BOK Financial can trace the beginning of its story to a little more than a century ago, in Tulsa, Oklahoma. The bank was first founded as the “Exchange National Bank of Tulsa,” and its main clientele was oilmen; the bank is still known for its funding of the oil industry. In 1975, it rebranded as the Bank of Oklahoma and in 1994, the bank began expanding to other regions, now serving eight states across the heartland. In 2018, BOK Financial acquired CoBiz Financial, spreading to Colorado and Arizona as well.

As one of the largest financial institutions in the nation—and as one firmly situated in so-called “fly-over country”—BOK has a unique opportunity to act as a leader in respecting the diverse views of everyday working Americans. And, though its overall tally of 20 percent on the Viewpoint Diversity Score 2022 Business Index doesn’t exactly jump off the page, that result does put BOK head and shoulders above the competition, as the financial and services industries posted a mere 11 percent score overall on the inaugural list.

Still, BOK can make significant strides in transparency, inclusive charitable giving programs, and its use of divisive concepts in workplace. Let’s take a look.


In the market section, we evaluate companies on whether their policies and practices respect the freedom of expression and belief of customers, users, sellers, creators, and other external stakeholders. On this section, BOK checked in at 13 percent—a mark that could be remedied by the company’s response to the survey section of the 2023 Business Index. Participating in the survey allows for the most accurate score on the Index, and more importantly, it demonstrates a commitment to transparency to shareholders, employees, and customers alike.

A major positive for BOK—especially compared to its fellow banks on the Index—is that the company does not rely on unclear or imprecise in its terms of service. Others, including JPMorgan Chase, hold vague and ambiguously worded policies that allow employees to take adverse action against account holders. As we’ve noted previously, JPMorgan Chase cited its prohibitions on “hate” and “racial intolerance” to de-bank Defense of Liberty— just ahead of an event featuring Cecilia S. Johnson, National Director of Black Engagement for the Republican National Committee.

As JPMorgan Chase explained at the time, “Per our terms of service, we are unable to process for hate, violence, racial intolerance, terrorism, the financial exploitation of a crime, or items or activities that encourage, promote, facilitate, or instruct others regarding the same.” Shortly after news outlets covered the story, JPMorgan Chase reversed its decision, but did nothing to correct its policy.

In addition to avoiding similar mistakes in its policies, BOK proactively guards against religious or ideological discrimination for its account holders. BOK’s “Governance: Customers” and “Fair and Responsible Banking” policies states that it “does not discriminate against any applicant or discourage anyone on the basis of race, color, religion…or any other prohibited basis. We are fully committed to the principle that all consumers will be treated consistently and fairly in all phases of our credit operations…”

BOK underscores its commitment to treat customers of faith in an even-handed way in its terms of service, but it can take another step forward in this area by extending that promise to all external stakeholders in its CSR/ESG reporting. The absence of a guiding policy leaves BOK vendors and partners vulnerable to religious and viewpoint-based litmus tests.

As indicated above, BOK can drastically improve its score simply by providing substantive responses to the survey portion of the 2023 Business Index. Doing so demonstrates a tangible commitment to transparency for shareholders, employees, vendors, and customers.


A company’s workplace section score on the Index reflects the company’s respect for religious and ideological diversity in the workplace. BOK’s 13 percent score in the workplace section is largely reflective of its unresponsiveness to the survey section of the Index.

Just as BOK policies prohibit religious and viewpoint discrimination against customers, the bank also lays out strong protections for employees. Under policies related to “Inclusion,” BOK states that “Our vision it so continually foster and support the principles and values of our company by promoting an environment that is inclusive of the diverse values, opinions experiences, culture, and needs of our employees, clients, and communities.”

Additionally, publicly accessible workplace non-discrimination or EEO policy includes religion as a protected category: “We are committed to providing equal employment opportunities for training, compensation, transfer, promotion and other aspects of employment for all…employees without regard to sex, race, color, religion…or veteran status.”

One main point of concern for BOK is its utilization of divisive concepts for employee training. In one document, for example, the company relies on Critical Theory to state that, “all managers are assigned training on recognizing and mitigating unconscious bias.” While it is certainly appropriate to train managers to treat all employees on an equal playing field, “unconscious bias” is an ideological term that divides all employees into inherently rival groupings and actually discourages cooperation and mutual respect.

As we have written elsewhere:

Divisive concepts are any framework used in employee trainings that disparages a person or particular categories of people because of their religion, race, ideology, or sex. Based on our research, at least 78% of the 50 companies we scored promote divisive concepts in their workplace training programs. When companies weave this kind of training into their programs, they undermine the trust, respect, and openness in their workplaces.

Rather than continuing down this destructive path, companies like BOK should adopt frameworks designed to foster unity in the workplace, such as those provided by BrighterSideHR and Dr. Carol Swain’s Real Unity Training Solutions.

Public Square

The Public Square section evaluates whether corporate giving practices and public advocacy broadly respect free speech, religious tolerance, and open discourse. By this measure, BOK far exceeded its fellow financial institutions scored on the Index, though with significant room for improvement at 50 percent.

BOK earned full credit on all four sub-categories under “Political Spending and Advocacy Respects Diverse Views.” That means less than 30% of BOK’s political spending undermines free speech; at least 30 percent of political contributions went to U.S. Senate/House members who have positive legislative records on free speech and religious liberty; and BOK does not support laws or litigation harmful for speech or religion.

Aside from losing out on points for declining to participate in the survey portion of the Index, BOK lost possible points by holding a policy that excludes or threatens to exclude faith-based non-profits from charitable contributions or non-profit pricing.

This is a widespread issue throughout the 50 companies scored on the inaugural Index, where 40 percent of benchmarked companies’ matching gift policies prohibit or threaten to prohibit employees from making matching-gift contributions to non-profits based solely on religious status or practices. And at least 34 percent restrict or threaten to restrict employee gifts based on charities’ faith-based issue advocacy. This overt discrimination restricts charitable choice and forces religious employees to leave their faith at the door when it comes to giving back.


Among the Fortune 1000 banking institutions we rank, BOK is ahead of the pack. Its record of political spending demonstrates the company’s willingness to respect fundamental American freedoms, and the company’s statements regarding its support of viewpoint diversity among employees is an example of a policy other companies can easily adopt; policies like this help keep companies accountable and earn them more stakeholder trust.

Looking over BOK’s score, two things are apparent: companies can do a lot for themselves and stakeholders if they first include religious non-profits in their charitable giving programs, and secondly, if they are fully transparent to the public about policies enforced within the workplace. Transparency is key if companies are to sharpen their political edge, especially in a time when other businesses are weaponizing their resources to push through ideological agendas.