Q3-4 2024 Integrity Advocate

The Answer: Since MPC will be participating as well, the event would be considered entertainment. If MPC were not participating it would be viewed as a gift rather than entertainment and additional reporting requirements would be necessary.  If a government official or commercial foreign government officials were invited, MPC's Guidelines for Business Courtesies require further reporting and pre-approval in Convercent. 

To learn more about reporting requirements and approvals, including for business courtesies with government officials or commercial foreign government officials, review MPC's Guidelines for Business Courtesies. You can email [email protected] if you need additional guidance on Business Courtesies. 

The Answer: MPC respects the rights of employees to engage in the political process and political activities in their personal capacities during non-work hours.  Policy #9001 – Political and Lobbying Activity requires employees who are considering running for or being appointed to public office to consider potential conflicts of interest  as explained in Policy #2006 – Conflicts of Interest.  Interested employees should discuss any potential conflicts and work arrangements with their supervisor, notify the Human Resources organization, and file an interim disclosure on BI&C’s SharePoint site. 

Remember, personal political activities should not be conducted on company premises, on company time or otherwise under any circumstances that would create the appearance that such activity is sponsored by the company. If you do accept a position in public office, you have an ongoing obligation to keep your supervisor and the company informed of this relationship.

The Answer: In accordance with Policy #2009 Business Courtesies and supporting guidelines, MPC personnel may accept, without supervisor approval, Meals, Gifts valued at $100 or less, and Entertainment valued at $200 or less.  Acceptance of all other Business Courtesies requires disclosure and supervisor approval in Convercent.  Since the business host providing the activity will be present, the activity is considered Entertainment. However, if the business host providing the activity was not present, the activity would be considered a Gift under the Policy.  Other things you should consider before accepting the Business Courtesy include: 1) whether the gift of entertainment is lavish, frequent, lewd, offensive or unusual in nature; 2) whether the gift or entertainment is intended to create an obligation or provide undue influence; and 3) whether the gift or entertainment is offered during the time of contract negotiations.  

Given the information provided, it is unlikely that the tailgating event alone would exceed $200.  Thus, there would be no disclosure requirement.  However, the winners of the raffle would need to submit a disclosure if the ticket (in conjunction with the tailgating event offerings) exceeds $200.  When calculating the value of Entertainment or a Gift to determine whether disclosure is required, any Business Courtesy accepted by a family member of and MPC employee is treated as though accepted by such MPC employee as well.