Q2 2022 Integrity Advocate

It Takes a Village

You’ve surely heard the African Proverb, “it takes a village to raise a child.” But, did you know that Business Integrity and Compliance (BI&C) takes this same approach to building and promoting our company’s compliance and ethics program?

We do this through our BI&C Partner Program. Through the cultivation and training of a select group of engaged employees to partner with BI&C, the BI&C Partners help to strengthen the company’s compliance and ethics program as well as assist BI&C to more fully realize its chief objectives.

Responsibilities of the BI&C Partner:

  • Actively look for opportunities to work with organization and local management to increase employee awareness and understanding of the Code of Business Conduct, Company Policies, integrity as a core value, and our Compliance and Ethics Program.
  • Encourage the reporting of allegations to appropriate resources. Employees can report any suspected illegal or unethical conduct connected with the business of the Company or any of its subsidiaries to their supervisor, their supervisor’s manager, Internal Audit, Law-Government Affairs, Human Resources or the Integrity Helpline.
  • Reinforce the Company’s anti-retaliation policy.
  • Assist BI&C with presenting compliance and ethics training.
  • Act as a liaison between the organization or location and BI&C to identify specific compliance and ethics issues and determine targeted training needs; meet at least quarterly with organization or local management.
  • Promote and encourage the timely completion of the Annual Code of Business Conduct Questionnaire and Certification and answer employee questions relating to the questionnaire and certification.
  • Distribute and reinforce messaging in publications and other materials from BI&C.
  • Provide feedback to BI&C on the effectiveness of BI&C’s strategies, communications and training.

Designated groups have at least one BI&C Partner who serves as a liaison between BI&C and the employees within their respective Partner’s group.

Meet our most recently appointed partners:

Programs like MPC’s BI&C Partners are a best practice in the compliance and ethics space. Typically referred to as “ethics ambassadors” or “ethics liaisons,” individuals in these roles are increasingly used and relied upon as an effective supplement to a company’s overall compliance and ethics program. View the entire list of BI&C Partners to find out who serves in this role for your organization/group and visit the BI&C Partner Page on MPCConnect to learn more about the Program.

The Importance of Corporate Compliance    and Ethics Programs

In simple terms, compliance is conforming to specific requirements in laws, regulations, standards, and policies, while ethics encompasses values and principles that help individuals make decisions that are in line with ethical standards. Similarly, corporate compliance is how a company goes about ensuring conformance, it includes the design, implementation, and monitoring of effective policies, procedures, practices, and programs surrounding adherence by an organization, its employees and other third parties involved with an organization’s business activities. In business ethics, integrity describes how people live the values in which they say they believe. Ethics is a principled decision making by which one commits to acting with integrity even when no one is watching and even when it may not be to the person’s advantage. For a company to have integrity, it needs to know what its values are and strive for conduct that models those behaviors.

Firsthand from the DOJ

According to Assistant Attorney General Kenneth Polite, he has “seen first-hand how a strong compliance program can ward off misconduct and empower ethical employees.” In remarks he delivered at NYU’s Law Program on Corporate Compliance and Enforcement in March of 2022, he shared that the Department of Justice (DOJ) expects “an effective corporate compliance program to be much more than a company’s policies, procedures, and internal controls.” They “expect companies to implement compliance programs that (1) are well designed, (2) are adequately resourced and empowered to function effectively, and (3) work in practice.” He then went on to say, “Our message is clear – companies that make a serious investment in improving their compliance programs and internal controls will be viewed in a better light by the Department. Support your compliance team now or pay later.”[1]

Deputy Attorney General Lisa O. Monaco previously expressed similar sentiments in her keynote address at the American Bar Association’s 36th National Institute on White Collar Crime, stating:

 

A corporate culture that fails to hold individuals accountable, or fails to invest in compliance — or worse, that thumbs its nose at compliance — leads to bad results.

Let me also be clear: a company can fulfill its fiduciary duty to shareholders and maintain a commitment to compliance and lawfulness. In fact, companies serve their shareholders when they proactively put in place compliance functions and spend resources anticipating problems. They do so both by avoiding regulatory actions in the first place and receiving credit from the government. Conversely, we will ensure the absence of such programs inevitably proves a costly omission for companies who end up the focus of department investigations.[2]

MPC’s Compliance and Ethics Program

At MPC, 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 (Program) and delegates day-to-day operational responsibility for the Program to Business Integrity and Compliance (BI&C).

The chief objectives of our 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 DOJ and the Securities and Exchange Commission (SEC) have observed that no compliance program can ever prevent all criminal activity. We acknowledge that reality, but we also assert in good faith that our Program has been well constructed, thoughtfully implemented and enforced consistently in a corporate environment fully supportive of its objectives.

Our 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.

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 our 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:

          • Your supervisor or manager
          • Another supervisor or manager
          • Law-Government Affairs, Internal Audit, or HESS&PQ
          • Business Integrity and Compliance
          • Integrity Helpline
                o 855-857-5700[3]
                o www.FuelingIntegrity.com

 

[1] Office of Public Affairs. (2022, March 31). Assistant Attorney General Kenneth A. Polite Jr. Delivers Remarks at NYU Law’s Program on Corporate Compliance and Enforcement (PCCE). The United States Department of Justice. Retrieved April 29, 2022, from https://www.justice.gov/opa/speech/assistant-attorney-general-kenneth-polite-jr-delivers-remarks-nyu-law-s-program-corporate

[2] Office of Public Affairs. (2021, October 28). Deputy Attorney General Lisa O. Monaco Gives Keynote Address at ABA's 36th National Institute on White Collar Crime. The United States Department of Justice. Retrieved April 29, 2022, from https://www.justice.gov/opa/speech/deputy-attorney-general-lisa-o-monaco-gives-keynote-address-abas-36th-national-institute

[3] Mexico - All Carriers 800.681.6945; Telmex 001 866 376 0139; Singapore – All Carriers 800.852.3912; Singapore Telecom 001 800 1777 9999; United Kingdom 0-(808)-189-1053

Integrity in Action

Integrity in Action

Glad You Asked

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

Click arrows below to view the company response to the concern.

The Question: Employees from my team were contacted by a vendor about participating in a feedback session regarding their services and offered compensation for their participation. I believe this is inappropriate, can you provide guidance on the matter.

The Answer: Yes, this opportunity is a conflict of interest under Policy #2006, “an employee may not appropriate or use personally, or for an immediate family member or other person or outside organization, any benefit or opportunity which comes to the employee’s knowledge in the course of employment”.

The Question: I have a manager who has been asked to take part in a panel discussion put on by a national trade association. The trade association has offered to pay for the employee’s flight, hotel, and expenses. Do we allow them to pay for this, or is this something we as a Company would cover the cost for?

The Answer: Policy #2009 - Business Courtesies provides instruction for the acceptance of meals, gifts, entertainment and hospitality. Under this policy, in general, MPC Personnel should not accept lodging or air transportation from third parties, nor accept direct or indirect payment for lodging or commercial air transportation. Instead, MPC Personnel should pay for such expenses using either the MPC Business Expense Report process or personal funds, as appropriate. The acceptance by MPC Personnel of ground transportation incidental to business activities is acceptable. There may be circumstances when lodging accommodations may be accepted by MPC Personnel, but regardless of the value, supervisor preapproval must be secured by submitting a Business Courtesies Disclosure in Convercent.

The Question: I am interested in running for local elected politics. I want to verify that this is not a violation of company policy.

The Answer: MPC respects the right of employees to engage in the political process in their personal capacities during nonworking hours. In accordance with Policy #9001- Political and Lobbying Activity, employees who are considering running for or being appointed to public office should discuss potential conflicts of interest and work arrangements with their supervisor and notify the Human Resources organization. If you do become an elected or appointed government official, you should disclose such by submitting an Interim Disclosure. Instructions for doing so are available on BI&C’s SharePoint site.

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 our scope 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 M-01-004 Findlay Campus or [email protected].