Marathon Petroleum Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Marathon Petroleum discloses a well-defined governance structure that covers both its own advocacy and its work through trade associations, with clear oversight and monitoring mechanisms. The Board-level Sustainability and Public Policy Committee is explicitly charged to oversee the governance framework and budgets for the Companys contributions to political candidates, committees or parties, lobbying expenditures, and certain payments made to trade associations that engage in lobbying activities and to review reports and disclosures regarding such contributions. Day-to-day responsibility is further delegated, as political activities by and on behalf of Marathon Petroleum Corporation are managed by our federal and state government affairs organizations, while members of our senior management team exercise oversight of trade association activities through an annual review. The company sets an alignment policy that its climate-related lobbying activities [be] in alignment with the ambition of the Paris Agreement to reduce global GHG emissions and limit global warming to well below 2 degrees Celsius, and states that MPC evaluates climate-related legislative proposals within the totality of the bill and determines the level of engagement and support, if any, that is appropriate, demonstrating a process for governing direct lobbying. For indirect lobbying, the company explains that on an annual basis, our senior management undertakes a review of trade association memberships, using criteria such as whether the trade association explicitly supports the ambition of the Paris Agreement and pledging to disclose if their positions become inconsistent, which indicates active alignment work rather than simple membership lists. Named governance owners span both Board and management: the Committee, the general counsel and senior vice president of Government Affairs, and senior management all review or sign off on lobbying activity. While this indicates strong governance of both direct and indirect climate-related lobbying, the disclosures do not reference a published, stand-alone lobbying-alignment audit or an independent third-party review, and there is no evidence of outcomes such as withdrawing from misaligned associations; therefore the transparency stops short of the most comprehensive level. View Sources	B

Overall Assessment

Analysis

Score

Strong

Marathon Petroleum discloses a well-defined governance structure that covers both its own advocacy and its work through trade associations, with clear oversight and monitoring mechanisms. The Board-level Sustainability and Public Policy Committee is explicitly charged to oversee the governance framework and budgets for the Companys contributions to political candidates, committees or parties, lobbying expenditures, and certain payments made to trade associations that engage in lobbying activities and to review reports and disclosures regarding such contributions. Day-to-day responsibility is further delegated, as political activities by and on behalf of Marathon Petroleum Corporation are managed by our federal and state government affairs organizations, while members of our senior management team exercise oversight of trade association activities through an annual review. The company sets an alignment policy that its climate-related lobbying activities [be] in alignment with the ambition of the Paris Agreement to reduce global GHG emissions and limit global warming to well below 2 degrees Celsius, and states that MPC evaluates climate-related legislative proposals within the totality of the bill and determines the level of engagement and support, if any, that is appropriate, demonstrating a process for governing direct lobbying. For indirect lobbying, the company explains that on an annual basis, our senior management undertakes a review of trade association memberships, using criteria such as whether the trade association explicitly supports the ambition of the Paris Agreement and pledging to disclose if their positions become inconsistent, which indicates active alignment work rather than simple membership lists. Named governance owners span both Board and management: the Committee, the general counsel and senior vice president of Government Affairs, and senior management all review or sign off on lobbying activity. While this indicates strong governance of both direct and indirect climate-related lobbying, the disclosures do not reference a published, stand-alone lobbying-alignment audit or an independent third-party review, and there is no evidence of outcomes such as withdrawing from misaligned associations; therefore the transparency stops short of the most comprehensive level.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Marathon Petroleum Corp provides extensive, concrete information on every facet of its climate-policy lobbying. It names multiple identifiable measures it works on, including the Renewable Fuel Standard Set process—where it asks “the EPA to correctly categorize renewable diesel” and to add canola oil as an approved feedstock—state and federal Low Carbon Fuel Standard programmes, and federal incentives for Sustainable Aviation Fuel, as well as economy-wide carbon-pricing proposals. The company also explains how it undertakes this advocacy. It details direct dialogue with the “EPA”, “Congress”, the “U.S. Department of Agriculture” and state and federal elected officials, participation in trade associations such as the American Petroleum Institute and the Advanced Biofuels Association, and “grassroots activities [that] include the development and distribution of information and the mobilization of stakeholders to contact officials.” Finally, it is explicit about the outcomes it seeks: an “economy-wide price on carbon,” incentives that will expand SAF production, recognition of regenerative-agriculture carbon sequestration so that “LCFS credits could be generated,” and government grants and tax incentives to accelerate CCUS and hydrogen projects. By clearly linking these desired regulatory changes to the specific policies and targets it pursues, the company demonstrates a high level of transparency in its climate-related lobbying.	A