Midland States Bancorp, Inc.

Rating Overview

Midland States Bancorp, Inc. is Medium Risk.

Midland States 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	Lower Risk
Discriminatory Philanthropy	Medium Risk
Employment Protection	High Risk

Corporate Weaponization ⓘ

Corporate Governance and Public Policy Risk Levels
Criteria	Risk Level
Advocacy Bias	Medium 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:

Lower

Rationale:

Midland has not publicly canceled customers, suppliers, or vendors based on political views or religious beliefs (1).

Criteria:

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

Risk Level:

Medium

Rationale:

Midland’s charitable giving guidelines require that organizations abide by its nondiscrimination policy, including on the basis of sexual orientation and gender identity, thereby excluding some religious charities (1).

Criteria:

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

Risk Level:

High

Rationale:

Midland offers diversity training to its employees (1). It appears to prioritize diversity over merit in its leadership composition. From its 2021 Annual Report: “Our board composition includes 40% women and minorities, and our criteria for identifying directors includes seeking diverse individuals” (2). Midland is an affirmative action employer. “We’re proud to be an Equal Opportunity and Affirmative Action employer” (3)(4). The company does not provide viewpoint protections for its employees (5)(6).

Corporate Governance and Public Policy

Criteria:

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

Risk Level:

Medium

Rationale:

Midland supports DEI within its business practices, hosting a Diversity & Inclusion Council (1). It supports DEI within its business practices. From its Careers webpage: “Diversity and inclusion has been a significant part of our history and a guiding principle for our future” (2). Otherwise, Midland has not supported ideological causes or policies (3).

Criteria:

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

Risk Level:

Lower

Rationale:

Midland 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:

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