Q1 2018 Integrity Advocate
Annual Code of Business Conduct Questionnaire and Certification
Success in our business depends on maintaining the trust and confidence of all of our stakeholders, which include employees, shareholders, business partners, governments and the law, customers, and the communities in which we operate. Our company’s commitment to high ethical standards and its Code of Business Conduct (Code) are the bedrock upon which stakeholder trust and confidence are built.
That’s why all employees at all levels of MPC/MPLX and Speedway as well as the MPC and MPLX Boards of Directors are expected to know and understand the Code and follow its principles. It’s also why employees and our Boards of Directors are asked to renew their commitment to the Code through annual certification – mandatory for salaried employees and the Boards of Directors; voluntary for hourly employees.
Business Integrity and Compliance (BI&C) administered this year’s annual certification during the months of January and February 2018 to:
Salaried Employees/Board of Directors (Mandatory) Hourly Employees (Voluntary)
Assigned to: 5,198 Assigned to: 8,098
Completion Rate: 100% Completion Rate: 61% (4% increase)
Prior Year Completion Rate: 100% Prior Year Completion Rate: 57%
Convercent Investigator Training
An investigation is conducted when potential misconduct is reported to Business Integrity and Compliance (BI&C) – violations of the Code of Business Conduct, policies, applicable laws and government regulations in any location where our company operates. When conducting investigations, it’s important to apply consistent principles, procedures and documentation.
Therefore, BI&C, with the help of its third-party case management system provider, Convercent, recently revised its Investigation Guidelines and conducted investigator training for all of its internal investigators.
Because BI&C uses a variety of internal investigators at MPC and Speedway, ensuring a consistent investigation process is critical. BI&C’s Investigation Guidelines are designed to guide investigators toward a consistent, unbiased, thorough and well documented investigation process, and to protect the confidentiality of involved parties.
On February 22, 2018, BI&C hosted an in-person/live webcast training session, facilitated by Autumn Sanelli from Convercent. During the training, Ms. Sanelli shared the revised Investigation Guidelines and a tutorial of how to properly document an investigation within the Convercent system. The session was attended or watched by 57 investigators, and was also recorded for later viewing via Passport. All BI&C investigators are required to complete this training.
MPC and Speedway are committed to living up to high standards of ethical behavior. In support of this commitment, BI&C has a process for investigating reports of alleged misconduct made to its office. Investigators are a vital component of this process. The Investigation Guidelines and training are valuable tools for our investigative partners, and help build and retain the confidence and trust of all employees in our process.
Have Questions or Concerns?
Talk to your management or
Contact the Integrity Helpline
at 855-857-5700 or
Glad You Asked
Below is a sample of inquiries received by Business Integrity and Compliance and responses to the same.
Q: Is it okay to accept the conference fee, lodging and travel expenses for a vendor’s annual conference in exchange for participation on their Customer Advisory Board?
A: Our policy on Meals, Gifts and Entertainment provides instruction for the acceptance and reporting of meals, gifts and entertainment. In accordance with the policy and supporting guidelines, acceptance is okay provided you obtain approval from your supervisor (and, in the case of Speedway, your organization’s Vice President). You must obtain approval via the online Gift and Entertainment Approval Form prior to accepting.
Q: An employee is traveling to a destination for business purposes. Rather than return home at the end of the work week, the employee stays at that location for the weekend to visit family in the area. However, the ticket cost to return home Sunday vs. Friday is $200 more expensive. What is the company policy on this? Should the project leader pay the difference? Is this decision based on supervisor discretion?
A: MPC’s Travel, Corporate T&E Card, and Business Expense Guidelines define procedures for authorized business travel and guidelines for expense reimbursement.
Air Travel
MPC will pay for air travel between the business origin and business destination using the lowest logical fare, routing, and class of service. If an employee deviates from this routing or the approved class of service due to personal reasons, and the new flight arrangements are more costly, the employee shall pay the additional cost. The employee should follow the Business Expense Reporting Guidelines when completing his/her BER and appropriately categorize the additional cost as “personal” and reimburse the company accordingly.
Q: An employee is traveling to a city for business purposes for the week. A friend from college is in town and is looking for a place to crash for the night. The company was already paying for a room with two queen beds, is it against company policy to permit that friend to utilize the extra bed?
A: MPC’s Travel, Corporate T&E Card, and Business Expense Guidelines define procedures for authorized business travel and guidelines for expense reimbursement.
Hotels
The spouse and/or guest of an employee may accompany them on a business trip. Any incremental costs incurred by the spouse or guest must be segregated as “Personal Expense” when the employee completes his/her BER and the company reimbursed.
It Happened Here
The following scenarios happened with employees at our company. Situations and descriptions have been edited to maintain anonymity and confidentiality.
The Concern: A Manager sold surplus assets from her organization and purchased them back for her own personal use.
The Response: Based on the review, both deals (sale of the materials to outside entity; subsequent purchase by Manager) were arm’s lengths transactions. No fraud was suspected. Rather, the Manager did not understand the importance of using Global Procurement (GP) to help facilitate such transactions. GP advised the Manager of the appropriate procedures to follow when she is making future sales of surplus/obsolete materials.
The Concern: In an effort to clean up a work backlog, an employee forged her Manager’s signature on documents meeting the dollar-amount threshold requiring Manager-level review and signoff. The employee’s conscience got the best of her and she reported what she’d done to her Manager.
The Response: An internal review was conducted of all documents processed by this employee meeting the dollar-amount threshold for Manager-level review and signoff, as well as a significant sample processed by other employees. The review found that the confessing employee had in fact forged documents; no forgeries were found by other employees. This employee no longer works for MPC.
The Concern: A Store manager called an employee from the store phone asking if she could borrow $250 to put in the safe until the store audit was complete. The Manager stated that she would give the employee the money back that afternoon once the audit was complete. The employee did not report to work on this day as her bank is across the street from the store and she was fearful that the Manager would harass her all day to get the money for the safe.
The Response: An audit of the store found that between the safe and the Daily Shift Report (DSR), the store was significantly short on their change fund (greater than $2,000). The Manager confessed to taking the money and she no longer works for Speedway.
The Concern: A male and a female co-worker travel together frequently. It was evident to their peers that the male employee was enamored with the female employee. The female employee didn’t understand why the male employee traveled with her all the time and expressed that she would rather he didn’t.
The Response: The investigation found that the male employee was inappropriately texting the female employee. The texts contained harassing language. At the time of the investigation, the male employee was on a final written warning for similar behavior. He no longer works for MPC.
The Concern: A male Supervisor was overheard using an inappropriate word to refer to the women on his team. The Reporting Party wasn’t sure of the entire context of the conversation but didn’t believe the Supervisor was attempting to be sexually suggestive; and felt uncomfortable given the word’s meaning and connotation.
The Response: The Supervisor admitted using the word though not with the literal definition of the word in mind. The Supervisor received coaching from Human Resources and his Manager.
The Concern: Several Employees were being scheduled to provide vacation coverage that violated a fatigue policy. Some individuals were scheduled to work more than four nights and did not have a full 48 hours off before returning to work multiple day shifts.
The Response: The contemplated “vacation coverage” scheduling would have violated the fatigue policy. The violations would have occurred when employees were working overtime to cover other employees’ vacations. Management had made an effort to preserve employee's seven day break in their rotation as requested by employees who responded to the Employee Survey. The potential fatigue policy violation was an unintended consequence of this effort. Once this issue was brought to Management's attention the schedule was corrected to follow appropriate guidelines. This was done prior to the first schedule infraction, so no policy violations actually occurred.
To seek guidance or report misconduct, talk to a supervisor or manager, Law, Internal Audit, Human Resources, Environment, Safety, Security & Product Quality, Business Integrity and Compliance or contact the Integrity Helpline (www.MPCIntegrity.com, www.MPLXIntegrity.com, www.AndeavorLogisticsIntegrity.com, www.SpeedwayIntegrity.com, 855.857.5700).