At Marathon Petroleum Corporation, we view participation by the company in the public policy process as an essential part of advancing the meaningful exchange of information and views on issues affecting our company and our stakeholders.
Philosophy
Marathon Petroleum Corporation 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. We engage on a variety of issues affecting our company and our stakeholders. As it relates to climate change, our public policy engagement is guided by our commitment to sustainability, including lowering carbon intensity of our operations and products, expanding renewable fuels and technologies, conserving natural resources, engaging stakeholders, and contributing in our communities. We support policies that complement this strategy and the investments that continue to transform our company.
Federal, state and local 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. The entire process is subject to oversight by our Board of Directors, general counsel and senior vice president of Government Affairs, and senior management.
Because 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 civil and political affairs, employees do not represent the company and their views and actions are their own, and not those of the company.
In our political engagement efforts, we focus on maintaining strong refining and marketing, midstream and retail industries in the U.S., continuing to meet the energy needs of consumers at competitive prices, and protecting the value of our shareholders’ investments.
Political Transparency
Marathon Petroleum Corporation’s business 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 safe, reliable, affordable and sustainable energy and products. We recognize that our public policy activities are of interest to our shareholders and other stakeholders, and therefore make the voluntary disclosures found on this website.
Additional Information
Board and Management Oversight
Marathon Petroleum Corporation’s political contributions and lobbying expenditures are subject to the oversight of our Board of Directors, general counsel and senior vice president of Government Affairs, and senior management. The charter of the Board’s Sustainability and Public Policy Committee articulates the purpose for the Committee and sets forth broad responsibilities that the Committee implements in the following ways:
- Oversight of the company’s governance framework for political engagement and public policy development
- Oversight of budgets for lobbying expenditures and review of the company’s advocacy positions
- Oversight of budgets for payments made to trade associations that engage in lobbying activities and review of the advocacy positions of our trade associations, including their positions on climate
- Oversight of budgets for contributions to political candidates, committees or parties
- Review of reports and disclosures regarding such expenditures and contributions
Additionally, members of our senior management team exercise oversight of trade association activities through an annual review, as well as through their own involvement and assignment of various employee technical and subject matter experts to support trade group committees and projects. Please see our Sustainability Report for more information on Sustainability Governance.
Government Affairs Organizations and Compliance
Political activities by and on behalf of Marathon Petroleum Corporation are managed by our federal and state government affairs organizations. 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 organizations.
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 Audit, Assurance and Advisory Services organization routinely conducts reviews of the practices of and reporting documentation prepared by the government affairs organizations, 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 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, 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 the PAC Contributions section above 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 and 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 management and designated members 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.
Marathon Petroleum Corporation 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 online. Marathon Petroleum Corporation’s corporate political contributions are available in the Corporate Contributions section above 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 the PAC Contributions section above 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."
Lobbying Activities
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. LDA reports filed by the company as well as retained lobbying firms may be found on the website of the Clerk of the U.S. House of Representatives by searching for “Marathon Petroleum” 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. The Lobbying Disclosure section above contains 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 companies, Marathon Petroleum Corporation is active in trade associations and similar groups at the national, state and local levels. Taking part in these associations is an important part of our role as an active member of our industry and the business communities in which we operate. These associations engage in many activities for the benefit of their members, including developing industry standards and best practices. Trade associations provide an important forum for us to engage in the development of these standards and practices, and to share advances in science and engineering that inform the best practices of the future.
Through our trade associations we seek to champion legislative solutions that are in the best interests of the company and our stakeholders. 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 Marathon Petroleum Corporation’s new or continued participation. We recognize that viewpoints of other trade associations 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.
Information concerning the company's participation in trade associations with dues of $50,000 or greater and that may engage in lobbying activities is provided for the years 2023, 2022, 2021, 2020 and 2019 .
Trade Associations and Climate Policy
We recognize the importance of a collective effort to develop a comprehensive sustainable energy strategy to provide all people on the planet a chance at prosperity while continuing to reduce greenhouse gas emissions. We also believe there should not be a “one-size-fits-all” business strategy that every company must adopt. An effective solution will take into account the enormous complexity of the global energy system, the varying needs from region to region, and companies' differing operational footprints.
We are encouraged by our trade associations’ recent positions on climate change and we believe our industry has an opportunity to coalesce around the development and delivery of solutions.
It is critical that our trade associations are working to help our industry address climate challenges. When our trade associations engage on climate policy, we strive to encourage them to take positions that are not inconsistent with our commitment to sustainability, including lowering carbon intensity of our operations and products, expanding renewable fuels and technologies, and conserving natural resources. As part of this, we expect them to conduct their climate-related lobbying activities in alignment with the ambition of the Paris Agreement to reduce global GHG emissions and limit global warming to well below 2 degrees Celsius.
To evaluate whether our trade associations currently meet this expectation, MPC weighs a number of considerations, including:
- Whether the trade association explicitly supports the ambition of the Paris Agreement to reduce global GHG emissions and limit global warming to well below 2 degrees Celsius
- Whether the trade association demonstrates a commitment to convene its membership to advance climate action
- Whether the trade association advocates in ways that support our commitment to sustainability, which includes lowering carbon intensity of our operations and products, expanding renewable fuels and technologies, and conserving natural resources
These considerations likewise inform our dialogue with our trade associations throughout the year and as to specific climate-related legislative proposals. Because we do not control the position of any trade association, they do not always end up endorsing our preferred positions. Our company may take positions that are different from, or extend beyond the scope of, trade association platforms.
We believe that the recent climate positions of our trade associations, including the American Petroleum Institute, American Fuel & Petrochemical Manufacturers, National Association of Manufacturers, and Western States Petroleum Association (our largest national and regional trade associations), are not inconsistent with the ambition of the Paris Agreement. We commit to evaluate the positions of our trade associations over time and to disclose if their positions become inconsistent.
To mitigate potential risk of future misalignment, we have engaged with each of our trade associations to communicate our lobbying expectations and our plans for ongoing evaluation and disclosure. Finally, we have communicated our commitments and expectations to our employees who liaise with these organizations.
We believe it is critical to remain engaged in these policy debates – both as a company and as an industry.
Below is a summary of the climate positions of MPC’s trade associations with dues of $50,000 or greater and that may engage in lobbying activities:
Advanced Biofuels Association (ABFA)
- To help meet energy and climate targets, ABFA supports and advocates for public policies that are technology neutral, afford flexibility for the use of a variety of sustainable feedstocks and ensure viable advanced biofuels can compete with the benefit of a level playing field.
American Petroleum Institute (API)
- API’s Climate Action Framework includes a five-part action plan to 1) accelerate technology and innovation to reduce emissions while meeting growing energy needs; 2) further mitigate emissions from operations to advance additional environmental progress; 3) endorse a carbon price policy by government to drive economywide, market based solutions; 4) advance cleaner fuels to provide lower-carbon choices for consumers; and 5) drive climate reporting to provide consistency and transparency.
- API’s Climate Position and Policy Principles include support for global action that drives greenhouse gas emissions reductions. API supports the ambitions of the Paris Agreement.
- API’s Climate-related Reporting Initiative aims to develop more consistent and comparable reporting of key greenhouse gas indicators and has resulted in the publication of API Template 2.0 for GHG Reporting. The Template includes Scope 1 and 2 emissions, greenhouse gas mitigation, Scope 1 intensity, targets and reporting, and third-party verification.
American Fuel & Petrochemical Manufacturers (AFPM)
- AFPM’s climate issues statement acknowledges the reality of climate change and commits to the development of policies that enable members to supply products in an environmentally sustainable way.
California Business Roundtable (CBRT)
- CBRT is a non-partisan organization with Policy Issues focused on the state’s business climate, education, infrastructure, regulatory reform, tort reform and job creation. CBRT supported an extension of California’s Cap and Trade program.
Gas Processors Association (GPA Midstream)
- GPA Midstream co-developed an ESG Reporting Template to facilitate standardized information disclosure among the midstream sector, including greenhouse gas emissions, greenhouse gas reduction targets, participation in energy reduction programs, use of renewable energy, and use of third-party data verification.
Liquid Energy Pipeline Association (LEPA)
- LEPA’s Climate Change statement recognizes climate change is a challenge and commits to promoting innovations that minimize pipeline greenhouse gas emissions. Innovations LEPA is promoting to reduce GHG emissions include: encouraging improved pipeline operations with a focus on GHG emissions; investing in development and deployment of technologies that reduce emissions; engaging in research and development to better understand and manage emissions; and participating in the development of responsible policies that address climate change as part of a comprehensive plan for meeting the world's energy needs.
Louisiana Mid-Continent Oil and Gas Association (LMOGA)
- LMOGA asserts that Louisiana’s energy industry is committed to real, bipartisan policy solutions to reduce the risks of climate change, protect the environment and encourage economic growth. It supports Louisiana’s Climate Initiative Task Force and believes that through the efforts of the task force and the actions of LMOGA members, Louisiana can become a leader in climate change solutions.
Marcellus Shale Coalition (MSC)
- MSC’s Commitment to Climate includes a commitment to clean-burning American natural gas, air quality improvements, and accountability for the full life cycle and associated impacts of all energy resources in a fact-based manner. MSC asserts that a clean, reliable and resilient power grid based on natural gas and renewable energy sources working together is the only technologically feasible way of affordably meeting President Biden’s climate goals for a carbon-free electrical grid by 2035 and net-zero emissions by 2050.
National Association of Manufacturers (NAM)
- NAM's call for climate action includes support for improving the Paris Agreement; enacting a single, unified federal policy to manage greenhouse gas emissions; investing in energy efficiency; funding and expanding climate and clean energy research and development programs; modernizing the electric grid; and deploying carbon capture, utilization and storage technology.
Ohio Business Roundtable (OBR)
- OBR’s Priority Issues include energy, with the belief that Ohio is in dire need of a comprehensive energy policy that addresses all energy sources and provides stability and predictability. OBR advocates for energy decisions to be made on a less ad hoc basis, to consider the views of the entire energy sector, and to increase the transparency of the regulatory process at the Public Utilities Commission of Ohio.
Texas Oil & Gas Association (TXOGA)
- TXOGA is a member of the Texas Methane & Flaring Coalition established in December 2019 to develop solutions to reduce flaring and methane emissions with a goal to end routine flaring by 2030.
Waterways Council
- While not actively involved in energy policy, the Waterways Council’s Key Issues focus on advocating for investments to maintain and modernize water transportation infrastructure.
Western States Petroleum Association (WSPA)
- WSPA’s climate change issues statement supports members on the cutting edge of energy production and consumption changes, investing in and developing diverse energy sources and technologies of the future. WSPA acknowledges there is no more important challenge to address than climate change and supports the aspirations of the Paris Agreement.
Grassroots Activities
Marathon Petroleum Corporation’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.
Issue Advocacy
Marathon Petroleum Corporation engages in issue 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. As it relates to climate change, our issue advocacy on climate change is guided by our commitment to sustainability, including lowering carbon intensity of our operations and products, expanding renewable fuels and technologies, and conserving natural resources.
We are committed to conducting climate-related lobbying activities in alignment with the ambition of the Paris Agreement to reduce global GHG emissions and to limit global warming to well below 2 degrees Celsius. MPC evaluates climate-related legislative proposals within the totality of the bill in which they reside and determines the level of engagement and support, if any, that is appropriate. Recognizing that not all proposed climate-related legislation reflects sound government policy, that proposals may change significantly during the amendment process, and that legislation may have implications unrelated to climate, MPC takes a thoughtful and deliberate approach to the execution of this commitment.
With regard to a price on carbon, we support market-based approaches. An economy-wide price on carbon would be the most effective mechanism to drive emissions reductions at the lowest cost to society. Regarding low carbon fuel programs, we believe programs should be enacted in a manner that provides the most value for stakeholders. Where markets currently exist, such as California’s Low Carbon Fuel Standard, we are a major participant. We also support continued government investment in innovation through grant programs and guaranteed low-interest loans that can spur new technological solutions. Finally, we view cap and trade programs as the most inefficient and costly option for actually reducing carbon emissions.
The primary ambition of the Paris Agreement is to limit global warming to well below 2 degrees Celsius compared to pre-industrial levels. MPC and MPLX have committed to reduce our manufacturing (Scope 1 and 2) greenhouse gas emissions intensity 30% below 2014 levels by 2030 – a metric linked to executive pay – and MPLX will reduce gathering and processing methane emissions intensity 50% below 2016 levels by 2025 and 75% below 2016 levels by 2030. We are focused on continuing to reduce our carbon intensity, improve energy efficiency and make significant investments in renewables.
Recent examples of Paris-aligned advocacy:
- Sustainable Aviation Fuel (SAF): Increasing the commercial viability of SAF is a natural next step for the airline industry and the refining industry, and we look forward to supporting the airline industry’s efforts to reduce carbon emissions through SAF production. MPC broadly supports incentives from Congress and the Administration for SAF. We support the GHG reduction targets of the BTC, the duration (10 years) and the amount of the BTC. We have been advocating that incentives for SAF leverage the expansive waste, residue and agricultural feedstock potential in the United States in order to result in meaningful levels of production.
- Carbon Capture Utilization and Storage (CCUS) and Hydrogen: We are considering projects that would allow us to capture carbon from our facilities directly, be a hub to collect and sequester carbon from other facilities in the regions we operate, and collaborate through alliances exploring hydrogen energy production and utilization. MPC continues to support robust grant programs, as well tax incentives to provide the necessary drivers to advance these projects.
- Cellulosic pathways: We are considering projects that would increase our capacity to produce advanced biofuels, such as those made from cellulosic materials derived from plants. In order to do so economically, we are asking the EPA to evaluate the processes (or “pathways”) we use to procure and manufacture these cellulosic biofuels, and to categorize the cellulosic biofuels as advanced biofuels based on a lifecycle analysis of their greenhouse gas emissions.
- Renewable diesel pathways: Currently, the federal government classifies renewable diesel as “biodiesel,” which isn’t accurate. Renewable diesel is a drop-in substitute for petroleum diesel, while biodiesel must be blended with petroleum diesel or renewable diesel before it can be safely used as vehicle fuel. We’re asking the EPA to correctly categorize renewable diesel, which would enable us to provide more of it to the fuel market. We also requested that the EPA recognize canola oil as an approved renewable diesel feedstock under the Renewable Fuel Standard.
- Renewable Fuel Standard Set: As part of the RFS SET process, we are asking the EPA to prioritize GHG reductions. The RFS should recognize the benefits of certain practices – such as regenerative farming, renewable energy use, carbon capture, etc. – that lower the carbon emissions from both the use and production of fuels. By recognizing these practices, the RFS will better incentivize the production of cleaner-burning fuels and achieve more carbon reductions from the transportation sector.
We will continue to work with policy makers as they establish goals aligned with the Paris Agreement to pursue smart, effective regulations that allow us to meet energy demand affordably and sustainably.
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.