Policy on Affirmative Action and Reaffirmation

PURPOSE OF THE AFFIRMATIVE ACTION PROGRAM

Midland Financial Co., including their subsidiaries and affiliates (hereafter collectively referred to as the “Company”) Affirmative Action Program is a set of specific and results-oriented procedures to which we are committed.  The procedures, coupled with our good faith efforts, will ensure equal employment opportunity.

AFFIRMATIVE ACTION POLICY

The Company is a federal contractor subject to Executive Order 11246.  It is the policy of the Company to hire well-qualified people.  An integral part of this policy is to provide equal employment opportunity for all persons and to recruit and administer hiring, working conditions, benefits and privileges of employment, compensation, training, appointments for advancement including upgrading and promotion, transfers, and terminations of employment including layoffs and recalls for all employees, without discrimination on the basis of race, color, religion, national origin, sex, sexual orientation, gender identity, age, protected veteran status or disability.

Pay Transparency Policy Statement:  The contractor will not discharge or in any other manner discriminate against employees or applicants because they have inquired about, discussed, or disclosed their own pay or the pay of another employee or applicant.  However, employees who have access to the compensation information of other employees or applicants as a part of their essential job functions cannot disclose the pay of other employees or applicants to individuals who do not otherwise have access to compensation information, unless the disclosure is (a) in response to a formal complaint or charge, (b) in furtherance of an investigation, proceeding, hearing, or action, including an investigation conducted by the employer or (c) consistent with the contractor’s legal duty to furnish information.”

In order to implement the foregoing policy, the Company will consider qualified applicants from all sources to ensure equal consideration of individuals.  Additionally, the Company will continue to maintain all Company facilities on a completely non-segregated basis and will fully cooperate with all authorized individuals and agencies responsible for administering laws and regulations in the area of equal employment opportunity and fair employment practice.  This policy extends to all employees and all aspects of the employment relationship, and all personnel are hereby directed to take all reasonable efforts to carry out the spirit and intent of the Company’s policy.  Violations of this policy by any employee will be met with appropriate action.

The Company shall disseminate this policy to all its employees, and encourage all indirect sources of job applicants, such as employees, suppliers, shippers, customers and other contractors, to refer qualified and interested minorities and females.  The Company further pledges to implement additional measures designed to achieve the goals established by this plan.  Responsibility for the direction of equal employment opportunity policy, programs and practices has been assigned to each Company’s EEO/AA Officer.

The objective of the Company’s Affirmative Action program is to ensure that all employees receive equality of opportunity limited only by each employee's desire and ability. The objective calls for a work environment free of discrimination in employment because of race, color, religion, national origin, sex, age, protected veteran status, disability, sexual orientation or gender identity. The Company is assuring the full realization of our stated objective through a continuous process of monitoring and reporting.

As President, I am in full support of the Company’s affirmative action program and am fully committed to implementation of the Company’s affirmative action policy.  Responsibility for the oversight, implementation and auditing of this policy has been delegated to Lorri Darrah, 1st Vice President, Director of Recruiting and the Company’s EEO/AA Officer. Any and all complaints should be directed to your Company’s Human Resources department.


Veterans Equal Employment Opportunity Policy

It is the policy of Midland Financial Co., including their subsidiaries and affiliates (hereafter collectively referred to as the “Company”) to hire well-qualified people. An integral part of this policy is to provide qualified protected veterans which includes disabled veterans, recently separated veterans, active-duty wartime or campaign badge veterans and Armed Forces service medal veterans, as appropriate, with equal employment opportunity in respect to all employment practices, including hiring, promotion, demotion, transfer, recruitment or recruitment advertising, layoff, termination, rates of pay or other forms of compensation and selection for training.

In order to implement the foregoing policy, the Company will consider qualified applicants from all sources to ensure equal considerations of individuals. Additionally, in making employment decisions, the Company will make reasonable accommodations to the physical and mental limitations of a disabled veteran provided such accommodation does not impose an undue hardship on the Company's business. The Company will periodically review its employment practices to ensure that appropriate affirmative action is taken with respect to all protected individuals, as appropriate.

The Company shall disseminate this policy to all its employees, and encourage all indirect sources of job applicants, such as employees, suppliers, shippers, customers, and other contractors, to refer qualified protected veterans which includes disabled veterans, recently separated veterans, active-duty wartime or campaign badge veterans and Armed Forces service medal veterans, as appropriate. This policy extends to all employees in all aspects of the employment relationship and all personnel are hereby directed to make all reasonable efforts to carry out the spirit and intent of the Company’s policy. Violations of this policy by any employee will be met with appropriate action. Furthermore, employees and applicants shall not be subjected to harassment, intimidation, threats, coercion or discrimination because they have engaged in or may engage in any of the following activities: (1) filing a complaint; (2) assisting or participating in an investigation, compliance evaluation, hearing, or any other activity related to the administration of the affirmative action provisions of the Vietnam Era Veteran’s Readjustment Assistance Act of 1974, or any other Federal, State or local law requiring equal opportunity for protected veterans; (3) opposing any act or practice made unlawful by VEVRAA, or its implementing regulations in this part or any other Federal, State or local law requiring equal opportunity for protected veterans; or (4) exercising any other right protected by VEVRAA or its implementing regulations in this part.

As Todd Dobson, President, I am in full support of the Company’s affirmative action program and am fully committed to implementation of the Company’s affirmative action policy. Responsibility for the implementation and direction of the Company's Affirmative Action Program for disabled veterans and qualified protected veterans has been assigned to Lorri Darrah, 1st Vice President, Director of Recruiting and the Company’s EEO/AA Officer. Employees and applicants wishing to review this Affirmative Action Program may do so in the Human Resources Office during normal business hours, Monday through Friday.


Equal Employment Opportunity Policy – Individuals With Disabilities  

It is the policy of Midland Financial Co., including their subsidiaries and affiliates (hereafter collectively referred to as the “Company”) to hire well-qualified people. An integral part of this policy is to provide qualified disabled individuals with equal employment opportunity in respect to all employment practices, including hiring, promotion, demotion, transfer, recruitment or recruitment advertising, layoff, termination, rates of pay or other forms of compensation and selection for training.

In order to implement the foregoing policy, the Company will consider qualified applicants from all sources to ensure equal considerations of individuals. Additionally, in making employment decisions, the Company will make reasonable accommodations to the physical and mental limitations of a disabled worker provided such accommodation does not impose an undue hardship on the Company's business. The Company will periodically review its employment practices to ensure that appropriate affirmative action is taken with respect to all covered individuals, as appropriate. An individual who may have a disability can request a reasonable accommodation by contacting our designated Disability Program Manager, Kathy Billen, Vice President, Benefits Manager in the following manner: kathy.billen@midfirst.com or 405.767.7002.

The Company shall disseminate this policy to all its employees, and encourage all indirect sources of job applicants, such as employees, suppliers, shippers, customers, and other contractors, to refer qualified disabled workers. This policy extends to all employees in all aspects of the employment relationship and all personnel are hereby directed to make all reasonable efforts to carry out the spirit and intent of the Company policy. Violations of this policy by any employee will be met with appropriate action. Furthermore, employees and applicants shall not be subjected to harassment, intimidation, threats, coercion or discrimination because they have engaged in or may engage in any of the following activities: (1) filing a complaint; (2) assisting or participating in an investigation, compliance evaluation, hearing, or any other activity related to the administration of Section 503 of the Rehabilitation Act of 1973, or any other Federal, State or local law requiring equal opportunity for individuals with disabilities; (3) opposing any act or practice made unlawful by Section 503 or its implementing regulations in this part or any other Federal, State or local law requiring equal opportunity for individuals with disabilities; or (4) exercising any other right protected by Section 503 or its implementing regulations in this part.

As Todd Dobson, President, I am in full support of the Company’s affirmative action program and am fully committed to implementation of the Company’s affirmative action policy. Responsibility for the implementation and direction of the Company's Affirmative Action Program for disabled workers has been assigned to Lorri Darrah, 1st Vice President, Director of Recruiting and the Company’s EEO/AA Officer. Employees and applicants wishing to review this Affirmative Action Program may do so in the Human Resources office during regular business hours, Monday through Friday.

Todd Dobson President signature