Philosophy and Purpose
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 capitols of the states where we do business can significantly affect our ability to meet market needs for reliable, affordable fuels. 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.
MPC believes that its participation in the political process is very important to, and in the best interests of, our shareholders. 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 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 corporate 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 must be made with the intent to promote the best interests of the Company. The entire process is subject to oversight by senior management and the Corporate Governance and Nominating Committee of our Board of Directors.
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 the Marathon Petroleum Corporation Employees Political Action Committee (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. MPAC may also contribute to political parties, other political action committees and certain other political organizations. All of MPAC’s contributions are approved by a board comprised of Company employees. 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 members of senior management or their respective designees, 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.
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. Information on MPAC’s contributions to state and local candidates may be found on the FEC’s website by searching for “Marathon Petroleum Corporation Employees Political Action Committee."
Other Political Activities
The Company may periodically contribute or use funds to support or oppose ballot initiatives, or promote get-out-the-vote and generic campaign activities, issue advocacy and other political activities as permitted by applicable law. Any such contribution or expenditure involves 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 gift 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.
MPC engages in lobbying at the federal, state and local levels to advocate on issues that impact the Company and our industry. Federal, state and local statutes govern 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 for review 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 lobbying activities 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.
Trade Association Participation
MPC actively participates in trade associations and similar groups at the national, state and local levels, including the American Petroleum Institute, American Fuel and Petrochemical Manufacturers, American Chemistry Council, U.S. Chamber of Commerce and National Association of Manufacturers. 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 actively engaged with these organizations so our positions on issues of importance to the Company can be expressed. 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 to which we belong 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 participates in grassroots activity on a case-by-case basis as determined by, and based on collaboration between, appropriate Government Affairs and business unit personnel. Any such activity involves consultation with and the approval of members of senior management or their respective designees.
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.
Management and Board Oversight
MPC’s political contributions and lobbying expenditures are subject to the approval of the senior management of the Company and to oversight by the Corporate Governance and Nominating Committee of our Board of Directors. The Company’s political contributions and lobbying expenditures, as well as contributions made by MPAC, are reviewed by the Corporate Governance and Nominating Committee on a semi-annual basis.