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BOK FINANCIAL CORPORATION

Equal Employment Opportunity and Anti-Harrassment Policy

BOK Financial, and its family of brands, are committed to a work environment in which all individuals are treated with respect and dignity. Employees have the right to work in a professional atmosphere that promotes equal employment opportunities and is free from discriminatory practices, including all types of unlawful harassment.  

BOK Financial is committed to providing equal employment opportunities to all qualified employees and applicants without regard to race, religion, color, gender, sexual orientation, age, national origin, disability, military or veteran status, genetic information, or other criteria protected by federal, state or local law. This policy applies to recruitment, hire, promotion, transfer, termination, reduction in work force, training, compensation, benefits, and all other privileges, terms and conditions of employment. 

All employees are responsible for assuring that the workplace is free from discrimination and harassment, including sexual harassment, and should avoid any action or conduct which could be viewed as inappropriate or offensive.

PRACTICE

Prohibited Practices 

BOK Financial prohibits discrimination or harassment in all employment procedures where such discrimination or harassment is based upon an individual’s race, religion, color, gender, sexual orientation, age, national origin, disability, military or veteran status, genetic information, or any other criteria protected by applicable law. BOK Financial also prohibits retaliation against an employee where such retaliation is based upon the employee’s reporting or complaining about discrimination or harassment or upon the employee’s exercise of rights arising under laws prohibiting discrimination or harassment. 

Employment Discrimination is treating someone differently in the employment process because of their race, religion, color, gender, sexual orientation, age, national origin, disability, military or veteran status, genetic information, or other criteria as protected by federal, state or local law. 

Harassment is verbal or physical conduct that is derogatory or hostile toward a person because of his or her race, religion, color, gender, sexual orientation, age, national origin, disability, military or veteran status, genetic information, or other characteristic protected by law and that has the purpose or effect of: 

  • unreasonably interfering with an employee’s job performance; or
  • creating an intimidating, hostile or offensive working environment. 

Harassing conduct includes but is not limited to: derogatory or vulgar comments or jokes, epithets, slurs or negative stereotyping; threatening, intimidating or hostile acts; display or circulation of written or graphic material that denigrates or shows hostility or aversion toward an individual or group (including through e-mail). 

Sexual Harassment is defined as: Unwelcome sexual conduct when (1) submission to the conduct is an explicit or implicit term or condition of employment, (2) submission to or rejection of the conduct is used as the basis for an employment decision, or (3) the conduct unreasonably interferes with an individual’s job performance or creates an intimidating, hostile, or offensive working environment. Examples of sexual harassment are:

  • Repeated sexual flirtations, advances, or propositions.
  • Continued or repeated verbal abuse of a sexual nature.
  • Sexually related comments, jokes, or graphics.
  • Repeated degrading or sexually suggestive comments about an employee’s appearance.
  • The display of sexually suggestive objects or pictures, including any that may be obtained through the Internet or computer software programs.
  • Any uninvited physical contact or touching.

Individuals and Conduct Covered 

This policy applies to all applicants and employees, and prohibits harassment, discrimination and retaliation whether engaged in by a fellow employee, supervisor, manager or someone not directly connected to BOK Financial (i.e. customer, vendor or consultant).

This conduct is unacceptable in the workplace and in any work related setting outside the workplace, such as business trips, business meetings and business-related social events. 

Supervisors and/or employees engaging in sexual harassment are acting outside the scope of their authority on behalf of BOK Financial and are subject to disciplinary action, up to and including discharge.

Protection from Retaliation 

BOK Financial absolutely forbids retaliation of any kind against an employee who complains about alleged discrimination or harassment and will take disciplinary action against anyone who attempts to retaliate.

Reporting Procedure and Investigation

Employees are strongly encouraged to report all incidents of discrimination, harassment or retaliation, regardless of the offender’s identity or position. Individuals who have experienced conduct they believe is contrary to BOK Financial’s policy or who have concerns about such matters should address their concerns to one or more of the following: a) their immediate supervisor or manager, b) a Human Resources Manager or Consultant, or c) the Human Resources Compliance officer.

An employee may also anonymously make a report of discrimination, harassment or retaliation to the Employee Protection Line if uncomfortable with contacting a supervisor or Human Resources.

The telephone number for the Employee Protection Line is 1-800-576-5262, company code 30020.

Reports may also be made by a person who witnesses objectionable behavior or otherwise learns of the discrimination, harassment or retaliation.

Complaints of discrimination, harassment and/or retaliation will be investigated promptly by the Human Resources manager or the Human Resources Compliance officer with as much confidentiality as possible.  The investigation may involve interviews with the person making the complaint, the person alleged to have committed the offense and named or apparent witnesses.  

Employees should not discuss the complaint of harassment or discrimination at work, other than with Human Resources or their manager. This policy is intended to protect the confidentiality of the employee who files the complaint, encourage reporting of any incidents of harassment or discrimination, and protect the reputation of employees who may have been accused in error.

Disciplinary Action 

If the investigation supports the allegation of discrimination, harassment, and/or retaliation, BOK Financial will take disciplinary action it determines to be appropriate, up to and including termination of employment. Confidential documentation of all allegations and investigations will be kept, separate from personnel files. However, an appropriate disciplinary memo will be placed in the offending party's personnel file. 

If the investigator is unable to determine whether discrimination, harassment, and/or retaliation actually occurred due to lack of evidence or conflicting statements, the Human Resources Manager will attempt to conciliate the matter.

If it is found that an employee has deliberately made a false allegation of discrimination, harassment, and/or retaliation, BOK Financial will take disciplinary action it determines to be appropriate, up to and including termination of employment.

Effective September 27, 2010

© 2014 Bank of Oklahoma, a division of BOKF, NA. Member FDIC. Equal Housing Lender.