Q1 2025 Integrity Advocate

Commitment to  Compliance and Ethics

At MPC, our Compliance and Ethics (C&E) Program aims to inspire a culture where all employees act legally and ethically and feel empowered to speak up without the fear of retaliation. Our vision is to create an environment where compliance and ethics are valued from top to bottom, and misconduct is rare. We promote a “do the right thing” mindset and actively encourage employees to raise concerns freely and confidently.

Our Boards of Directors provide critical oversight, while senior management is responsible for managing legal and ethical risks. To lead these efforts, MPC appointed Chief Compliance Officer, Michelle Benavides, who reports to the Chief Legal Officer and Corporate Secretary. Michelle leads the Law-Compliance & Ethics team which includes an attorney that supports our C&E Program and serves as subject matter expert for certain compliance topics and the office of Business Integrity and Compliance (BI&C), which is delegated day-to-day operational responsibility for our C&E Program.

Business Integrity and Compliance

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 potential or actual unlawful or unethical conduct anonymously.  All allegations of misconduct are reviewed and investigated to the extent needed based on the nature of each allegation and requests for confidentiality within the context of each investigation are diligently honored to the extent possible. 

BI&C educates the workforce and promotes its C&E program through a comprehensive communication and training plan, including anticorruption training, monthly updates and learning points on company policies, as well as a fulsome report on integrity and compliance issues. 

To maintain its vast reach, BI&C draws on the assistance of a network of more than 70 Business Integrity 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 (Code), company policies and the company’s values.  

In addition, BI&C is responsible for:

  • Administering, advising and training on the Code through bi-Annual Code of Business Conduct Training and the Annual Code of Business Conduct Questionnaire and Certification process.
  • Overseeing the annual certification for the Code of Ethics for Senior Financial Officers and survey of the Board of Directors as to compliance with or violations of the Code.
  • Maintaining and ensuring access to company policies. 
  • Overseeing Business Courtesies, the New Hire and Interim Disclosure processes and providing guidance to manage potential conflicts of interest. 
  • Providing in person training on the company’s ethics and compliance program and our Convercent system and answering questions regarding company policies, including the Business Courtesies (meals, gifts, entertainment & hospitality) Policy.  
  • Providing 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 Committees of the Board of Directors for both MPC and MPLX. 
  • Hosting an enterprise-wide Corporate Compliance & Ethics Week celebration to help raise awareness and reinforce the importance of an ethical culture. 

Please visit the BI&C SharePoint site for additional resources and feel free to contact us at [email protected] with questions.

Empowering Employees Through Communication and Training

MPC’s Global Compliance and Ethics Program reflects an unwavering commitment to conducting business with the highest standards of integrity, as outlined in the Company’s Code of Business Conduct (the "Code"). 

The Law-Compliance and Ethics team recognizes providing employees with the tools and resources necessary to understand and manage potential compliance risks is crucial to empowering ethical decision making.  That’s why in 2024 the team, with Business Integrity and Compliance leading the charge, continued to prioritize communication and training to ensure all employees were well-informed about key compliance risks.

To support this effort, our monthly publication, Compliance Connection, covered essential topics such as conflicts of interest, data privacy, insider trading, and political activity. Additionally, The Integrity Advocate, published three times per year, worked to further embed compliance and ethics knowledge across the organization. Each issue of The Integrity Advocate included sections such as "It Happened Here," which shared anonymized case studies from Code investigations, or "Glad You Asked," which answered employee-submitted questions on compliance topics. This publication also featured articles and videos designed to help employees practice ethical decision-making. In 2024, Compliance Connection and The Integrity Advocate emails were opened 164,157 times, reflecting strong engagement with these vital communications. 

 

Additionally, as highlighted in the image to the right, thousands of employees participated in targeted training on the Code and Anticorruption policies.  These trainings, along with our ongoing communications, demonstrate a significant level of employee engagement and commitment to maintaining high standards of compliance across the organization.

Looking Ahead

The communication and training efforts we have highlighted here are just one example of how we strive to foster a best-in-class compliance program focused on:

  • Creating value
  • Mitigating risk
  • Reflecting our Core Values
  • Ensuring the long-term success of MPC

As we continue our work in 2025, we maintain this focus and a devotion to ensuring that every employee has the resources and support needed to make ethical decisions and uphold our Code.

Thank you for your continued dedication to maintaining a workplace that reflects our Core Values and contributes to the long-term success of MPC.

It Happened Here


The following scenarios happened with employees at our company. Situations and descriptions have been edited to maintain anonymity and confidentiality.

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

The Concern: An employee was reported for making inappropriate comments during a team meeting.

The Response: The investigation confirmed that the employee made racially insensitive and non-inclusive comments to co-workers during a team meeting in violation of Policy #10003 – Harassment and Appropriate Workplace Conduct. Employee received formal coaching, including a requirement to complete several training sessions; clear expectations for future behavior were set.

The Concern: An employee provided lunch to a small group of U.S. Government Officials without receiving preclearance.

The Response: The investigation confirmed that an employee did in fact provide lunch to a group of U.S. Government Officials without the preclearance required by Policy #2009 – Business Courtesies. Preapproval from Compliance Counsel is required for all Business Courtesies to U.S. Government Officials because federal and state laws restrict the value and type of Business Courtesies that can be provided.  The employee was counseled on the need for preclearance of all business courtesies involving U.S. Government Officials.

The Concern: A report was received regarding the adherence to safety protocols by MPC employees working on a public roadway. 

The Response: The investigation confirmed that while employees had taken various safety precautions, they were not utilizing additional safety measures that would further alert passing motorists of the work being conducted on the roadway. The employees were counseled on safety standards and safety conditions continue to be monitored.

The Concern: An employee was reported for making sexually explicit, vulgar and derogatory comments to co-workers either in the workplace and/or on their company mobile device

The Response: The investigation confirmed the employee had in fact made sexually explicit, vulgar and derogatory comments including inappropriate sexual jokes to co-workers and using his company mobile device to send sexualized texts in violation of policies #2001 - Code of Business Conduct, #10003 - Harassment and Appropriate Workplace Conduct, and #6002 - Use of Company and Personal Information Systems for Company Business. The employee no longer works for the company.

 

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].