Marathon Oil Corporation received Notices of Violation from the Environmental Protection Agency (?EPA?) related to alleged violations of the Clean Air Act with respect to operations on the Fort Berthold Indian Reservation between 2015 and 2019. On July 10, 2024 Marathon Oil Corporation entered into a consent decree with the Environmental Protection Agency and Department of Justice to fully resolve this matter. The consent decree is subject to a 30-day public comment period before it may be considered for entry by the court.

The consent decree will require the completion of mitigation projects, implementation of specific injunctive relief, and payment of a $64.5 million civil penalty with substantially all of that civil penalty accrued in previously filed quarterly report for the period ending March 31, 2024. In 2022, the company began early implementation of the injunctive requirements associated with likely settlement terms and are scheduled to complete this work in 2025. The total cost associated with the injunctive relief is estimated to be approximately $177 million, but over 70% of that cost has been incurred or included in the previously announced 2024 capital budget with the remaining amount to be spent by the end of 2025.

The consent decree sets out a detailed compliance schedule with deadlines for achievement of milestones through at least 2026. The consent decree further contains requirements for ongoing permitting, inspection and monitoring, maintenance, auditing, and reporting. Findings from such inspection, monitoring and auditing activities may result in decisions to temporarily shut in or reduce production from certain wells and facilities.

The company have cooperated fully with the EPA, including collecting and sharing extensive data to resolve this matter. The vast majority of emission reductions are being achieved by Marathon?s voluntary commitment to incorporate technologies, like new lowest emitting automated facilities (LEAF). This work in the Bakken, which has been ongoing for some time, complements and builds on longstanding emission reduction and overall compliance enhancement efforts.

Marathon does not admit liability regarding any of the allegations in the complaint associated with the consent decree and elected to resolve the allegations in a negotiated settlement rather than litigation. The company do not believe that the mitigation expenditures, penalties, and injunctive relief that resulted from this settlement will have a material adverse effect on either business or operations or the previously announced Agreement and Plan of Merger with ConocoPhillips.