Q2 2024 Integrity Advocate
Commitment to Compliance and Ethics
At MPC and MPLX, accountability and responsibility for ethical conduct is a strategic business commitment. We ask our employees to act with ethics and integrity in everything they do and to speak up freely, without fear of retaliation, when they see violations of our Code of Business Conduct or the law.
To continue to lead these efforts, MPC and MPLX have appointed Michelle Benavides to lead our Compliance and Ethics (C&E) Program as Chief Compliance Officer. Michelle reports to Molly Benson, Chief Legal Officer and Corporate Secretary, and the Audit Committees of MPC and MPLX.
Michelle joined in April 2024 from Halliburton, where she was responsible for leading a global compliance program across 70+ countries as Chief Compliance Officer. Michelle shares her views on compliance, the role of a Chief Compliance Officer, and cultivating a culture of ethical conduct and compliance in this short video.
To support our commitment to integrity and ethical business conduct, the C&E team in the Law organization includes attorneys and compliance professionals knowledgeable about our business and ready to assist you with any compliance questions or concerns.
Meet the Team
Nicole Blevins, Senior Counsel. Nicole joined the company in February 2023 as an attorney in the Business Operation & Commercial Law group. She supported MPLX’s Gathering and Processing operations in the southwest advising on environmental, land, contract, health, and safety matters before joining the C&E team in April 2024. Prior to joining the company, Nicole advised clients on a broad range of environmental and regulatory legal matters, served as a prosecutor at the Colorado Attorney General’s Office, and acted as in-house counsel for State Farm Insurance Company.
Zach Cheslock, Senior Counsel. Zach joined the company in 2019 as an attorney in the Business Development Law group. He played a key role in numerous acquisitions, divestitures, and joint venture deals for MPC and MPLX. Zach joined the C&E team in April 2024 but continues to use his expertise to assist in acquisitions, divestitures, and joint ventures. Prior to joining the company, Zach advised clients on a broad range of corporate and transactional law issues in the healthcare, transportation, and manufacturing industries.
Sue Harris, Business Integrity Manager. Sue joined the company in 2017 as a compliance professional in the Law organization’s Business Integrity and Compliance group. Prior to joining the company, Sue was the Director of Regulatory Compliance at ProMedica Health System’s insurance division, Paramount Health Care. Her career with ProMedica spanned 24 years and focused on development and operational management of compliance, fraud, waste and abuse, and delegation oversight programs.
Shelly Joseph, Business Integrity Representative. Shelly joined the company in 2020 as a compliance professional in the Law organization’s Business Integrity and Compliance group. Prior to joining the company, Shelly worked for the Findlay-Hancock County Community Foundation for nearly 10 years overseeing and administering 200+ scholarship funds and ensuring compliance for each as the foundation's Scholarship Manager.
Patrick Matheny, Senior Counsel. Patrick joined the company’s Law organization in 2011, starting as an intern the summer of the spin-off from Marathon Oil. As a member of the Business Operation & Commercial Law group, Patrick supported a variety of the company’s commercial and corporate teams, including trading and logistics, marine, marketing, IT, supply chain, and real estate before joining the C&E team in November 2024. Before attending law school, Patrick worked for the Brunswick Group advising companies on financial, transactional and other critical communications, and served as the Director of Operations for a local business in downtown Findlay.
Denise Wilson, Advanced Business Integrity Representative. Denise joined the company as a paralegal for Speedway in 1999. Before joining the Business Integrity and Compliance group in April 2018, Denise supported the labor and employment group in the Law organization and subsequently accepted a position as a Law Administrator, where she used her systems experience to support the company’s legal systems of record. Before joining the company, Denise worked at the law firm of Rieser & Marx supporting a Chapter 7 Bankruptcy Trustee.
We encourage you to reach out directly to any C&E team member with any questions or concerns.
You can also email [email protected] or visit the BI&C SharePoint site for additional resources and information about our C&E Program.
"There's No Such Thing as a Free Lunch"
We’ve all heard the idiom, "There's no such thing as a free lunch." Its origins are believed to come from the early American saloon tradition
where a drink would come with some free salty food, intended to make the eater order another drink. The phrase is often used today to illustrate opportunity cost. To get something you want, you often must give up something in return. Nothing is truly free.
In your personal and professional lives, the promise of free or easy money should always be reviewed through the “no free lunch” lens. What is the opportunity cost? What is my trade-off?
The federal government awards more than $500 billion in grant money annually through more than 1,000 different grant programs. States and some local jurisdictions run similar programs as well, giving out grants to selected projects intended to provide some public benefit, directly or indirectly. These funds come with requirements and restrictions, some unique to the specific opportunity, and others more broadly applied to grant recipients.
When a grant being offered overlaps with the company’s interests these opportunities can and should be reviewed as a potential funding source for a company project. A formal process has been developed to evaluate grant activities, designed to receive proper stakeholder engagement and an understanding of the associated opportunity cost before any commitments are made.
Marathon's Grant Process
The Process Overview for Grant Activities (“Grant Process”) was finalized at the end of last year by the Strategy & Business Development (S&BD) and Law organizations, with the input and approval from the executive leadership team. The Grant Process designates specific roles for individuals in S&BD, Law, and the various business units that could pursue or would support grant activity, and establishes an enterprise-wide approach to pursuing, reviewing, and complying with these grant opportunities. The Grant Process contemplates different levels of review and approval based on the actual role of the company in the grant activity, whether pursuing the grant directly or supporting a third-party applicant. The idea is to tailor the review and work to the company’s expected level of exposure and involvement.
Compliance is critical in any project, but complying with the terms of a grant is of the utmost importance. “Strings” on the money often include rules for the supplier selection process, requirements to buy American manufactured materials, special accounting and reporting standards, and audit rights. This is why it’s important, on the front end, to understand what comes with the government funding offered as part of a grant opportunity. That’s why the Grant Process was developed, to ensure we understand the true cost of what could otherwise be viewed as a free lunch.
If you have questions related to the Grant Process, they can be sent to the Grant Coordinator by clicking here.
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: We have an employee who would like to get a second job teaching. Their lectures would not affect their current employment at MPC, nor would they be using any Marathon materials. Please let us know your thoughts/if the employee needs to complete a disclosure for this?
The Answer: In general, employees are allowed to undertake personal business ventures such as outside professional activities so long as the outside activity does not interfere with the loyalty, time and effort required by MPC or its affiliates, does not utilize company resources or confidential information, and does not otherwise violate Policy #2006 - Conflicts of Interest. Based upon the information provided, we do not see a conflict of interest with the employee teaching courses at the local college. It is, however, important to remember that the employee should not share any non-public information regarding the Company's business and processes with outside parties who do not have a business need to know and they should also notify their supervisor of their plans.
*This is a unique situation, all situations or relationships which might create potential conflicts of interest should be promptly disclosed and will be evaluated on their individual facts and circumstances.
The Question: We had a demo with a vendor and they sent a Yeti rambler. We are not currently in negotiations with this vendor, am I allowed to accept this?
The Answer: A Yeti mug would be conisdered a gift. Policy #2009 - Business Courtesies allows employees to accept Gifts, but employees must disclose any Gift valued at greater than $100 to their supervisor by submitting a Business Courtesies Disclosure. Given the fact that you are not currently in negotiations with this vendor, provided the associated dollar amount of the Yeti Mug is not greater than $100, there is nothing further from a business courtesies disclosure perspective needed. Additional information about the acceptance of meals, gifts, entertainment and hospitality can be found in Policy #2009 - Business Courtesies.
The Question: I am attending a conference and a family member wants to come along to the location. Is it acceptable for them to stay in the hotel room with me during this conference?
The Answer: A spouse and/or guest of an employee may accompany them on a business trip, but any incremental costs incurred by the spouse or guest must be segregated as “Personal Expense” when the employee completes his/her business expense report. Please contact the BER Helpdesk at 855-837-6933 – press 3 or [email protected] for additional questions or to learn more about what incremental costs might include.
Remember, when it comes to booking business travel, pre-approval from your manager/supervisor is always required. Review the Travel, Corporate Credit Card and Business Expense Report Guidelines to learn more about the procedures for business travel and to review guidelines for expense reimbursement.
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].