Governance
As a financial services company, we understand the importance of trust. That’s why unwavering integrity goes beyond a core value to simply being a part of how we evaluate everything we do. Our governance structure, prudent policies and active engagement with our employees underscore our commitment to always acting in the best interest of our clients, employees, communities and shareholders. Our Board consists of a substantial majority of independent directors. The average tenure of the 17 directors on our Board is 16 years.
Board oversight
The company’s Board of Directors is composed of a group of strong leaders with executive experience that aligns with our organization’s business strategy. Brief biographies for our board members and senior management can be found on the "Our Leadership" section of our investor relations website.
The board oversees the company’s overall strategic and reputational risks and regularly reviews the company’s credit, liquidity and operations, as well as the risks associated with each. Committees of the board focus on specific areas, including:
- Audit Committee: accounting and financial reporting, internal controls, and whistleblower complaints
- Credit Committee: credit and lending strategies and objectives
- Risk Committee: risk management strategies, policies and practices that identify, assess, monitor and manage risk
- Compensation Committee: compensation policies, programs and incentives
Related documents
Standards of Conduct
The Audit Committee of the Board of Directors annually reviews and approves the company’s Standards of Conduct on which employees are annually trained and attest to. Each member of the Board of Directors takes an annual Oath of Office prescribed by the Office of the Comptroller of the Currency (OCC) and is bound by the company’s Code of Ethics.
Proxy Statement
The company’s annual proxy statement identifies responsibilities of board committees.
10-K
The company’s 10-K reviews a wide array of company performance factors, including any legal proceedings associated with fraud, insider trading, anti-trust, anti-competitive behavior, market manipulation, malpractice, or other related financial industry laws or regulations.
Business ethics
We provide annual training for all employees on our Standards of Conduct, compliance management requirements, BSA/AML (Bank Secrecy Act/Anti-Money Laundering) processes, physical security, risk culture and internal controls, risk reporting and awareness, and information security awareness.
The Board of Directors is also required to adhere to the company’s Code of Ethics in satisfaction of Section 406 of the Sarbanes-Oxley Act of 2002, the NASDAQ listing requirements and related regulations. As a national bank, each member of BOK Financial’s Board of Directors affirms their commitment to uphold the organization’s standards in its annual Oath of Office.
BOK Financial’s Chief Compliance Officer oversees the enterprise compliance program and reports to the Chief Risk Officer. The compliance program includes policies and procedures, annual training requirements, monitoring and testing, annual risk assessments and a complaint management program.
Compliance staff actively monitor line of business activities and governance to determine compliance with applicable regulatory requirements. Monitoring processes identify, track, and report issues discovered in the lines of business through formal risk assessments.
Independent monitoring and risk assessments inform the scope of testing performed by Corporate Compliance Management and Internal Audit.
Customer privacy
The ethical collection, use, sharing and retention of customer data is a requirement for building data trust. We believe creating data trust combines the elements of data privacy and data security. As such, the company’s Chief Information Security Officer also serves as the Privacy Officer, and the privacy program is overseen by the Risk Committee of the Board.
The Privacy Officer is responsible for implementing privacy practices and ensuring compliance with applicable privacy regulations. We apply privacy-by-design in the development of our applications and establish processes to fulfill data requests from our customers.
Risk assessments are performed on an annual basis to evaluate the company’s ability to protect customers’ private information; risk results as well as the company’s overall compliance status are reported to the Risk Committee.
