Q1 2020 Integrity Advocate
Record Numbers Complete Annual Questionnaire
Each January, directors, officers, and employees are asked to certify that they've read the Code of Business Conduct (Code) and complete a questionnaire inquiring about compliance with company policies, including the Code1 and Conflicts of Interest Policy #2006.
This year the Annual Code of Business Conduct Questionnaire and Certification was assigned to an all-time high 24,193 employees. A record-breaking 19,545 employees completed the questionnaire with 100% responding in the mandatory response category2 and 51% in the voluntary category3.
Work now begins in Business Integrity and Compliance (BI&C) to review the 469 disclosures submitted by employees via the questionnaire, and those requiring further review will be referred to the appropriate organization, such as Human Resources, Internal Audit, and/or Environmental, Safety, Security & Product Quality. Submitting employees can expect to receive communication from BI&C acknowledging their submissions and providing direction, as warranted.
If a new conflict of interest arises at any time during the year, you may submit a disclosure via the Interim Disclosure process.
If you have a question or concern regarding the Code of Business Conduct or company policies, including a potential conflict of interest,
you may contact the Integrity Helpline at:
855-857-5700, or www.FuelingIntegrity.com.
1 Speedway Code of Business Conduct
2 Mandatory response category includes MPC salaried employees and all Speedway corporate and non-store field employees.
3 Voluntary response category includes MPC hourly employees paid on a salary basis.
What is Corporate Compliance?
In simple terms, compliance is conforming to specific requirements in laws, regulations, standards, and policies. Corporate compliance is how a company goes about ensuring conformance. It encompasses the design, implementation, and monitoring of effective policies, procedures, practices, and programs surrounding adherence by an organization and its employees and other third parties involved with an organization’s business activities.
Is There a Difference Between External and Internal Compliance?
Most often, when one thinks of corporate compliance, what first comes to mind is compliance with laws, rules, and other regulations imposed by a government or regulatory agency. Conforming to such requirements is considered external compliance.
How a company goes about ensuring it’s compliant with a specific law or regulation is typically not proscribed. As such, companies are free to decide in what way they will comply by developing policies, procedures, standards for conduct, etc. Employees and others conducting business on behalf of the company must then comply. This is considered internal compliance.
For example, in general, the Foreign Corrupt Practices Act (FCPA) prohibits U.S. companies or their officers, employees, agents or other representatives from paying, providing, offering or promising anything of value to a foreign government official for purposes of securing an improper advantage to assist in obtaining or retaining business. To provide a framework for compliance with this FCPA prohibition, MPC adopted Policy #2010 Anticorruption, the Foreign Anticorruption Compliance Manual, Policy #2009 Business Courtesies, supporting guidelines, and an anticorruption training program. All of which are considered internal compliance activities designed to meet an external compliance requirement.
How Do We Maintain Corporate Compliance?
Maintaining corporate compliance begins with our commitment to conduct our business in observance of the highest standards of integrity and ethical conduct, and in compliance with applicable laws and regulation as well as strong governance.
The business and affairs of MPC and MPLX are managed under the direction of their respective Boards of Directors. To lead the companies’ efforts to manage risks such as those relating to legal compliance and business ethics, the MPC and MPLX Boards of Directors have designated a single corporate officer, Molly Benson, to serve as the companies’ Chief Compliance Officer (CCO). The CCO has overall responsibility for our Compliance and Ethics Program and delegates day-to-day operational responsibility for the program to Business Integrity and Compliance (BI&C).
The chief objectives of our Compliance and Ethics Program are to prevent unlawful and unethical conduct, detect such conduct should it occur, and pursue prompt and appropriate remedial action when warranted, with the aims of promoting our strong compliance culture, protecting our valued corporate reputation and ensuring investor confidence.
The Program is built on an integrated approach, which values and leverages the subject matter expertise of professionals across numerous disciplines and communities of practice throughout our diverse energy business. With our strong governance and leadership foundation, we believe the primary responsibility for legal compliance and maintaining our reputation for ethical business practices rests with those closest to the operations and commercial components of our enterprise. Our BI&C team is fully dedicated to its charge of managing our enterprise-wide compliance and ethics initiatives but is only one of many critically important constituent parts to our Program.
Should Corporate Compliance Concerns be Reported?
The key mission of our Compliance and Ethics Program is to encourage all employees to act legally and ethically and to report concerns without fear of retaliation. Our vision for the Program is to foster a top-to-bottom and bottom-to-top ethical culture, where compliance with the law and adherence to high ethical standards are celebrated, misconduct is rare, and retaliation is simply not tolerated.
We encourage anyone who suspects or has knowledge of illegal or unethical conduct related to our company to report it. Our Code of Business Conduct urges employees to report concerns to:
· His/Her Supervisor
· Another Supervisor or Manager
· Law, Internal Audit, or ESS&PQ
· Business Integrity and Compliance
· Integrity Helpline
855-857-5700
www.FuelingIntegrity.com
It Happened Here
The following scenarios happened with employees at our company. Situations and descriptions have been edited to maintain anonymity and confidentiality.
Click arrows below to view the company response to the concern.
The Concern: A manager was reported to be verbally harassing their employees.
The Response: It was found that the manager was involved in a number of borderline harassing incidents with their employees. The manager was removed from their leadership position within the company.
The Concern: When approaching coworker with a policy related question, coworker asked for a kiss “with tongue” in return for providing the answer. This isn’t the first time the coworker has made sexually explicit, lewd and offensive comments to coworkers of opposite gender.
The Response: Investigation confirmed employee was sexually harassing coworkers. Employee no longer works for the company.
The Concern: Employee reported work-related injury to Lead Assistant Manager (LAM). After receiving the notice of injury, LAM requested employee return to work to fill shift. LAM informed management on duty that employee could only work behind register because of physical injury.
The Response: Investigation found neither LAM, nor management on duty followed the correct process for injury protocol. LAM who received initial report of injury received a written warning; member of management on duty was counseled.
Be an Integrity Advocate
Being an advocate is about speaking up not only about what may be wrong, but also about what is going right. Examples of ethical conduct should be highlighted and celebrated!
We invite you to help expand the scope of “It Happened Here” to include positive stories of integrity in action in future issues of the Integrity Advocate by submitting instances of integrity in action to Business Integrity and Compliance, Room M01004 Findlay Campus or [email protected].