Q3 2018 Integrity Advocate

Get with The Program

Compliance and ethics programs help ensure that an organization operates within the law and stays true to its own core values and ethical principles.  Such a program demonstrates to a company’s stakeholders —employees, business partners, shareholders, community, regulator—that the organization is committed to doing business the right way.

MPC’s Compliance and Ethics Program

MPC’s Compliance and Ethics Program is no different. The chief objectives are to prevent unlawful and unethical conduct, detect such conduct should it occur, and pursue prompt and appropriate remedial action when warranted.  Our objectives are aimed at promoting our strong compliance culture, protecting our valued corporate reputation, and ensuring investor confidence. Though both the U.S. Department of Justice and the Securities and Exchange Commission provide companies with guidance on what constitutes an “effective compliance and ethics program” for purposes of corporate enforcement and prosecution, both have also 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 is well constructed, thoughtfully implemented, and enforced consistently in a corporate environment fully supportive of its objectives.   

Documented here, we synthesize and summarize the depth and breadth of the decentralized yet aligned activities that comprise our overall program.

Program Framework

The framework for our Compliance and Ethics Program conforms to the four-step iterative model Plan, Do, Check, and Adjust commonly used by businesses—including ours—as a methodology for the continuous improvement of processes or products.  As many of our employees, senior leaders and industry stakeholders have a foundation in this Plan, Do, Check, and Adjust model, it serves as the organizational structure for documenting our Program, which substantively tracks the hallmark elements of an effective program set forth in Chapter 8 of the U.S. Sentencing Commission Guidelines Manual.

Compliance and Ethics Program Revision

Our Compliance and Ethics Program is subject to ongoing review, updating and evaluation for effectiveness, and that continuous improvement process will continue in connection with the integration of Andeavor.

Molly Benson, vice president, chief securities, governance and compliance officer and corporate secretary, oversees periodic revision of the Program to respond to changes in the Company’s needs and applicable laws, rules and regulations, and to address identified gaps or weaknesses in the Program.

Get with the Program by checking out the MPC Compliance and Ethics Program document on BI&C’s TeamView site.  If you have feedback on the Program, please submit comments to BI&C at [email protected].

Business Integrity & Compliance

The Heart of Compliance and Ethics Coast to Coast

What do the State of Ohio, the Findlay Campus and MPC’s Business Integrity and Compliance Office (BI&C) all have in common? They all serve as the “heart of it all” for their respective functions:  Ohio, for purposes of tourism; the Findlay Campus, for purposes of our corporate headquarters; and BI&C for purposes of promoting an enterprise-wide compliance and ethics program (C&E) that educates and encourages all employees to act legally and ethically and to report concerns without fear of retaliation.

Who We Are

BI&C’s vision is to have a top-to-bottom ethical culture where compliance with the highest legal and ethical standards is celebrated, misconduct is rare, and retaliation for reporting misconduct is non-existent.

The BI&C function encourages and fosters a “speak up” culture by maintaining and promoting a helpline for employees and third parties to ask questions and report allegations of unethical or illegal conduct anonymously.  All allegations of misconduct are reviewed and investigated to the extent warranted based on the nature of each allegation and requests for confidentiality within the context of each investigation are zealously honored to the extent possible.  View our recent helpline statistics here.

BI&C educates the workforce and promotes its C&E program through a comprehensive communication and training plan, which provides monthly updates and learning points on company policies as well as a fulsome report on integrity and compliance issues in its quarterly newsletter.  To maintain its vast reach, BI&C draws on the assistance of a network of more than 70 Business Integrity & Compliance Partners in organizations across the enterprise who drive opportunities within each organization and with local management to increase employee awareness and understanding of the Code of Business Conduct, company policies and the company’s values.  Within the newly combined company, the depth and breadth of the BI&C Partners will be expanded as new partners are solicited and nominated by management and added to the team in the coming months.

The BI&C function reports to Molly R. Benson, Vice President, Chief Securities, Governance and Compliance Officer and Corporate Secretary, and is staffed by three individuals in Findlay, including Manager Tara Griffith, and one representative located in Enon, Ohio, at Speedway’s headquarters. The department profile is located here. 

What We Do

In addition to managing and responding to the allegations and inquiries that come into our office through the integrity helpline, we are responsible for administering Bi-Annual Code of Business Conduct Training and sending the Annual Code of Business Conduct Questionnaire and Certification.  We also oversee the New Hire and Interim Disclosure processes and facilitate responses to the disclosures made by employees.  We provide in person training on the company’s ethics and compliance program and our Convercent system and answer questions regarding company policies, including the meals, gifts and entertainment policy.  In addition, we provide case and trend analytics and C&E program updates to senior management through regular meetings with the Business Integrity Committee as well as the Audit Committee of the Board of Directors.   Annually, we deliver a company-wide Ethics Forum and participate in internal awards programs that help drive an ethical culture. 

Please visit the BI&C TeamView site on MPCConnect or the Speedway Homepage for additional resources and feel free to contact us at [email protected] or [email protected] with questions.

Commitment to Integrity

Check Yourself

October 1 marked the combination of Marathon Petroleum Corporation (MPC) and Andeavor—complementary companies each with a strong cultural commitment to uphold the highest standards of business ethics and compliance, both with a reputation for integrity through trust, respect, dignity, and honesty.

MPC Code of Business Conduct

As we lead our industry coast to coast, and as set forth in the Day 1 Quick Start Guide, all business and operations will be conducted in accordance with MPC Policy #2001, Policy #2002 and the MPC Code of Business Conduct, which you should read here.  Formal training on the Code is forthcoming, but until then, we invite you to view this short video related to the importance of reading, understanding and adhering to the Code of Business Conduct. 

Highlights of our Code are outlined below.  Work through each highlight and test your knowledge to ensure you have the information you need to keep your commitment in check.

 I know the Company’s CORE Values.

 Company’s CORE Values.

• Integrity
• Health and Safety
• Environmental Stewardship
• Corporate Citizenship
• Inclusive Culture

I know who is expected to follow our Code.

Every employee. And our business partners.

I know which company policies I am expected to follow.

With noted exceptions, MPC corporate policies apply. If you aren’t familiar, find them here.

I know that for which I am responsible and accountable under the Code.

I am responsible and accountable under the Code to:

  • Create and sustain a work environment in which fellow employees, consultants and contract workers know that ethical and legal behavior is required.
  • Be on the lookout for unethical or illegal conduct.
  • Elevate and take appropriate action to address any situation in conflict with the law or the Code.
I am familiar with the Integrity Decision Model.  

I understand my options for seeking guidance and/or reporting suspected illegal or unethical conduct.

Options for seeking guidance and/or reporting suspected illegal or unethical conduct.

• Supervisor or manager
• Representative from HR, Law, Internal Audit or Environment, Safety & Security and Product Quality
• Business Integrity and Compliance
• Anonymously (if desired) via the Integrity Helpline at 855-857-5700; www.MPCIntegrity.com, www.MPLXIntegrity.com or www.SpeedwayIntegrity.com

I understand the how the Company handles confidentiality in connection with reporting.

The Company will treat the employee’s identity and the alleged illegal or unethical conduct as confidential information and will disclose the identity of such source only as necessary to comply with legal requirements and investigate the reported conduct. Those informed of the employee’s identity will be made aware of the need for confidentiality.

I understand our Responsibility to One Another under the Code.

Treat each other with dignity, respect and fairness.
Ensure a safe and healthy work environment.

  • Take precautions to protect ourselves, fellow employees, visitors and other from accidents, injuries or unsafe conditions;
  • Promptly report unsafe or unhealthy conditions and take steps to correct those conditions immediately.

The following are prohibited in our work environment: discrimination, harassment and violence, and unauthorized drug or alcohol use or influence.

I understand our Responsibility to the Public under the Code.

Responsibility to the Public under the Code.

  • Customers.  Think in terms of how our customers might feel about how we conduct business. Act accordingly.
  • Environment.
    • Reduce and prevent waste, emissions and releases in all our operations.
    • Safely use, handle, transport and dispose of all raw materials, products and wastes.Help others that we work with to understand their environmental responsibilities.
    • Strive for continuous improvement in environmental performance in partnership with government agencies, contractors and communities.
  • Communities. Conduct our operations safely and be prepared for emergencies. Give back by supporting and participating in civic and charitable causes.
  • External Communications.  Refer media and general public requests for information to Public Affairs and legal-related requests to Law.
I understand our Responsibility to Shareholders under the Code.

Responsibility to Shareholders under the Code.

  • Protect Company assets from loss, damage, misuse or theft. This includes our time when compensated by the Company.
  • Properly use Company information systems. Our information systems include computers and mobile devices, phones, email, internet and network access, software and applications and electronic storage devices. These systems and devices are intended to be used for business purposes consistent with all Company policies.
  • Adhere to Social Media Guidelines.
  • Protect our good name. Only use our Company name and logo for authorized Company business and never in connection with personal activities or personal communication.
  • Prepare business records and communications with accuracy, raising concerns to the best source for correction of errors.  Communicate in correspondence in a way that you would be comfortable if you read what you wrote later in a newspaper or court of law. Dispose of documents in accordance with our records retention policy.
  • Protect confidential information, including proprietary technical information, business plans, status of operations and equipment, detailed financial data and all other non-public business information that would be of use to competitors or harmful to the Company if made public. Also protect the confidential information of our employees and customers.
  • Avoid conflicts of interest. Business decisions and actions on behalf of our Company must never be influenced by personal considerations or personal relationships. You must promptly disclose all potential conflicts of interest.
I understand our Responsibility to our Business Partners under the Code.

Responsibility to our Business Partners under the Code.

  • External Business Practices. Deal honestly with our suppliers and contractors. Do business with those who embrace and demonstrate high standards of business conduct. External business partners that knowingly seek to have Company employees violate our Code risk possible cancellation of all current and future contracts.
  • Marketing Practices. Compete for business aggressively and honestly.  Do not misrepresent our products, services or prices.  Do not make false or misleading claims about our (or our competitors’) products or services.
  • Purchasing Practices. Base all purchasing decisions on the value realized by our Company and alignment with our business standards and goals.
I understand our Responsibility to Governments and the Law under the Code.

Responsibility to Governments and the Law under the Code.

  • Antitrust and Fair Competition Laws. We comply with all applicable laws. Employees must seek advice from Law before taking any action that might be questioned under such laws.
  • Antibribery and Anti-Corruption Laws.  Bribes to government officials or their representatives are strictly forbidden. Consult with Law as soon as possible if you are concerned that there is or might be a potential violation of applicable antibribery or anticorruption laws. All employees whose job duties give rise to compliance issues related to these laws are provided with compliance training.
  • Anti-money Laundering. The Company does not condone any business activity that involves money laundering or the use of illegal funds.
  • Political Activities. We respect the right of each of our employees to participate in the political process and to engage in political activities or his/her choosing. When engaged in personal civic and political affairs, employees must make clear that their view and actions are their own, and not those of the Company. Employees may not use Company resources to support their choice of political parties, causes or candidates. Lobbying activity is highly regulated by law. Employees who communicate with government officials and employees on issue that affect our Company should contact Law to ensure that such activities fully comply with the law and that our Company’s lobbying efforts are coordinated.  Any proposed corporate contribution should be arranged through Government Affairs.

Anti-corruption

Combined Footprint Sharpens Focus on Anti-Corruption Compliance

Not only is Marathon Petroleum Corporation now leading our industry coast to coast, our footprint is more international than ever. Beyond our existing presence in Canada, our touchpoints now include operations and employees in Mexico and Singapore.

With this exciting international landscape comes heightened risk for issues related to potential corruption and bribery. MPC maintains an Anti-Corruption Policy, which prohibits bribery and other corruption pursuant to laws, including the U.S. Foreign Corrupt Practices Act (FCPA).[1] The FCPA is a federal law that generally prohibits bribery of foreign government officials in connection with business as well as requires companies to maintain accurate books and records and adequate accounting and internal controls. MPC provides biennial training on the FCPA for employees whose jobs may require interaction with foreign government officials or employees of foreign government owned or controlled business enterprises, such as those listed here. 

As we embrace the opportunity to have a prescence beyond U.S. borders, we also understand the unique risks related to corruption inherently faced by maintaining those operations. Insight into that risk is provided by the annual Corruption Perceptions Index from Transparency International, which ranks 180 countries and territories in terms of perceived levels of public sector corruption according to experts and businesses. Rankings are based on a score of zero to 100, where zero is highly corrupt and 100 is very clean.  With a score of 29, Mexico, ranks 135 of 180, while Singapore, in contrast, ranks sixth with a score of 84. In 2017, the index concluded that more than two-thirds of countries scored below 50, with an average score of 43.

As we continue to expand our footprint, be sure to familiarize yourself with the applicable corporate policies and watch for enhancements to and additional training opportunities related to our anti-corruption and anti-bribery compliance program.  In the meantime, take a moment to educate yourself with the brief anti-bribery video included within this newsletter.

1 Andeavor’s Anticorruption Compliance Manual and Procedures, September 2018, remains in effect for transitioning Andeavor employees.