Hilltop Holdings Inc. - 1792 Exchange

Rating Overview

Hilltop Holdings Inc. is Medium Risk.

Hilltop Holdings Inc. is Medium Risk. The company often yields to political activism in shaping corporate governance, potentially alienating consumers, dividing employees, and harming shareholders. The company implements race and identity-based policies that replace merit, excellence, and integrity with preferential treatment and outcomes. The company occasionally embraces corporate initiatives that redirect its central focus from business goals to partisan policies and divisive issues at times. This approach fails to safeguard free exercise, free speech, and free enterprise.

Rating Criteria

Corporate Weaponization Risk Levels
Criteria	Risk Level
Cancellations	Medium Risk
Discriminatory Philanthropy	Lower Risk
Employment Protection	High Risk

Corporate Weaponization ⓘ

Corporate Governance and Public Policy Risk Levels
Criteria	Risk Level
Advocacy Bias	High Risk
Funding	Lower Risk
Political Actions	Lower Risk

Corporate Governance and Public Policy ⓘ

Rating Criteria Detail

Criteria Risk Level Rationale

Corporate Weaponization

Criteria:

Has canceled customers, suppliers, or vendors due to their political views or religious beliefs OR corporately boycotts, divests, or sanctions regions, people groups, or industries.

Risk Level:

Medium

Rationale:

Hilltop Holdings integrates ESG into its business practices. From its 2022 ESG Report: “Hilltop established an ESG Policy for the enterprise, effective in 2022, with Board approval. Our ESG Policy is designed to provide guidance in aligning Hilltop’s ESG initiative with the operating and strategic practices of our businesses” (1). However, the company has not canceled customers, suppliers, or vendors based on political views or religious beliefs (2).

Criteria:

Charitable giving (including employee matching programs) policies or practices discriminate against charitable organizations based on views or religious beliefs.

Risk Level:

Lower

Rationale:

Hilltop Holdings does not appear to discriminate against charitable organizations based on views or beliefs (1).

Criteria:

Employment policies fail to protect against viewpoint or other discrimination and/or are ideological in nature.

Risk Level:

High

Rationale:

Hilltop Holdings offers unconscious bias training to its employees (1) The company appears to prioritize diversity over merit in its leadership composition. From its Nominating and Corporate Governance Committee Charter: “To make recommendations to the Board regarding the selection and approval of the nominees for director to be submitted for election by the Company’s stockholders at the annual meeting of stockholders or appointment by the Board, as the case may be, pursuant to the bylaws of the Company, which recommendations shall be consistent with the Board’s criteria for selecting new directors. Such criteria include the possession of such knowledge, experience, skills, expertise and diversity, including ethnicity, so as to enhance the Board’s ability to manage and direct the Company’s affairs and business, including, when applicable, to enhance the ability of committees of the Board to fulfill their duties and/or to satisfy any independence requirement imposed by law, regulation or listing standard of the NYSE and the current size and composition of the Board” (2). Hilltop Holdings does not provide viewpoint protections for its employees (3).

Corporate Governance and Public Policy

Criteria:

Uses corporate reputation to support causes, organizations, or policies hostile to freedom of expression.

Risk Level:

High

Rationale:

Hilltop Holdings supports DEI within its business practices, hosting a DEI Council (1). The company supports ESG within its business practices. From its 2022 ESG Report: Our ESG Policy is designed to provide guidance in aligning Hilltop’s ESG initiative with the operating and strategic practices of our businesses” (2).

Criteria:

Uses corporate funds to advance ideological causes, organizations, or policies hostile to freedom of expression.

Risk Level:

Lower

Rationale:

Hilltop Holdings has not used corporate funds to advance ideological causes, organizations, or policies (1).

Criteria:

Uses corporate political actions and/or financial contributions for ideological, non-business purposes.

Risk Level:

Lower

Rationale:

Hilltop Holdings has not used its PAC donations for ideological purposes and does not report on its lobbying at this time (1)(2)(3).