Q2 2018 Integrity Advocate

Time for Change

Change is in the air. Not only will Marathon and Speedway experience significant change with the recently announced transaction with Andeavor, but Business Integrity and Compliance will be undergoing some changes of its own.

Effective August 1, Gene Farmer will retire from Marathon after 30 years of service.  Since 2011, he has been the Manager of Business Integrity and Compliance.

Replacing Gene will be Tara Griffith. Tara is a Senior Attorney in the Marathon Law Organization. She has been with Marathon since 2007 as a Human Resources attorney.

Advanced Business Integrity Representative Heidi Kiffmeyer left BI&C in April 2018 for a position in GP Process and Systems. Denise Wilson replaced Heidi. Denise comes to BI&C from the Marathon Law Organization and started her career at Speedway. In fact, Denise has recently transferred back to Speedway to work as an Advanced Business Integrity Representative in their organization. Denise will report to Tara.

Please contact Business Integrity and Compliance ([email protected])  if you have any questions about these changes.

Gift and Entertainment Disclosures

The exchange of gifts and entertainment is a common business practice that can enhance business relationships. Sometimes, however, conflicts of interest, both real and apparent, can develop when gifts and entertainment are exchanged.  To help avoid situations that present actual conflicts of interest or the appearance of such, employees must seek approval from their supervisor (Speedway also requires VP approval) prior to accepting a gift valued at $100 or more and entertainment valued at $200 or more.

The process to report gifts and entertainment meeting these reporting thresholds changed recently.  On May 31, 2018 MPC and Speedway began using Convercent’s Disclosure module for gift and entertainment reporting.  This same Disclosure module was used to manage this year’s annual Code of Business Conduct questionnaire and certification process.

Submitting a gift and entertainment Disclosure is easy, here’s how:

  1. Log in to Convercent by entering your email address into the User Name field and hitting “Tab”
  2. Dashboard – Under “Disclosures”, click “Go to My Disclosures”
  3. Click “Add a New Disclosure”
  4. Select “Gift or Entertainment Received – Requesting Approval” category at bottom of list
  5. Complete form, save

You and your supervisor will be notified of your Disclosure via Convercent generated emails, reading:

A new disclosure has been submitted for the location [NAME]

Click here to sign in to Convercent and view the disclosure. (link here is example only)

Sincerely,
The Convercent Team
1-800-335-7639
www.convercent.com

Convercent will also send you an email notification once your supervisor, or VP in Speedway’s case, has reviewed and approved (or denied) your request.

With this new process, you can log in to Convercent at any time to view your Disclosures by navigating to “Go to My Disclosures” from the Dashboard.

Please visit the Business Integrity and Compliance TeamView site for additional meals, gifts and entertainment resources and feel free to contact us at [email protected] or [email protected] if you have any questions.

Glad You Asked

Below is a sample of inquiries received by Business Integrity and Compliance and responses to the same.

Q: Can an employee accept cash or cash equivalent prizes as part of a raffle that occurs during a golf outing?

A: According to Policy #2009 on Meals, Gifts and Entertainment and its supporting guidelines, it depends on who paid for the raffle ticket.  If the employee paid for it with personal funds, then the employee can keep the money.  Otherwise, this would be a cash gift and impermissible to accept.

Q: An employee is traveling for business to meet with vendors. Part of the trip includes tickets to a concert in a suite.  The employee wants to know how to determine the value of the entertainment for reporting purposes.  The employee researched the range of ticket prices for the area closest to their seats, but nothing reflects suites prices.

A: Our Meals, Gifts and Entertainment FAQs addresses this specifically:

Q18: A Vendor invited me to join them in their company’s private suite for a concert. They did not discuss the value of the ticket to the suite and the type of food that would be available, and it feels awkward to ask for this information. How do I estimate the value of the ticket?  

A18: Accepting a suite experience should be reported for approval via the online Gift and Entertainment Approval Form, regardless of the estimated value of the ticket. You should still put forth a reasonable effort to estimate the value of the experience, but the act of reporting is of greatest importance.

Q: An employee is traveling on business with a contractor.  The contractor brought his spouse to dinner. Is the employee allowed to include the spouse’s dinner as part of the business expense?

A: If there is a business reason for the spouse to be there, then the Company could pay for it.  If there is no business reason, then the employee should ask the contractor to put the spouse’s expense on a personal card.

Q: An employee was randomly selected to receive a $50 Amazon gift card for completion of an online survey related to a webinar (work related).  Is it permissible for the employee to accept the payment?

A: Retail Brand Gift Cards or Gift Certificates such as Amazon gift cards are acceptable gifts, as long as the employee complies with all other aspects of Policy #2009, including appropriate reporting, which is not required in this case because the value is less than $100.

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: An employee printed a money order without paying for it and returned the next day to pay for it and pick it up.

The Response: The investigation found that the employee had violated company policy by not paying for the money order at the time it was printed.   This employee no longer works for Speedway.

The Concern: At a company meeting a female employee made several inappropriate comments regarding one of her male co-workers.  Several individuals attempted to stop her and tried to change the subject.  But she continued and stated she would “love to work with him.”

The Response: The investigation found that the female employee not only made inappropriate verbal comments but also sent e-mails that contained inappropriate and harassing language.  The female employee was disciplined.

The Concern: A store manager offered vendor products (for free) to other store employees because his girlfriend worked for the vendor.

The Response: During the investigation, employees admitted that they were offered certain items from the store manager, who claimed he could get them “anything they ever needed.”  However, there was no proof that any store employee ever received or accepted free vendor merchandise.  The store manager was disciplined. 

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).