Mid Penn Bancorp, Inc. - 1792 Exchange

Rating Overview

Mid Penn Bancorp, Inc. is Medium Risk.

Mid Penn Bancorp 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	No Data

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:

Mid Penn Bancorp integrates ESG into its business practices. From its 2024 ESG Factsheet: “As part of this overall mission, Mid Penn is focused on integrating environmental, social and governance (“ESG”) principles into how we conduct business” (1). However, it 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:

Mid Penn Bancorp 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:

Mid Penn Bank, a subsidiary of Mid Penn Bancorp, offers DEI training to its employees (1). The company appears to prioritize diversity over merit in its leadership composition. From its Nominating and Corporate Governance Committee Policy and Charter: “In considering potential candidates for Director, the Committee shall seek to ensure that the composition of the Board reflects a meaningful level of diversity in four specific areas: expertise and experience; tenure and age; gender, race and ethnicity; and geography. Gender, Race and Ethnicity” (2). Mid Penn Bancorp appears to prioritize diversity over merit in its business structure through the establishment of gender and racial targets for its leadership composition. The company is seeking “a balanced level of diversity in the composition of the Board” (3). The company does not provide viewpoint protections for its employees (4).

Corporate Governance and Public Policy

Criteria:

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

Risk Level:

High

Rationale:

Mid Penn Bancorp supports DEI within its business practices, hosting a DEI Committee (1). It supports DEI within its business practices. From its 2024 ESG Factsheet: “Diversity, equality, and inclusion (“DEI”) is also central to our success at Mid Penn. Our commitment to diversity and inclusion starts with hiring, retaining, and developing a workforce that is diverse in background, knowledge, skill and experience” (2). Mid Penn Bancorp supports ESG within its business practices. From its 2024 ESG Factsheet: “Our executive leadership team and Board is tasked with driving and monitoring progress on key ESG issues, with a goal of increasing transparency, including the publication of this annual ESG report” (3).

Criteria:

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

Risk Level:

Lower

Rationale:

Mid Penn Bancorp 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:

N/A

Rationale:

Mid Penn Bancorp does not operate a PAC or engage in lobbying at this time (1)(2)(3).