Q2 2025 Integrity Advocate
Sara McCarthy Joins Law - Compliance & Ethics
Law - Compliance & Ethics is pleased to welcome Sara McCarthy as a new Senior Counsel.
Prior to joining Marathon, Sara worked in Halliburton’s law department for 18 years, holding various roles in compliance and ethics, commercial contracting, and litigation.
Sara is located in Houston, TX, and is focusing her time supporting the Company on matters involving anticorruption compliance, sanctions and trade compliance, government contracting, and political engagement.
“I believe a company which values integrity and encourages a strong culture of compliance fosters a successful organization and employees. My role as Compliance Counsel is to help support and strengthen this compliance culture, by providing guidance to employees on compliance-related issues."
Sara can be reached at [email protected] or 281-717-1804.
Spotlight on Integrity: Celebrating Our Business Integrity Partners
At the heart of our company’s values are the individuals who go above and beyond to foster a culture of compliance and ethics, transparency, and trust. This month, we proudly spotlight two employees who have demonstrated commitment and initiative in their roles as Business Integrity (BI) Partners.
The mission of Business Integrity and Compliance (BI&C) is to promote a strong compliance and ethics program-one that educates, empowers, and encourages every employee to act legally and ethically and to report concerns without fear of retaliation.
To extend its reach, BI&C relies on a dedicated network of more than 70 BI Partners embedded within business units across the enterprise. These partners are instrumental in driving local opportunities to enhance employee awareness and understanding of our Code of Business Conduct, company policies, and our company values. They also support ethics communication efforts, provide feedback on key messages, and help promote compliance initiatives to employees throughout their organizations.
The following spotlight highlights our featured BI Partners, recognizing their leadership and contributions to building a workplace grounded in our core value of integrity.
BI PARTNER SPOTLIGHT
Please join us in celebrating and thanking your BI Partners for being champions of compliance and ethics. Their dedication strengthens our culture and ensures that our company remains a place where doing the right thing always comes first.
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: Does our Code of Business Conduct discuss consulting and consulting adjacent opportunities. Do we have any rules against consulting?
The Answer: Policy #2006 - Conflicts of Interest, addresses possible situations and/or relationships that might create a potential conflict of interest. Each situation must be evaluated on individual facts and circumstances. To determine if a consulting opportunity caused a conflict of interest, we would need additional information. For example, what your role and job duties are at Marathon, what type of consulting – functions and services would be provided, to whom services would be provided, how much time would be devoted to consulting, etc.
The Question: One of our suppliers is hosting an event at which they will be handing out a cash prize. I’m assuming this would be a violation of our policy on business courtesies. My instinct is to shut this down, but I wanted to get your thoughts before doing so. I believe they can do this, but they just can’t award a cash prize. Is that correct?
The Answer: Policy #2009 Business Courtesies provides instructions for the acceptance and reporting of meals, gifts, entertainment and hospitality (travel/lodging). In accordance with the policy, acceptance of cash or cash equivalents is prohibited. A cash equivalent is defined as “a non-retail brand gift card/certificate, ticket, security or other instrument that is easily convertible to cash. Examples include an American Express®, Visa® or MasterCard® card that is not issued by a specific retail store, refundable airline tickets, shares of stock and gambling chips.” Such offers should be immediately reported to your supervisor, who will take appropriate action to discourage such Gifts.
The Question: A supervisor of a company we use for contractor services approached us and asked if Marathon would be willing to be a reference for their company. Is there a policy that would provide guidance for such interactions?
The Answer:
In general, participation in any testimonials, endorsements or promotions of individuals or other companies, products or services is prohibited in accordance with Policy #12002 Internal and External Release of Proprietary Information. Most of MPC’s agreements with business partners have non-publicity provisions in which the MPC-business partner relationship is itself confidential information. A seemingly innocuous referral could therefore result in the unauthorized disclosure of such relationship or other confidential information in violation of our agreements. Additionally, if the intent of the referral is to garner favor for the recipient, it would make it a work-related endorsement, which would make it a violation of the current MPC policy.
Contact the Law organization before making any testimonials, endorsements or promotions related to MPC-business of individuals or other companies, products or services.
Click here to review additional inquiries and responses.
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].