Philosophy and Purpose
At MPC, we view participation by the Company in the public policy process as essential to promoting the best interests of our shareholders.
MPC’s business – the refining, transportation and marketing of fuels – is heavily regulated by federal, state and local governments. As a result, developments in Washington, D.C. and in the capitals of the states where we do business can significantly affect our ability to meet the need for reliable, affordable transportation fuels and other petroleum products. Some legislative and regulatory proposals could adversely affect MPC and the industry as a whole. MPC advocates for its own interests and for those of the industry, with three primary areas of focus: maintaining a strong refining and marketing industry in our nation; continuing to meet the energy needs of consumers at competitive prices; and protecting the value of our shareholders’ investments.
The Company participates in the political process in a number of ways, including lobbying, grassroots activity, issue advocacy, participation in trade associations, supporting an active employee political action committee and, where lawful, the direct support of political candidates and ballot issues. Federal, state and local laws and regulations govern certain aspects of corporate involvement in activities of a political or public policy nature, such as lobbying and making political contributions. These laws and regulations contain prohibitions and limitations, detailed reporting and record-keeping requirements and enforcement provisions. The Company has established policies and guidelines to ensure compliance with these laws and regulations, and to govern its participation in the political process.
All uses of Company funds or resources to participate in the political process are made with the intent to promote the best interests of the Company and without regard for the private political preferences of our executives. The entire process is subject to oversight by our Board of Directors and our senior management.
Because we believe participation in the political process is vital to a free and democratic society, we respect the right of and encourage our employees to engage in political activities of their choosing. When engaged in personal civic and political affairs, employees are to make it clear that their views and actions are their own, and not those of the Company.
Board and Management Oversight
MPC’s political contributions and lobbying expenditures are subject to the oversight of our Board of Directors and the approval of our senior management. As provided by the charter of the Board’s Corporate Governance and Nominating Committee, the Committee reviews on a semi-annual basis contributions made by the Company to political candidates, committees or parties and reviews on an annual basis lobbying expenditures, payments of $50,000 or more made to trade associations that engage in lobbying activities and the content of this Political Engagement and Disclosure portion of our website. Additionally, as noted below, members of our senior management team exercise oversight of trade association activities through an annual review, as well as through their own service in association leadership roles and their assignment of various employee technical and subject matter experts to support trade group committees and projects.
Government Affairs Organization and Compliance
Political activities by and on behalf of MPC are managed by our Government Affairs Organization. To ensure compliance with laws regulating political contributions and lobbying activities, and to ensure that such activities are aligned with the interests of the Company and its shareholders, lobbying contacts made on behalf of the Company with federal, state and local government officials and all political contributions by the Company are arranged through the management and other professional staff members of our Government Affairs Organization.
On an annual basis our Office of Business Integrity and Compliance circulates a Code of Business Conduct questionnaire and each salaried employee, executive officer and member of our Board of Directors is required to complete the questionnaire and sign an annual certification that includes a specific statement of compliance with our political activity policy. Our Internal Audit Organization routinely conducts reviews of the practices of and reporting documentation prepared by the Government Affairs Organization, as well as the eligibility of employees contributing to the Marathon Petroleum Corporation Employees Political Action Committee (MPAC), and reports its findings to senior management.
Federal Political Campaign Contributions
Federal laws and regulations strictly prohibit contributions of corporate funds to candidates for federal office or to third parties, such as political parties and political action committees, whose purpose is to contribute to or assist federal candidates. The Company’s policies and guidelines are intended to ensure compliance with these prohibitions. The Company is authorized by law to establish and pay certain administrative costs of an employee political action committee. Accordingly, the Company has established MPAC. Eligible employees, officers and directors of the Company may make contributions to MPAC. All such contributions are voluntary.
Subject to strict limits imposed by federal laws and regulations, MPAC may contribute funds to candidates for federal office, political parties, other political action committees and certain other political organizations. MPAC contributions are approved by a board comprised of Company employees and are available in an interactive map format on the PAC Contributions page of this website and will remain archived there for a period of five years. MPAC is registered with the Federal Election Commission (FEC) and reports its contributions to the FEC on a monthly basis. MPAC’s monthly reports and other information on its receipts and expenditures can be found on the FEC’s website by searching for “Marathon Petroleum Corporation Employees Political Action Committee."
State & Local Political Campaign Contributions
Individual state and local laws govern contributions to candidates for state and local offices. Where permitted by applicable law, and in consultation with and upon the approval of our Government Affairs Organization and designated member of our senior management team or their designee, the Company may, directly or indirectly, contribute corporate funds to candidates for state or local office or political parties that support or assist candidates for state or local office. Also where permitted by applicable law, the Company may use Company funds, properties or services for the purpose of influencing the nomination or election of candidates to state or local office, providing assistance or support to candidates seeking election to such office or supporting ballot measures or other issue-related campaigns.
MPC reports its state and local political contributions and expenditures as required by applicable law. Not all states and localities require reports of political contributions or expenditures, or provide access to such reports on line. MPC’s corporate political contributions are available in an interactive map format on the Corporate Contributions page of this website and will remain archived there for a period of five years.
In many states, including states where corporate contributions are not permitted, MPAC may make contributions to state and local candidates, subject to limits established by applicable state or local laws or regulations. MPAC contributions to state and local candidates are available in an interactive map format on the MPAC Contributions page of this website and will remain archived there for a period of five years and may also be found on the FEC’s website by searching for “Marathon Petroleum Corporation Employees Political Action Committee."
MPC engages in lobbying at the federal, state and local levels to advocate on issues that impact the Company and our industry. Separate Federal, state and local statutes govern these lobbying and reporting requirements.
The Company complies with the federal Lobbying Disclosure Act (LDA) by filing quarterly reports of our lobbying activities and expenditures, and semi-annual reports of MPAC’s federal political contributions. The Company’s LDA reports are available on the Lobbying Disclosures page of this website and will remain archived there for a period of five years and may also be found on the website of the Clerk of the U.S. House of Representatives by searching for “Marathon Petroleum Corporation” in the registrant field.
Some states also require the filing of reports of lobbyingactivities and expenses. The Company files these reports where it is required to do so by applicable law. Not all states require reports of lobbying activities and expenditures. The map on the Lobbying Disclosures page of this website depicts the states in which the company (including any subsidiaries) is currently or has been within the past five years registered as an employer or principal of lobbyists (including company employees or independent contractors). Many of these states maintain a publicly available database of lobbying disclosure reports and registrations.
Trade Association Participation
Like most large companies, MPC is active in trade associations and similar groups at the national, state and local levels, including the American Petroleum Institute, American Fuel and Petrochemical Manufacturers, U.S. Chamber of Commerce and National Association of Manufacturers. We believe participation in these associations is important to the Company’s role as an industry leader and as an active member of the business communities in which we operate. These associations engage in many activities for the benefit of their members, including encouraging industry standards among member companies. A list of the trade associations in which the Company incurred dues greater than $50,000 in the previous calendar year and that may engage in lobbying activities is available on the Trade Association Membership page of this website.
While not our primary motivation for joining or maintaining our membership, many trade associations actively engage in lobbying on issues that impact their respective members. Through our participation in trade associations, we seek to champion legislative solutions that are in the best interests of the Company. We believe it is important to be engaged with these organizations so our positions on issues of importance to the Company can be expressed. On an annual basis our senior management undertakes a review of trade association memberships and assesses the effectiveness of the respective groups and the utility of MPC’s new or continued participation. We also pride ourselves on taking an active role in our trade associations and have executives, technical experts and other personnel serving in various leadership and support roles within such groups. We recognize that viewpoints of other trade association members may differ from our own. When this occurs, we seek to work with the association membership to promote reasonable compromise. However, we do not control the position that any trade association may take on any particular issue.
MPC’s grassroots activities are designed to encourage broad support for favorable action on legislation important to the Company. Grassroots activities include the development and distribution of information and the mobilization of stakeholders to contact officials. The Company encourages grassroots activity on a case-by-case basis as determined by, and based on collaboration between, appropriate Government Affairs and business unit personnel, and with the approval of an appropriate member of senior management or his or her respective designee.
For MPC’s purposes, issue advocacy is the support of a pro-energy or other pro-business measure, or the opposition to an anti-energy or other anti-business measure. The Company engages in such advocacy when it has a significant business interest in a particular issue, subject to consultation with and the approval of members of senior management or their respective designees.
Gifts to Elected Officials, Regulators and Government Employees
Federal law prohibits registered federal lobbyists and entities, such as the Company, that employ federal lobbyists from providing gifts or anything of value to members of Congress or congressional staffers. Separate and similarly strict rules apply to officers and employees of the executive branch of the federal government. Additionally, many state and local governments have enacted various types of gift laws and regulations applicable to their elected officials and public employees. The Company has adopted policies and guidelines that are intended to assure compliance with these prohibitions.
Other Political Activities
The Company may periodically contribute or use funds to support or oppose ballot initiatives, or promote get-out-the-vote or other generic campaign activities, issue advocacy and other political activities as permitted by applicable law. Any such contribution or expenditure requires consultation with and the approval of members of senior management or their respective designees.