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Acting ethically

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Serving stakeholders

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Managing risks

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Creating long-term value

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About the Company ........................................................................................................

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Awards and Recognition ................................................................................................

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Sound Governance ..........................................................................................................

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Developing Social and Human Capital .........................................................................

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Managing Environmental Risks ....................................................................................

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Asset Quality – Superior asset quality is the cornerstone to our strong balance sheet and supports consistent, long-term profitability.

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Community Leadership – By being a leading corporate citizen in our communities.

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Customer Care – A high level of customer care and service differentiates us from our competitors, contributing to retention and growth of our customer base.

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Employee Development – Highly trained and motivated employees are critical to our success.

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Integrity – Integrity and unquestionable business ethics are the foundation for meeting the needs and expectations of our stakeholders.

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Profitability – Consistently growing long-term profitability produces long-term value.

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Sound Governance

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Developing Social and Human Capital

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Managing Environmental Risk

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BancFirst ranked 10th in the United States on Forbes list of World’s Best Banks, making it the top ranked Oklahoma-based bank on the list

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The Forbes ranking was based on survey responses from BancFirst customers who measured customer service, overall banking satisfaction and trust

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For the 14th consecutive year, BancFirst was rated as one of the "Nation's Strongest and Safest Banks"​ by Bank Director magazine

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For the 9th consecutive year, BancFirst was included on the KBW Bank Honor Roll. Keefe, Bruyette & Woods, Inc., a full‐service, boutique investment bank that names U.S. banking institutions to its coveted “Bank Honor Roll” of superior performers every year

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BancFirst was included on the Dividend Achievers Index for having consecutively increased their dividend payments for at least 10 years

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BancFirst has been named the top volume SBA lender in Oklahoma for over 28 years

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BancFirst was the largest producer of PPP loans in Oklahoma with $854 million going to businesses

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We funded 8,576 loans in round one, with an average loan balance under $100,000

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Independence – A majority of the directors meet the independence requirements.

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Refreshment and Assessment – All directors serve a one-year term, and must be nominated for election each year.  There is an ongoing process to assess the skills and performance of continuing directors, and to identify and consider new director candidates.  The Company’s age limit for directors is 79 years old.

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Skillset of Directors – The directors possess a wide range of skills and experiences representing a number of industries that are prevalent in the Company’s market areas.  A Directors Skills Matrix is included in our Proxy Statement.

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Diversity - The Board members include two women, an additional member who identifies as Hispanic, and another member who identifies as Native American.

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Confidential Nature of Customer Affairs – Requires that information and affairs of customers be kept private.

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Conflicts of Interest – Prohibits conflicts of interest between directors, officers and employees and the Company, including:

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Directly doing business as a vendor to the Company;

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holding a substantial financial interest in, or serving as a director or officer of, any vendor to the Company;

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competing with the Company;

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having outside employment, unless approved in advance;

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using inside information for personal gain; and

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accepting gifts, payments, extravagant entertainment, services or loans from any vendor soliciting or already doing business with the Company.

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Government and Community Relations – Provides guidance for political, community development and community relations activities.

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Insider Trading – Prohibits use of inside information, insider trading and hedging of Company securities, and we impose blackout periods when appropriate.

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Self-Dealing Transactions – Prohibits employees from conducting and processing transactions with the Company for their own benefit.

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Compliance with Laws and Regulations – Various policies that require compliance with laws and regulations, including lending and consumer compliance.

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Antitrust Laws – The Company prohibits anti-competitive practices such as cartels and abuse of dominant market power.  It complies with antitrust laws and has never faced an antitrust charge or allegation.

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Anti-Money Laundering – Extensive policy, program and procedures for compliance with the Bank Secrecy Act and anti-money laundering laws and regulations.

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Corporate Governance Risk Report – Each year the Chief Risk officer prepares a report assessing the Company’s governance processes and the related risks.

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Code of Conduct Training – Annual training for the Code of Conduct is required.

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Compliance Training Program – An extensive compliance training program is conducted covering a wide range of laws and regulations.

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Conflicts of Interest Review – The Chief Risk Officer conducts quarterly reviews for possible conflicts of interest.

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Related Party Transactions Audit – The Internal Audit Department performs an audit of related party transactions annually.

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Annual Assessment of Corporate Governance – The Internal Audit Department assesses the Company’s corporate governance as part of the entity level controls over financial reporting.

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Leading and investing in our communities

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Providing financial services accessible to everyone

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Fair and ethical conduct in serving our customers

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Maintaining privacy and information security

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Developing a diverse, well-trained and motivated workforce

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Serving on the boards of industrial authorities and economic development foundations

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Using their financial expertise to review and approve grant monies and provide assistance to new businesses and businesses moving into their communities

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Serving on the boards or committees of various affordable housing authorities

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Teaching financial literacy courses in schools in their communities where over 50 percent of the students receive free and reduced cost lunches

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Providing financial education and literacy resources on our website

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Preservation Oklahoma – PlanFirst Grant Program – a “grass-roots preservation matching funds” grant program to provide funding for historic preservation initiatives

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Oklahoma Historical Society – Oklahoma History Center Traveling Program – a program which brings the Oklahoma History Center museum to the classroom, including lesson plans, hands-on activities, and artifacts for the students to handle

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Our sponsorship targets rural elementary and secondary schools and is offered free to teachers

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Oklahoma Children’s Theatre – BancFirst Tour – annual performances of the Oklahoma Children’s Theatre in rural BancFirst communities, targeted to lower elementary school students

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Oklahoma Arts Institute - Teacher Workshops – provides 15 teacher scholarships to attend the Oklahoma Fall Arts Institute, where four-day workshops are taught by nationally renowned artists in areas such as creative writing, photography, film, painting, and vocal music

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Local Programs – many of our community banks fund programs through their local public schools and foundations

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110 banking locations in 60 communities throughout Oklahoma and in Dallas, Texas

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Over 25% of its locations are in low-to-moderate-income census tracts

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Over 220 ATMs, 27% of which are located in low-to-moderate-income census tracts

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Free online and mobile banking services

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Online services, such as deposit account opening, consumer loan applications, credit card applications,  small business loan applications, and mortgage loan requests

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Products such as money orders and check cashing services

Number of Accounts

Balance

Personal

  Demand Deposit

240,100

$1,655,255,000

  Savings

66,500

$590,199,000

  Treasury Fund

16,600

$1,307,973,000

Small Business

  Demand Deposit

32,300

$437,056,000

  Savings

1,900

$30,038,000

Number of Accounts

Balance

No Cost Accounts

216,300

$1,124,607,000

Number of Accounts

Balance

Personal

30,778

$353,839,000

Small business

11,304

$535,263,000

Corporate

502

$1,022,918,000

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In the Oklahoma City metropolitan area, a program for lending to non-citizens to reach more Hispanic borrowers, maintaining bilingual staff, and advertising in media serving Black and Hispanic communities.

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In the Tulsa metropolitan area, specific action plans, developed by management of six bank locations, to increase applications from majority minority areas.

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In the Lawton metropolitan area, a Business Development Team tasked with increasing the bank’s presence in the Black community and increasing applications from Black borrowers.

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Lending –

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An excellent record regarding its lending activity, supported by market rankings of 4^th for home mortgage loans, 3^rd for small business loans, and 1^st for small farm loans

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An excellent responsiveness to its market areas’ community development needs

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Originated 108 community development loans totaling $331,359,489 (7.7% of average loans)

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Innovative and flexible lending practices in order to serve assessment area credit needs

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Originated 1,059 innovative or flexible loans totaling $248,460,000 (5.8% of average loans)

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Investment –

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The Company had 135 qualified investments totaling $44,552,000, which included:

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98 grants and donations of $153,000

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5 affordable housing investments totaling $22,139,000

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2 economic development/revitalization investments totaling $5,560,000

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Service –

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The Company’s branch network and delivery systems are accessible to essentially all portions of its market areas

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Company employees provided a total of 271 community development services since the previous evaluation, including affordable housing, community, economic development, and revitalization services

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Community services also included employees teaching financial literacy courses in schools where over 50 percent of the students receive free and reduced lunches

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The Company contributed over $1,800,000 to charitable organizations during the year

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Periodically reviewing all marketing information, disclosures and agreements for consumer products and services to ensure that:

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the information is easily understandable, not misleading, comprehensive, and accurate;

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there is transparency of all costs and conditions; and

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there is limited use of “fine print”.

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Reviewing pricing of products and services to ensure fair and competitive pricing.

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Reviewing sales practices and incentives to ensure that they don’t encourage abuse.

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Maintaining compliance with consumer protection laws and regulations, such as the Truth in Savings Act.

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Compliance Program – Establishes a comprehensive compliance program encompassing consumer protection, fair lending, and community credit activities.  

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Compliance Training Program – Provides employee training for consumer compliance and lending compliance.

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Truth in Savings – Requires compliance with regulations regarding account disclosures and advertising of accounts.

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Tying Restrictions – Prohibits tying extensions of credit to use of other products or services.

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Fair Lending – Ensures that all persons receive fair and consistent treatment throughout the credit function of the bank, without discriminatory practices.

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Americans With Disabilities Act – Requires that we provide banking services that are accessible for customers with disabilities.

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Reducing fees for returning checks – We reduced our fee for returning checks and other items by $10.

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Eliminating Mobile Deposit fee – We eliminated the fee for making mobile deposits; the service is now free.

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Allowing customers to defer loan payments – Through our skip-a-payment program, individuals deferred 18,665 payments for 9,832 loans.

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Eliminating late fees – The Company temporarily ceased charging late fees on past due loan payments beginning in early 2020 to the second quarter of 2021.

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Participating in the Paycheck Protection Program – BancFirst was Oklahoma’s largest producer of PPP loans for round one, making 8,576 loans totaling over $854 million, with an average loan balance of under $100,000

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Ensure the security and confidentiality of sensitive information

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Protect against threats or hazards to the security or integrity of such information

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Protect against unauthorized access to or use of such information that could result in substantial harm or inconvenience to any customer

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Ensure the proper disposal of sensitive information

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Maintaining a risk assessment process that identifies areas that are required to be protected, and to determine if effective controls are used to safeguard the bank against threats and vulnerabilities

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Assigning ratings to identify priorities that need additional controls

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Providing training on cybersecurity to all employees and to customers to address the ever changing technology and tactics of malicious actors

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Maintaining a Vendor Management Program to regularly review critical vendors’ information security processes, and evaluate third party contracts for information security requirements to ensure vendors adequately protect information

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Monitoring security controls and the use of systems and networks

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Conducting security review meetings to discuss monitoring activities and relevant security events

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Assessments by Internal Auditors of our controls, design, and monitoring capabilities

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Engaging external parties at least annually to perform security assessments that further test and review the effectiveness of our security

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Providing for response to information security events and management of any such events by the Information Security Committee

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Diversity, equity, and inclusion - affirmatively recruiting, promoting, and developing an increasingly diverse group of current and prospective employees

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Equal employment opportunity – the Company is an affirmative action employer, and its policies prohibit discrimination in hiring, training, promotion, compensation or in any other aspect of employment based on race, religion, sex, sexual orientation, national origin, ancestry, marital status, disability, medical condition, age, genetic information, military service, or any other basis prohibited by state and local law

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Freedom of association and collective bargaining – by policy, the Company recognizes employees’ rights and protections provided by the National Labor Relations Act, however none of the Company’s employees are represented by collective bargaining agreements

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Confidential channels for reporting – publicizing and promoting, through policy, employees’ ability to anonymously report workplace, off-duty, and Code of Conduct matters through EthicsPoint

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Competitive compensation practices – paying competitive wages, including a minimum wage of $12.50/hr., a comprehensive health plan, a 401(k) plan, and an employee stock ownership plan

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Opportunities to earn variable pay – a bonus plan, various sales and referral incentive programs, and individual performance-based bonuses are available

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Training and education assistance – providing an extensive in-house training program with specific plans for certain supervisory and non-supervisory positions, and reimbursements for certain outside education

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Annual performance development reviews – written performance development reviews and coaching sessions conducted each year for every employee

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Career development - identifying high potential candidates and providing specifically tailored plans developing their careers

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Management Succession Plan – annually identifying high potential employees for development and opportunities for internal promotions

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Employee appreciation and recognition – conducting monthly anniversary lunches in celebration of work anniversaries and holding annual employee appreciation events

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Anti-harassment policy and training – prohibiting harassment, discrimination and retaliation, and providing annual training

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Health and safety – promoting employee health and safety, including: a smoke free, drug free and weapon free workplace; an Employee Assistance Program for mental health and other counseling; a Smoker Cessation Program; and subsidies for gym memberships

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Employee Assistance Program – for mental health, work-life balance, and other counseling and assistance, available to all full-time employees

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Special leave – providing paid short-term leave for personal and family illnesses, and unpaid long-term leave for medical, parental, family care, and personal reasons, available to all full-time employees

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Dependent Care Benefit – providing a dependent care benefit under its Flexible Benefit Plan, available to all full-time employees

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COVID-19 Pandemic response - providing moral and economic support to employees through plans for maintaining safe operations, constant and consistent communication, and a variety of compensation and incentive strategies for employees affected by the pandemic, including but not limited to subsidies for child care obligations for employees affected by distance learning and school closures

Percentage of women in the overall workforce

74.5%

Percentage of women in management positions

68.3%

Percentage of women in the executive team

13.8%

Industry

Number of Loans

Balance

Oil & Gas Production

528

$267,058,135

Oil & Gas Service

602

$89,201,632

Manufacturing

988

$200,958,133

Restaurants

1,131

$177,562,547

Real Estate Leasing

868

$147,848,631

Transportation

890

$140,337,077

Finance and Insurance

394

$128,058,599

Legal Services

1,502

$114,953,559

Healthcare

1,072

$110,810,989

Construction

2,464

$85,791,587

Total Commercial & Industrial

21,109

$2,190,439,594

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Converting lighting systems to LED

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Installing geothermal heat pumps in new facilities

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Using building automation systems to better manage HVAC systems

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Building Intelligent Teller Machine (ITM) facilities rather than larger manned facilities

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Upgrading systems in its new headquarters building to energy efficient systems, including completely replacing the glass exterior with thermal glass

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Purchasing EPEAT registered computer equipment

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Reducing paper usage through increased utilization of digital systems and processes

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Shredding and recycling of most of its paper