The Code of Conduct Within Banc First Discussion

The Code of Conduct Within Banc First DiscussionRespond to posts by at least two (2) of your classmates. Reply with more than, “Wow! I love that company too!” or “I agree, that company is the best!” or “I never thought of number 2 in your code!” or…you get the idea (I hope). For each response, from the classmate’s code of ethics/code of conduct, choose two points/standards: one you really like/agree with and one you don’t really like/agree with. Explain why you picked them and why you like/don’t like or agree/do not agree. Again, think about engaging with your fellow classmates as if you were having an actual group discussion. Student 1 BancFirst 2. I chose BancFirst simply because this is where I currently work. When I started working here, I had to sign an acknowledgement, but after some time you forget what the code of conduct actually states. It was good to go back and refresh on this. 3. BANCFIRST CORPORATION CORPORATE CODE OF CONDUCT (Revised June 28, 2018) Purpose The purpose of this Corporate Code of Conduct is to set forth the Company’s standards regarding the ethical and legal behavior expected of its directors, officers and employees. The ethical and legal conduct of our business is critical to achieving our Company’s mission. Our corporate ethics are based on a set of core values: Asset Quality Community Leadership Customer Care Employee Development Integrity Profitability We expect our directors, officers and employees to conduct themselves with integrity both on and off the job. It is essential that all of our business activities be carried out in an atmosphere of mutual respect and courtesy, and in an ethical manner. The manner in which we conduct ourselves away from work also influences the public’s trust and opinion of the Company. This Corporate Code of Conduct applies to all directors, officers and employees of the Company. The Company requires that all directors and executive officers sign the form attached to this Code acknowledging their understanding of the Code and agreeing to comply with it at all times. Conflicts of Interest The Company’s Conflicts of Interest policy is a part of this Corporate Code of Conduct. All directors, officers and employees are expected to be familiar with the policy and comply with its requirements. Corporate Opportunities Directors, officers and employees are prohibited from (a) taking for themselves personally opportunities that are properly within the scope of the Company’s activities, (b) using corporate property, information or position for personal gain, and (c) competing with the Company. Directors, officers and employees owe a duty to the Company to advance its legitimate business interests to the best of their abilities. No director, officer, employee or an immediate family member, who is in a position to influence or control decisions affecting business transaction or relationships of the Company shall have any obligation to, have any material interest in, or receive any benefit from, any outside person, company or vendor which either directly or indirectly competes with or does business with the Company. If an obligation or material interest exists or develops, the director, officer or employee must make full disclosure of the obligation or material interest and obtain the approval of the appropriate authority. Confidential Nature of Bank and Customer Affairs The Company’s Confidential Nature of Bank and Customer Affairs policy is a part of this Corporate Code of Conduct. All directors, officers and employees are expected to be familiar with the policy and comply with its requirements. Inside Information/Insider Trading BancFirst Corporation is a registered public company and is subject to laws, rules and regulations regarding the use of non-public inside information and insider trading. In the course of performing their duties directors, officers and employees may receive information about the Company or its customers which, if known to the public, might affect the decision of a reasonable investor to buy, sell, or hold securities of the Company or that customer’s business. Directors, officers and employees are prohibited from acting upon material inside information prior to public disclosure through the purchase or sale of such securities for their own accounts or for fiduciary or agency accounts, and from divulging such information to others except as required by Company business. All directors, officers and employees will promptly report suspected abuse of inside information to the Executive Chairman or Chief Executive Officer, or through Ethicspoint as described below. All directors, officers and employees are prohibited from engaging in “short-swing” trading of securities issued by the Company by purchasing and selling, or selling and repurchasing such securities within a period of less than six months. Illegal Payments, Bribes, Kickbacks Directors, officers and employees shall not authorize or make any improper payment for any form of bribery, payoff, illegal contribution, or other payment of a questionable nature to individuals, businesses or government entities. Under no circumstances should the purchase or sale of products and/or services result in any Company director, officer or employee or an immediate family member receiving any form of kickback, rebate or gratuity. If you are approached by anyone to make or receive a questionable payment, immediately contact the appropriate authority. Foreign Corrupt Practices Act (“FCPA”) The Company and the law prohibit giving and/or offering money or anything of value to a foreign governmental official, agency, political party, party official or candidate under any circumstances which appears that such items were offered or given to induce the recipient to benefit the Company’s business in their country. The FCPA, as well as Company policy, prohibits bribing a governmental official or any other form of commercial bribery. If you are approached by anyone to make a questionable payment, immediately contact the appropriate authority. Public Reporting and Disclosure All directors, officers and employees of the Company should ensure that all information contained in reports and documents that the Company files with the banking regulatory agencies, the Securities and Exchange Commission, or other regulatory agencies, and/or contained in other public communications made by the Company is complete, accurate, timely, and in accordance with applicable requirements. In the event that a director, officer or employee has reason to believe that any such information does not meet these standards, then he or she should contact the Executive Chairman or the Chairman of the Audit Committee, or file a report through Ethicspoint as described below. Books and Records Laws, rules and regulations require, and it is the Company’s policy, that all business records (including customer records, transaction records, invoices, statements, tax records, payroll records, time cards, expense reports, benefit plan information, and documentation supporting financial and other reports) be prepared accurately, reliably, and in a timely manner. It is very important that no director, officer or employee create or participate in the creation of (or falsification or alteration of) any Company records which are intended to mislead anyone or conceal anything improper. Company books and records should be maintained in confidence, be safeguarded from loss and destruction, and be under effective internal controls. Directors, officers and employees should always be honest and straightforward when dealing with internal or outside auditors with respect to the Company’s transactions, records, accounts, and financial statements. Appropriate Authority for Disclosure/Waiver If any director, officer or employee becomes aware of a possible violation of this Code, he or she should report such possible violation immediately to any director or the Executive Chairman, Chief Executive Officer, or Director of Human Resources, or through Ethicspoint. Only the Board of Directors may grant waivers or exceptions to this Code for directors or executive officers. Ethicspoint Ethicspoint is a comprehensive, anonymous Internet and telephone based reporting tool that assists management and employees to work together to address fraud, abuse, misconduct, and other violations in the workplace. To file a report using Ethicspoint you can call the toll-free hotline at 866-ETHICSP, or on the Internet go to Every effort will be made to protect the confidentiality of those furnishing information. The Company will not tolerate retaliation in any form against any person for complaints or reports made in good faith. Any intentional violation of this Code by directors, officers or employees will lead to appropriate action, up to and including termination of the violator’s position and/or employment. student 2 1. Company I Choose: Under Armour 2. Why I chose this company? I chose this company because it is a major sports marketing brand that is based local to me. The Under Armour headquarters are in Portland, and I see them all the time. I have interest in working for one of those comapnies when I graduate. 3. AT UNDER ARMOUR, OUR “HOUSE” HAS BEEN BUILT AROUND FOUR PILLARS – MAKE A GREAT PRODUCT, TELL A GREAT STORY, PROVIDE GREAT SERVICE AND BUILD A GREAT TEAM. UNDER ARMOUR’S MISSION IS TO MAKE ALL ATHLETES BETTER THROUGH PASSION, DESIGN, AND THE RELENTLESS PURSUIT OF INNOVATION. Under Armour requires its teammates to comply with Under Armour’s Code of Ethics and Business Conduct. Consistent with these values, Under Armour seeks to do business with business partners, including manufacturers, licensees and agents and their subcontractors (hereinafter collectively called “suppliers” and “employers”) that share these values, strive for continuous and sustainable improvement in working conditions and practices and comply with this Supplier Code of Conduct (the “Code”) and all applicable laws. Suppliers shall collaborate with Under Armour and their subcontractors to assess current practices, identify opportunities for improvement, and implement improvement plans. Under Armour suppliers and their subcontractors must deal with their employees, their teams, in a legal, ethical and equitable manner. Under Armour seeks to do business with suppliers and subcontractors that comply with the laws of the United States, the countries in which Under Armour products, their components and materials are produced, distributed, bought and sold, and the Code. Any violation of these laws or the Code may be viewed as a breach of the Manufacturing Agreement and could lead to the termination of the business relationship between Under Amour and the supplier. NONDISCRIMINATION: Under Armour suppliers and their subcontractors shall not subject any person to discrimination in employment including hiring, salary, benefits, advancement, discipline, termination or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, or social or ethnic origin. Additionally, suppliers and their subcontractors must implement effective measures to protect migrant employees against any form of discrimination and provide appropriate support services to them. HARASSMENT OR ABUSE: Under Armour suppliers and their subcontractors must treat their employees with respect and dignity. No employee shall be subject to physical, sexual, psychological or verbal harassment or abuse. FORCED LABOR: Under Armour suppliers and their subcontractors shall not use forced labor, whether in the form of prison labor, indentured labor or bonded labor, or other forms of forced labor to make or perform work on Under Armour products or their components or materials or permit their suppliers to do so. CHILD LABOR: Under Armour suppliers and their subcontractors shall not employ persons under the age of 15 or under the age for completing compulsory education, whichever is higher. FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING: Under Armour suppliers and their subcontractors shall recognize and respect the right of employees to freedom of association and collective bargaining. Employers must develop and implement effective industrial relations systems and mechanisms to resolve industrial disputes, including employee grievances and ensure effective communication with employees. HEALTH AND SAFETY: Under Armour suppliers and their subcontractors must provide their employees with a safe and healthy working environment to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of employer facilities. Employers must fully comply with all applicable workplace conditions, safety and environmental laws rules, regulations and standards. Employers must effectively implement health and safety policies and procedures within their operations, workplaces and related residential facilities and jointly share responsibility for, and ownership of, them with appropriately trained employees. Where residential housing is provided to their employees, suppliers and their subcontractors must apply these standards to them and ensure that such housing provides a safe, healthy and sanitary living environment. SUSTAINABLE BUSINESS PRACTICES: Employers shall implement responsible measures to mitigate negative workplace and operational impacts on the environment and their community. This includes: integrating sustainability principles into business decisions; improving environmental performance by responsibly using natural resources; reducing waste, increasing energy efficiency; adopting cleaner production and pollution prevention measures and sustainably designing, developing and building products, materials and technologies. HOURS OF WORK: Under Armour suppliers and their subcontractors shall not require workers to work more than the regular and overtime hours allowed by the law of the country where the workers are employed. The regular work week shall not exceed 48 hours. Under Armour suppliers and their subcontractors shall allow workers at least 24 consecutive hours of rest in every seven-day period. All overtime work shall be consensual. Under Armour suppliers and their subcontractors shall not request overtime on a regular basis and shall compensate all overtime work at a premium rate. Other than in exceptional circumstances, the sum of regular and overtime hours in a week shall not exceed 60 hours. COMPENSATION: Every worker has a right to compensation for a regular work week that is sufficient to meet the worker’s basic needs and provide some discretionary income. Employers shall pay at least the minimum wage or the appropriate prevailing wage, whichever is higher, comply with all legal requirements on wages, and provide any fringe benefits required by law or contract. Where compensation does not meet workers’ basic needs and provide some discretionary income, each employer shall work with the FLA to take appropriate actions that seek to progressively realize a level of compensation that does. LEGAL AND ETHICAL BUSINESS PRACTICES: Under Armour suppliers and their subcontractors must fully comply with all applicable local, state, federal, national and international laws, rules and regulations including those relating to child labor, wages, hours, labor, health and safety, slavery, human trafficking and immigration. Under Armour suppliers and their subcontractors must be ethical in their business practices. GIFTS/CONFLICTS OF INTEREST: Under Armour’s relationships with its business partners are built on trust, value, quality and service. Suppliers and subcontractors must abide by Under Armour’s policies on gifts and conflicts of interest. Under Armour teammates may only accept modest gifts, meals and entertainment from suppliers or subcontractors (less than USD 200). Ordinary business meals and small tokens of appreciation generally are acceptable, but suppliers and subcontractors should avoid offering Under Armour teammates travel, frequent meals or expensive gifts. Gifts of cash or cash equivalents, such as gift cards, are not permitted. RECORDKEEPING: Under Armour strives for fairness and accuracy in all our records and reports. Under Armour expects its suppliers and subcontractors to maintain accurate financial books and business records in accordance with all applicable requirements. ANTI-BRIBERY AND ANTI-CORRUPTION: Under Armour is committed to conducting business free from corrupt practices. Suppliers and subcontractors must comply with applicable anti-corruption laws, including the United States Foreign Corrupt Practices Act and the UK Bribery Act of 2010. Suppliers and subcontractors may not offer anything of value, either directly themselves or through a third party, to government officials in order to obtain or retain business. EXPORTS: Suppliers and subcontractors must transfer Under Armour products across borders in a lawful manner and in compliance with the U.S. Export Administration Act and Export Administration Regulations. NON-RETALIATION: Under Armour suppliers and subcontractors must effectively implement a non-retaliation policy, procedures and reporting channels that enable workers to express anonymously and safely their concerns about workplace conditions directly to factory management and to other parties without fear of retribution, retaliation or any other adverse action. REPORTING POTENTIAL MISCONDUCT: Under Armour suppliers and subcontractors and their employees may report violations of this Code to Under Armour’s Hotline electronically via http:/ and/or The Hotline is monitored 24 hours a day, seven days a week. The Hotline allows for the option to report anonymously, depending on location. Suppliers and subcontractors must provide reasonable support during an investigation of a potenial violation. …

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