random testing at its Work Sites. Personnel who refuse to test, or who fail a test, may be permanently barred from working at a Marathon Work Site. Such infractions could negatively impact your company’s safety rating with Marathon.

Weapons

State laws allow individuals to keep legally obtained and possessed firearms in their locked personal vehicles in employer parking areas.

Marathon Oil will not impede the right of individuals to possess firearms in their locked personal Marathon Oil office parking areas.

Failure to abide by the foregoing requirement for storing a firearm in a motor vehicle will result in disciplinary action up to and including discharge. Contractors will not be approved to return to a Marathon Oil site.

Weapons including firearms will remain prohibited from company-owned vehicles, Marathon Oil- owned, rented, used or leased office buildings and other properties, including lodging furnished or paid for by the company or company work site locations.

Marathon Oil will uphold and enforce these provisions regardless of the vehicle status as a company or personal vehicle.

This policy applies to lawfully possessed firearms only. All other weapons are prohibited on company premises regardless of whether they are stored in a locked motor vehicle or not. In addition, in the interest of maintaining a safe workplace, the company recommends that employees and contractors not store firearms in their vehicles.

The majority of Marathon Oil operated leases prohibit firearms and weapons.

Written HES&S Policies and Programs

Contractor shall implement written health, environmental, safety, security, drug and alcohol, and emergency preparedness policies, programs, and procedures applicable to the Work.

Contractor shall further ensure that such policies, programs, etc. are equal to or exceed Company's policies, standards, and procedures in accordance with applicable federal, state and local laws, regulations, and best practices.

Contractor shall review programs and procedures against Company’s and implement any resulting measures and/or corrective actions when gaps are identified prior to starting Work.

Contractors must be familiar with and comply with safety permits for the Work.

HES&S Training

Contractor is responsible for providing the appropriate safety and job training to ensure Contractor Personnel have the knowledge and skills to perform their jobs safely. As a minimum, Contractors must meet regulatory training requirements applicable to the jurisdiction where the Work is to be performed and the hazards associated with the Work or work environment. The Master Contract, job order, recurring order, or any other commercial agreement may stipulate additional health, safety, and environmental training requirements.

Minimum HES&S Expectations

• Maintaining a current subscription to ISNetworld and achieve a PASS rating on HES
• ISNetworld Photo ID (for contractors with an existing ISN account only)
  An ISN photo ID is required for Contractor and Subcontractor personnel who will perform Safety Sensitive Work at a Marathon Work Site. The photo ID allows a Marathon Oil representative to verify Work Authorization. Please contact your ISN Account Representative to obtain Photo IDs for your personnel. An electronic version (e-badge) can be accessed via the ISNetworld mobile app by logging into your ISN profile and clicking on “Employee ID”. An e-badge that can be scanned electronically (i.e. by phone) is acceptable.
• Meeting and maintaining Marathon Oil’s insurance requirements throughout the duration of contract
• Acknowledgement of Marathon Oil's Drug & Alcohol Policy
• Contractor must be knowledgeable and abide by all federal, state, and local laws and regulations. National consensus standards and best practices should be utilized where applicable.
• Meeting Marathon Oil’s HES&S orientation and training requirements
• Adopting Marathon Oil’s injury case management program (provided by XstremeMD) or implementing an equivalent program
• Abiding by HES&S provisions in the Master Service Agreement (MSA) and the Marathon Oil contractor HES&S website
• Following Marathon Oil’s health, environmental and safety procedures applicable to the work scope or as otherwise agreed
• Abiding by Marathon Oil’s Life Critical Expectations and Statement of HES Beliefs
• Report ALL incidents and near misses immediately to a Marathon Oil representative and affected Contractor Personnel’s direct supervisor.

Safety Monitoring Requirements

Contractor shall maintain active accounts with the following third party safety management service providers designated by Company:

Information Management System

Contractor shall register with ISNetworld, maintain an accurate list of employees, obtain ISN IDs for those performing Safety Sensitive Work, and utilize Subtracker Tool, if applicable.

Contractor Qualification

Contractor shall maintain a PASS safety rating while performing Safety Sensitive Work on Company Work Sites. Company reserves the right to terminate Contractor’s services if ISNetworld safety rating is a FAIL or to require a Safety Improvement Plan to manage the Work for the period of a temporary exemption which, in the Company’s sole discretion, may be granted.

Third Parties and Subcontractors

Contractor shall include safety requirements and specifications that meet or exceed Company’s HES&S policies and requirements in contracts with subcontractors.

Contractor shall implement a subcontractor management process to manage the safety of subcontractor employees, and which shall be accessible to Company via Contractor’s ISNetworld RAVS programs.

Contractor shall require that subcontractors who perform Safety Sensitive Work on a Company Work Site subscribe to ISNetworld and link via ISNetworld’s Subtracker Tool.

Contractor shall perform a formal assessment of its subcontractors performing Safety Sensitive Work at Company locations and make available a copy of their assessment report and associated corrective action plan upon Company’s request.

Contractor shall ensure that subcontractors meet or exceed Company’s Drug & Alcohol policy

requirements and acknowledge Company’s right to deny access to subcontractors on grounds of reasonable suspicion or following a positive post-incident drug and alcohol test that was requested by Company.

Subcontractor employees shall obtain ISN ID, complete Company’s HES&S Orientation, which includes Company’s Life Critical Expectations Awareness Training, have industry- standard HES&S orientation training and/or any required certification required for the Work, and complete. Contractor shall provide records of such training to Company when requested.

Where a subcontractor is utilized for higher hazard work (i.e. rig move, well work, plug & abandonment, etc.), Company reserves the right to conduct an HES Leadership Engagement with the subcontractor and require additional controls by Contractor, including but not limited to: conducting a safety audit of subcontractor; performing a risk assessment for the Work; and/or increased on-site supervision.

Background Check

If requested by Company, Contractor shall perform criminal background checks on all Contractor Personnel. Such background checks will be performed in accordance with the Fair Credit Reporting Act and will consist of, and shall not be limited to, criminal records checks of federal, state or local records (as applicable). Upon request, Contractor will provide a letter of certification advising that it has performed a criminal background check on each of its Contractor Personnel.

Safety Apparel and Equipment

Contractors are responsible for conducting Personal Protective Equipment (PPE) hazard assessments to ensure their employees are protected with the proper PPE for the tasks being performed.

Contractor shall furnish all required safety apparel and equipment for the Work at Contractor’s sole cost and as Contractor Furnished Items. This includes at a minimum: flame resistant clothing (FRC), hard hats, safety footwear, safety glasses with side shields, and work gloves appropriate for the associated hazards.

Contractor shall provide work activity-specific personal protective equipment (PPE) such as:

• Hearing protection
• Personal alarm monitors (hydrogen sulfide (H2S) and/or, oxygen and lower explosive limit (LEL) monitors, as applicable to the Work Site and work activities)
• Respirators
• Chemical protective clothing
• Personal flotation devices
• Electric shock/arc flash protection
• Personal fall protection, and/or rescue equipment.

All safety apparel and equipment shall meet the standards of the applicable regulatory requirement and agency recommendations and Contractor’s personnel shall be properly trained in their correct use, storage, and maintenance.

Contractor Personnel reporting to a Work Site without appropriate safety apparel and equipment shall not be permitted to work and shall result in Contractor being in default. No compensation shall be paid by Company for such Contractor’s personnel until the situation has been appropriately corrected.

General HES&S

Safe Work Site / Housekeeping

Contractor shall at all times maintain a clean and safe Work Site and provide its personnel with a safe place of employment. Contractor shall ensure the Work Site is kept free from Contractor generated debris and waste.

Contractor shall promptly inform Company in writing of any unanticipated hazards that may be encountered in conducting the Work and shall take all necessary precautions to protect persons and property from damage or injury.

Work Site Inspection, Notice of Hazardous Condition, and Suspension

Contractor shall take measures to actively and routinely identify and address conditions which are or may become unsafe at any Work Site and promptly take action to correct such conditions.

Risk Assessment

If required by Company, Contractor, in advance of the Work, shall perform a Job Safety Analysis (JSA), or equivalent risk assessment to identify and mitigate possible hazards and risks posed by the Work. Contractor will ensure compliance with Company’s agency permits, regulatory plans, and agreements. For jobs or tasks that are considered ‘high risk’, the JSA shall be submitted to Company for review. Contractor Personnel involved with the Work shall be briefed on the hazards and mitigations identified in the JSA before commencing Work.

HES&S Communications

Contractor shall ensure that a Pre-Job Safety Meeting (PJSM) is conducted prior to each job involving two or more persons. The PJSM shall be repeated when unanticipated changes occur in the work scope, job location, weather, operational conditions, or work team composition. The PJSM shall be attended by Contractor’s personnel and documented. Contractor shall submit to Company, daily, or upon completion of the Work, a copy of the PJSM showing topic(s) discussed along with the record of attendance.

When requested, Contractor Personnel shall attend Company’s safety meetings. Company will compensate Contractor at rates specified for the time of such Contractor Personnel in job order, recurring order, purchase order, call-off, or any other commercial agreement executed between the parties, when applicable. If the Work project is initiated and completed during the period between the safety meetings, Company may consider an exemption or alternative option.

Hazard Communication

Contractor shall ensure that all hazardous chemicals relating to the Work, both products and wastes, are labeled and stored in compliance with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and other applicable regulations.

Contractor shall have immediate access to the Safety Data Sheet (SDS) for all hazardous chemicals stored or used on location and shall provide a copy of the SDS to Company when requested.

Company product SDSs are available on the Marathon Oil Contractor HES&S website. Contractor personnel will have completed hazard communication training conforming to 29 CFR 1910.1200 prior to deployment at a Company location.

Hand Tools

Tools are not altered from the manufacturer’s standards. The use of shop made tools is prohibited unless approved by BU Leadership and BU HES.

Hand tools are:

• Right for the job
• Operated according to the manufacturer’s instructions
• Kept in good condition with regular maintenance
• Used with all appropriate Personal Protection Equipment (PPE)
• Examined for damage before each use, taken out of service when damage is found, and either repaired or disposed of appropriately

Note: Inspection criteria is specific to the type of tool being used (i.e. pneumatic, electric, manual, etc.).

Ensure materials and tools used while working from elevated worksites are hoisted independently of the worker using secure, fit-for-purpose carrying pouches, or are transported by the worker using a tool belt or bag. Hand tools are tethered and secured to prevent falling.

Lone Worker

When personnel are working alone the following items are addressed:

• Developing a plan to contact rescue services
• Schedule of routine communications to ensure employees wellbeing
• A lone worker is prohibited from conducting the following work activities
  • Work at heights requiring the use of a personal fall arrest system
  • Entering an hazardous excavation
  • Any work, except for non-sparking hot work, conducted under a safe work permit
  • Working under supplied air respiratory protection in an IDLH atmosphere

Short Service Employees (SSE)

Personnel with limited amount of service (usually less than 6 months) in the same job/position with their present employer shall be considered Short Service Employees.

Contractor shall implement a formal SSE program that meets API RP 76 (Contractor Safety Management for Oil and Gas Drilling and Production Operations), Annex C requirements, namely: identification, orientation, and mentoring of the SSE employee, with clearly defined responsibilities for the mentor and mentee during the period of SSE status.

Fatigue Management

Contractor shall implement a fatigue management program or policy that limits the working hours for Contractor Personnel. Upon Company’s request, Contractor shall report, at a specified frequency, the cumulative Work hours of Contractor Personnel, including Subcontractors, performing Work for Company.

Heat and Cold Stress

Contractors are responsible for an adequate heat or cold stress program prior to the start of work.

Heat and cold stress programs include, at minimum:

• Administrative controls (i.e. work/rest/warm-up cycles)
• Symptom awareness
• Plans for treating heat / cold stress symptoms
• Hydration provisions to prevent heat related injuries
• Proper cold weather garments to prevent cold related injuries

Stop Work Authority

Contractor shall have a Stop Work policy that is supported by management and shall suspend operations when continuation of the Work is or will become hazardous to life or property, or if a suspension is necessary for health, environmental, safety, or security reasons. Contractor shall immediately notify Company Representative of any Contractor initiated suspension, including Contractor's proposed course of corrective action prior to restarting the Work.

Event and Case Management

In the event of an environmental or safety event, including any near miss, Contractor shall ensure that the Company representative and affected Contractor Personnel’s direct supervisor are informed immediately. A written incident report shall be furnished to Company as soon as possible but no later than 24 hours after the incident. Further, Contractor is responsible for reporting injuries and incidents involving its personnel and/or property to the relevant governmental agencies, and notifying Company when such reports are made.

All injuries shall be reported to Company’s Case Management (CM) provider (XstremeMD) or equivalent, as designated in the Contractor Management procedure. Contractor shall have an authorized representative accompany injured employee to the CM provider for initial treatment.

Contractor shall have a written restricted duty program/policy to accommodate injured employee and facilitate their return to full duties without restrictions.

Contractor shall make every effort to avoid spills or other environmental impacts at the Work Sites. If a spill or environmental impacts, such as wildlife impact, damage to landowners’ property or livestock, or damage to storm water controls occurs or is encountered, Contractor shall be responsible for immediately notifying a Company representative, taking such immediate steps to mitigate the spill as are reasonably prudent, and providing a report on the incident and any corrective actions taken.

Contractor shall have a written accident reporting, investigation, and Root Cause Analysis (RCA) program/policy and provide Company the results of an investigation, when requested, along with Contractor’s corrective action plan. Company may request Contractor’s participation in Company’s investigation of incidents involving Contractor Personnel or equipment on Company property. If corrective actions are assigned to Contractor from such investigations, they shall be addressed and closed to Company’s satisfaction in a timely manner.

Environmental Protection

Contractor shall conduct all activities in a manner consistent with Company’s commitment to environmental protection, which emphasizes, to the extent practical, resource conservation and minimization of wastes, emissions, and releases throughout Company operations.

Contractor shall have an appropriate waste management plan and be responsible for proper handling, labeling, storage, transportation, and disposal of any waste generated by its Work. Contractor shall seek Company approval of any disposal site prior to disposal of any spilled material, impacted soil, or wastes. Waste shall not be disposed at any facility other than facilities approved by Company in advance in writing.

Compliance and Right to Audit

Company reserves the right to audit Contractor’s compliance with the Health, Environment, and Safety, and Security requirements as per the Master Contract. Failure to comply with any of the requirements, or corrective actions following an audit, may cause Company to suspend the Work or terminate Master Contract, job order, recurring order, and/or any other commercial agreement.