Q3-4 2025 Integrity Advocate
Corporate Compliance &
Ethics Week
From November 2 through the 8, MPC will join organizations around the globe in celebration of Corporate Compliance & Ethics Week. This weeklong celebration—Integrity at our Core—offers the opportunity to shine a spotlight on the importance of compliance and ethics here at MPC.
Business Integrity & Compliance and our Business Integrity & Compliance Partners, located throughout the company, have a week full of giveaways, fun activities and prizes planned. Be sure to take a moment to participate in the festivities and to complete our Business Integrity Poll to let us know how we are doing! Your candid feedback will help ensure we are delivering on our commitment to compliance and ethics at MPC. Complete the Poll between now and November 13 to enter for a chance to win 100 Awardco points. Recipients can redeem their points for eligible items through the Awardco portal, including gift cards, concert tickets, hotels and more.
We hope you'll join us. A thriving ethics culture involves commitment, modeling, and the right conduct by all employees. Mark your calendars now and check out our Compliance & Ethics Week Page for more information. Keep Integrity at our Core—our reputation and success depend on it.
Newly Appointed BI&C Partners
Responsibilites of the BI&C Partner
- Actively look for opportunities to work with organization and local management to increase employee awareness and understanding of the Code of Business Conduct, company policies, Integrity as a Core Value, and our C&E program.
- Assist organization and local management to understand the disclosure and approval requirements associated with the Conflicts of Interest and Business Courtesies policies.
- Encourage the reporting of allegations to appropriate resources, including, but not limited to 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 specific 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.
- Distribute publications and other BI&C materials and help reinforce messaging, with special attention given during Corporate Compliance and Ethics Week in November.
- Provide feedback to BI&C on the effectiveness of BI&C’s strategies, communications, and training initiatives.
Who is your BI&C Partner
Designated groups throughout the enterprise have at least one BI&C Partner who serves as a liaison between BI&C and the employees within their respective Partner’s group. Do you know who your group’s appointed partner is? Visit the BI&C Partner Page on MPCConnect to learn more about the Program and find out who serves this role in your group.
MPC’s Global Presence and Continued Focus on Anticorruption Compliance
With operations and employees in Canada, Mexico, Peru, Singapore and the United Kingdom, MPC’s commitment to the highest standards of integrity is a global responsibility. Because operating internationally increases our exposure to unique risks — particularly around corruption and bribery — MPC maintains a strict Anticorruption Policy that prohibits bribery and other forms of corrupt behavior. Consistent with MPC’s commitment to integrity, the policy is designed to ensure compliance with applicable laws, including the U.S. Foreign Corrupt Practices Act (FCPA). 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.
To support this, MPC provides Anticorruption training every two years to employees whose roles may involve interacting with foreign government officials or employees of foreign government-owned or controlled business enterprises.
Understanding the Global Risk Landscape
As we continue to embrace a global footprint, it is important for us to stay informed about the environments in which we operate. One key tool we rely on is the Corruption Perceptions Index (CPI), published annually by Transparency International.
The CPI ranks 180 countries and territories based on perceived public sector corruption — scoring them from 0 (highly corrupt) to 100 (very clean).
The 2024 index revealed that:
- More than two-thirds of countries scored below 50,
- The global average remains at 43, and
- 148 countries have either stagnated or worsened in corruption rankings since 2012.
Undoubtedly, the global fight against corruption is far from over.
How MPC Manages Anticorruption Risk
To navigate these risks, our Compliance & Ethics (C&E) team uses the annual CPI rankings as a benchmark for conducting due diligence, as outlined in our International Business Partners (IBP) Manual.
This process helps assess the level of risk when working with new or existing international business partners. If significant red flags are uncovered, our C&E team works closely with relevant stakeholders to evaluate the risk and make informed decisions about whether to move forward with the partnership.
In light of our global footprint, every employee plays a role in protecting our reputation and ensuring compliance. Here’s how you can contribute:
- Review the IBP Manual to understand the protocols for international partnerships.
- Complete all required training related to anti-bribery and anticorruption.
- Watch the short anti-bribery video included in this newsletter — it’s a quick, practical refresher.
Thank you for staying informed, engaged, and committed to helping us operate responsibly and ethically wherever we do business.
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: I wanted to reach out to check the status of a Gift disclosure I submitted and see if additional information is needed. I submitted the disclosure, have not heard back, and want to make sure everything is ok before proceeding further.
The Answer: Thank you for reaching out with your question. As part of our normal process, your business courtesies disclosure was automatically routed to your supervisor for review when it was submitted. You will receive notification once the disclosure has been reviewed and processed by your supervisor.
The Question: I recently filed an application to be a village councilman where I live. It’s an elected position and won’t interfere with my duties here at Marathon. I wasn’t sure if there is any reporting or formal disclosure necessary to Marathon. Is there a specific policy or anything I need to do?
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 informed by 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 Question: Is it acceptable, under company policy, for an employee to add their non-company personal email under the Bcc (Blind Carbon Copy) field on a business-related email to a colleague?
The Answer: Under Policy #6002: Use of Company and Personal Information Systems for Company Business Authorized Users are prohibited from accessing, managing, communicating, creating, obtaining, transmitting, storing, or saving Business Information to Personal Systems, except (a) in times of emergency pursuant to active company-approved business continuity plans, (b) pursuant to the terms and conditions of MPC Group’s Bring Your Own Device (BYOD) Program, or (c) if deemed approved because it meets written criteria established and maintained by the MPC Group IT organization.
The Question: I am thinking about attending a software conference and the software company has offered to cover the cost of attendance due to our long-standing partnership. We are not currently in active negotiations with the software company so I am not as worried about a conflict of interest; however, I am wondering if I should report this as a gift. If so, and if the conference includes an entertainment event for all attendees (i.e., a happy hour with a live band one evening), should I report the entertainment separately or just the fee that was covered by the software company to attend the conference.
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 and supporting guidelines, acceptance (to attend the conference for free) is okay provided you obtain supervisor approval by submitting a Business Courtesies Disclosure prior to accepting. Instructions for doing so are available here: BI&C’s SharePoint site. There would be no further reporting with regard to happy hour and live music that are typically provided to all conference attendees and considered as being included with the attendance fees. That said, should you win any type of prize or gift(s) given during the conference, you would want to disclose that separately upon your return.
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].