Pathward - 1792 Exchange

Rating Overview

Pathward is Lower Risk.

Pathward is Lower Risk. The company does not yield to political activism in shaping corporate governance, preventing initiatives that potentially alienate consumers, divide employees, and harm shareholders. The company implements race and identity-based policies that replace merit, excellence, and integrity with preferential treatment and outcomes. Overall, the company does not embrace corporate initiatives that redirect its central focus from business goals to partisan policies and divisive issues. This approach protects free exercise, free speech, and free enterprise.

Rating Criteria

Corporate Weaponization Risk Levels
Criteria	Risk Level
Cancellations	Lower 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:

Lower

Rationale:

Pathward published a statement to encourage suppliers to follow ESG criteria. However, it has not published guidelines excluding certain suppliers due to ESG criteria (1). Pathward has not publicly 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:

Pathward does not appear to discriminate against charitable organizations based on views or beliefs. The company’s charitable giving focus areas are “work in disaster relief, educational support, financial inclusion, and personal and family empowerment” (1)(2)(3).

Criteria:

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

Risk Level:

High

Rationale:

The company’s DEI Curriculum is used to provide training against implicit bias and advocate for allyship (1). Pathward offers inclusion & belonginng training to its employees (2). The Company appears to prioritize diversity over merit in its promotions & leadership composition. From its Corporate Goverance Guidelines: “While the Company does not have a formal policy with respect to the consideration of diversity in identifying nominees, diversity is considered in the director identification process, with diversity being broadly understood by the Board to mean a variety of gender identities, demographics, opinions, perspectives, and personal and professional experiences and backgrounds” (3). The Company is an affirmative action employer. “Pathward has developed and maintained a written Affirmative Action Program (AAP). Pathward’s Chief Executive Officer supports the affirmative action program and urges each employee to commit to carrying out the intent of this policy” (4). Pathward 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:

High

Rationale:

The Company supports ESG within its business practices. From its 2024 Sustainability Report: “At the beginning of fiscal year 2024, the Board of Directors committee responsible for overseeing and strengthening Pathwards sustainability efforts was the ESG Committee. Effective February 28, 2024, the ESG Committee’s role was subsumed by the Corporate Governance and Nominating Committee, which was renamed the Governance, Nominating and Sustainability Committee (the “”Committee””), in an effort to create administrative efficiencies” (1). Pathward Financial’s CEO Brett Pharr signed the CEO Action for Diversity & Inclusion pledge, which includes a commitment to promote DEI through bias education training in the workplace, strategize on DEI programs/initiatives with other signatories, and engage boards of directors when developing and evaluating DEI strategies (2)(3). The Company supports DEI within its business practices, hosting a DEI Steering Committee (4). Also, from the Company’s Code of Business Conduct: “At Pathward, we place great value on inclusion and belonging, and we are proud of our commitment to treating all employees with dignity and respect through an inclusive work environment. We believe that diversity of backgrounds, thoughts and experiences in our organization leads to more innovative solutions for our customers and partners as we seek to understand the unique needs in the different markets that we serve. All employees are expected to contribute to a culture of mutual respect and inclusion” (5).

Criteria:

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

Risk Level:

Lower

Rationale:

Pathward has not used corporate funds to advance ideological causes, organizations, or policies (1)(2).

Criteria:

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

Risk Level:

Lower

Rationale:

Pathward has not used its PAC donations for ideological purposes and does not engage in lobbying at this time (1)(2)(3).