Q4 2018 Integrity Advocate

Celebrating MPC's Speak-Up Culture

The 2018 MPC Employee Survey results are in, and it’s time to celebrate our “speak-up” culture!  Ninety-five (95) percent of respondents said that, if they had a concern about unethical or illegal behavior, they would report it.  And 96 percent of respondents said they know how to report.  Employees also identified “integrity at all levels” as one of our company strengths.  These results are supported by the fact that, year over year, Integrity Helpline use at MPC continues to grow, with 2018 usage reaching 1,222 allegations and inquiries, the largest in MPC history.

  • 95% of 2018 MPC Employee Survey respondents say they’d report if they had a concern
  • 96% of 2018 MPC Employee Survey respondents said they know how to report a concern
  • 2018 Integrity Helpline received a record 1,222 allegations and inquiries

Both the survey results and our helpline statistics are a direct reflection of MPC’s commitment to its core value of integrity, manifested every day in the way MPC leadership proactively champions ethics and compliance.

IN ORGANIZATIONS CHARACTERIZED BY PROACTIVE COMMUNICATION AND WORKPLACE TRUST, EMPLOYEES ARE TO BELIEVE THAT THEIR MANAGERS AND SUPERVISORS ARE COMMITTED TO THEIR COMPANY’S VALUES1

 

While this tone from the top is impressive, it is just as important that each of us understand how to incorporate principles of integrity into our daily work.  Performing our jobs with integrity can mean a lot of things, like strictly adhering to our Code of Business Conduct and company policies, and understanding and mitigating the compliance risks we all face as part of our jobs. But it means so much more.

Performing with integrity also means speaking up—without fear of retaliation—and encouraging yourself and others to say something when standards aren’t being followed.  This is not always easy, and sometimes, it can even mean openly disagreeing with colleagues and trying to figure out where to turn for answers and support. 

Performing with integrity means holding yourself accountable by accepting responsibility for your mistakes. Indeed, those who perform with integrity take ownership and do not blame others when things go wrong.

Performing with integrity may just mean simply pausing to ask yourself, “What is the right thing to do,” even if it means the Company loses money, business or customers.  

Integrity is also demonstrated by genuine workplace interactions. Employees should feel valued and heard and be shown—as well as treat others with—respect, honesty and dignity.  Workplace trust forms as a result of showing others that that you care about them and that you are willing to listen to concerns.

Indeed, when it comes to acting with integrity, it can be just as important to listen as it is to talk. In fact, listening to concerns is one of the primary reasons for our Integrity Helpline. Internal reporting systems such as the helpline foster trust and transparency within an organization. And trust and transparency are keys to maintaining a speak up culture, where employees are willing to come forward to report potential illegal or unethical conduct.

Understandably, one might assume that more internal reporting suggests a troubled, possibly toxic corporate culture.  However, in fact, a recent study from George Washington University[1] found that the opposite is true:  more internal reporting correlates to better business performance in the form of:

1.     Greater profitability and workforce productivity;

2.     Fewer material lawsuits and lower settlements; and

3.     Fewer external whistleblower reports to regulatory agencies and authorities. 

Indeed, the study concluded that increased use of internal reporting systems positively affects the financial return on a company’s bottom line because reporting helps companies identify and resolve problems more quickly. The healthier the reporting system, the greater the business return on investment.

Study Findings: There is a correlation between increased use of internal reporting systems and improved business performance

As we begin 2019, take time to reflect on and evaluate the way integrity affects your daily work, to consider the way you set an ethical example for others, and to celebrate your commitment to maintain the “speak-up” culture that makes our company perform better and of which we are so very proud. 

1 Ethics & Compliance Initiative, Building Companies Where Values and Ethical Conduct Matter (October 2018)

2Stubben, Stephen and Welch, Kyle T., Evidence on the Use and Efficacy of Internal Whistleblowing Systems (October 26, 2018).  Available at SSRN: http://ssrn.com/abstract=3273589

Who is Your BI&C Partner?

What do Heather Boehler in IT, Mindy Kuhn in ESS&PQ, Isaac Perkins in MPL, Adrian Pringle at GBR and Josh Swaney in Marketing all have in common?  They are among the 65+ individuals throughout our company who serve as Business Integrity and Compliance (BI&C) Partners. Review the list of BI&C Partners to find out who serves this role in your organization/group.

Heather Boehler, IT Systems Integrator, conducted an integrity survey with IT employees to improve ethics and compliance related training and communication within IT.

Mindy Kuhn, Quality Professional, designed and distributed badge cards to ESS&PQ employees that includes a decision tree for accepting gifts on one side and accepting entertainment on the other. These badge cards were adopted by other organizations and are now also distributed by BI&C in training sessions.

Isaac Perkins, Advanced Human Resources Consultant, as part of MPL’s third annual Ethics & Integrity Week, coordinated the Knowing the Ethical Boundaries Workshop. This was a one-hour interactive workshop wherein improvisational actors from The Sapphire Theatre Company and participants navigated through challenging ethical scenarios.

Adrian Pringle, Advanced Human Resources Consultant, hosts a quarterly BI&C Breakfast to which he invites GBR employees to join to discuss ethics and compliance topics.

Josh Swaney, Sales Manager, developed, in conjunction with Marketing’s Ethics and Integrity iValues Team, the Let’s Talk Program, a quarterly initiative for Marketing supervisors to bring real-life scenarios to Marketing employees for discussion in small groups.

Indeed, since 2014, the BI&C Partner Program has cultivated and trained a select group of individuals—nominated by management—to help serve as ambassadors for integrity, ethics and compliance in their respective organizations. BI&C Partners help to strengthen our ethics and compliance (E&C) program as well as assist BI&C to more fully realize its mission, vision, and motto to Inspire Integrity - Everywhere, Everyone, Always.

Responsibilities of the BI&C Partner include:

  • Actively look for opportunities to work with organization and local management to increase employee awareness and understanding of the MPC/MPLX/Andeavor Logistics Code of Business Conduct; Speedway Code of Business Conduct and Company policies;
  • Encourage the reporting of suspected illegal or unethical conduct to a supervisor, manager, Internal Audit, Law, 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 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 publications and other materials promulgated by BI&C; and
  •  Provide feedback to BI&C on the effectiveness of its strategies, communications and training.

Designated groups within MPC and Speedway have at least one BI&C Partner who serves as a liaison between BI&C and the employees within their respective Partner’s group.  Beginning in 2019, BI&C will expand its program to include legacy Andeavor business units and locations.

Programs like MPC’s BI&C Partners are a best practice in the ethics and compliance space.  Typically referred to as “ethics ambassadors” (EA) or “ethics liaisons,” individuals in these roles are increasingly used and relied upon as an effective and cost-efficient supplement to a company’s overall ethics and compliance (E&C) program.  

In September 2017, 19 companies, including MPC, participated in a benchmarking study conducted by the Ethics and Compliance Initiative (ECI).   The results of the study are documented in a best practices white paper titled ECI Benchmarking Group on Ethics Ambassador Programs.  The study found that an EA is most often a regular, full-time employee who assumes responsibility for supporting and promoting the E&C program in addition to his or her primary role, which is usually not related to ethics. For the EA, taking on this supplemental role offers opportunities to learn and practice new skills, gain visibility into new and different facets of the organization, interact with a broader group of colleagues, and enjoy a new level of exposure to leaders. 

It also found that best practice programs appoint at least one EA in each business unit, provide for leadership nomination of EAs, and require a 1 to 3-year commitment, all characteristics shared by MPC’s BI&C Partners Program.  MPC’s program also tracks leading EA programs in that it is supported by the Business Integrity and Compliance office through Partner meetings, collaboration on training, and access to communication, toolkits, and other resource materials.  

MPC is known for its excellence and leadership in our industry; its performance in the ethics and compliance space is no different. ECI’s study confirms what we’ve known all along: our Partners Program is among the leading of its type and is best in class in terms of its characteristics and attributes.  We look forward to the upcoming expansion of the program as part of the combined company integration.

Glad You Asked

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

Q: I’ve been offered a contract to provide some training to programmers at an engineering firm that serves the natural gas industry.  Is this okay?

A: Side jobs are fine if they don’t create a conflict of interest.  Policy #2006 Conflicts of Interest outlines potential conflicts as:

  • When an employee or immediate family member engages in the same kind of business as MPC or its affiliates and the employee can influence a business decision by MPC or its affiliates, the competitor, or the outside business;
  • When an employee or immediate family member owns a beneficial interest in a competitor or in a business that does business with MPC or its affiliates and the employee can influence a business decision by MPC or its affiliates, the competitor, or the outside business;
  • When an employee or an immediate family member serves as a director, officer, employee or agent of an organization that’s a competitor or has a business relationship with MPC or its affiliates; or 
  • When an employee engages in a personal business venture that prevents devotion of the loyalty, time and effort required by MPC or its affiliates. 

As long as your situation doesn’t fit into one of the scenarios outlined above, you should be in the clear.  It is, however, important to remember that, in accordance with Policy #12002 Internal and External Release of Proprietary Information, you should not share any non-public information or proprietary information regarding the company's business and/or processes with outside parties, including relatives. You should also notify your supervisor of your plans. Your personal business venture should neither take away from your devotion of the loyalty, time and effort required by the Company nor utilize work resources.

Q: One of my employees attended a national conference and submitted a gifts and entertainment disclosure for a voucher for a training class worth $2,000 from the association running the conference. This week, she was notified she was selected as the winner of a refurbished laptop from one of the vendors at the conference. Can she accept both gifts?

A: Policy #2009, Meals, Gifts and Entertainment provides instruction for the acceptance and reporting of meals, gifts and entertainment.  In accordance with the policy and supporting guidelines, this employee may accept the laptop provided that she obtains approval from her supervisor using the online Gift and Entertainment Disclosure process.

Q: What is our company's policy on an intern dating a full-time employee in another department?

A: MPC does not have a “dating policy” per se.  However, any personal relationship between two employees should not negatively impact their work performance, create a conflict of interest, or put the company at risk.  If you're aware of any personal relationship with these impacts, please discuss it with the individual’s supervisor, Human Resources, or Business Integrity and Compliance.

Q: Given the recent incident involving Ohio State’s assistant football coach, Zach Smith, I’m wondering what our reporting structure is here at MPC?

A: Page 22 of the MPC Code of Business Conduct speaks to reporting non-compliance.  If you suspect or have knowledge of illegal or unethical conduct related in any way to the Company, you should report it to your supervisor, your supervisor’s manager, Internal Audit, Law, Human Resources, Business Integrity and Compliance, Environment, Safety & Security or the Integrity Helpline.  Policy #2008 Reporting of Illegal or Unethical Conduct also speaks to the steps an employee should take to report suspected illegal or unethical conduct. 

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: Contractor working full-time in an MPLX field location was running a personal business on MPLX paid time.

The Response: An investigation found this to be true. The contract worker was removed from the MPLX project and field location.

The Concern: MPC employee received “loan” payments from contractor, and the contractor’s billable manpower was much higher than the projected manpower needs.

The Response: Contractor admitted giving “loans” to the MPC employee; review of contractor badge records and video footage confirmed contractor supervisors were badging in multiple contract workers when the workers were not physically present or working.  Both the MPC employee and contractor no longer work for/with MPC.

The Concern: Employee is harassed by a co-worker who obtained her personal contact information from company contact list. Co-worker repeatedly contacts employee on her personal telephone number and Facebook and touches her inappropriately at work. Employee is afraid of this co-worker, who has a history of anger outbursts at work.

The Response: The investigation substantiated the female employee’s claims. The harassing co-worker no longer works for the company and has been banned from entering company premises by management and law enforcement.

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).