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Texas Capital Bank 
Equal Employment Opportunity Policy

Purpose

Texas Capital Bank, and any subsidiaries (collectively, “Texas Capital” or the “Company”) is committed to providing positive business and personnel practices designed to promote equal employment opportunity for job applicants and employees without regard to age (40 or older), race, color, religious creed (which includes religious belief, observance and practice, and dress or grooming practices), qualifying disability (physical or mental), sexual orientation (actual or perceived), gender, gender identity, gender expression, national origin, ancestry, U.S. military obligation or protected veteran status, marital status, familial status, pregnancy (including childbirth, breastfeeding, or related medical conditions), medical conditions, genetic information, marital status, or any other legally protected category.

Scope 

This Equal Employment Opportunity (“EEO”) Policy (or “Policy”) is applicable to all Texas Capital employees. 
 

Key Definitions 

There are no key definitions.
 

Policy

To implement this Policy, the Company will continue to:

  • Recruit, hire, develop and promote individuals in all job classifications in accordance with this Policy; 
  • Make selection decisions according to the principles of equal opportunity by using job-related and non-discriminatory job requirements; and
  • Ensure that all personnel practices and programs including, but not limited to, compensation, benefits, internal mobility, training, job assignments, performance management, and terminations of employment will be administered without regard to the protected categories listed above.

Texas Capital’s officers, directors, managers, and supervisors and with each employee’s help, the Company is committed to providing a work environment that supports these principles in the Company’s daily actions. Individuals who engage in conduct that violates this policy will be subject to disciplinary action, up to and including termination of employment. An employee who is impacted by or observes a potential violation of this Policy should report it to his or her supervisor, Human Resources, or another member of management. The Company prohibits retaliation of any kind against individuals who have made good faith reports or complaints of violations or possible violations of this Policy. The following employee resources are also available to report a concern:

If you have questions regarding this policy, feel free to contact Human Resources at [email protected].
 

Roles & Responsibilities 

All officers, directors, managers, and supervisors are responsible for the implementation of the EEO Policy.
 

Exceptions to Policy

There are no exceptions to the EEO Policy. 
 

Related Policies

TCB Code of conduct 
 

Approval Requirements

The operational Risk Management Committee (“ORMC”) and Executive Risk Committee (“ERC”) are responsible for reviewing and approving this Policy on at least an annual basis.
 

Dissemination

Upon approval, electronic copies of this Policy will be posted to Gateway and Archer.

 

Consequences

All employees are responsible for complying with applicable official Company policies, programs, standards, and procedures. Senior management of each Line of Business (“LOB”) or department is responsible for ensuring adherence to policy within their purview. Relevant units from the Second Line of Defense (“2LOD”), and/or Internal Audit, and potentially other control groups as applicable, will review and monitor compliance with policy. Noncompliance with approved policies may be a breach of the terms of employment and may lead to disciplinary actions which may include termination of employment.

 

Review

This Policy is owned by the Director of HR Compliance and Operations. This Policy was approved by the Operational Risk Management Committee on December 11, 2023 and Executive Risk Committee on January 5, 2024. 
 

Revision History

date

Revision Number

Updates / Changes Made

Approver

December 2020

1

Updated to more closely track the
required categories in CA and NY and
mirror the Anti-Harassment Policy.
Updated to Policy Governance format.
ERC, RC
December 2021

2

Updated Purpose and governance
bodies. 
ORMC, ERC, RC
December 2022

3

Annual review; minor edits and format
changes.
ORMC, ERC, RC
December 2022

4

Annual review; minor edits and format
changes. 
ORMC, ERC, RC
December 2023

5

Annual Review, realigned the approving
body. 
ORMC, ERC

 

Texas Capital Bancshares, Inc. and Texas Capital Bank (the “Companies”) are committed to providing positive business and personnel practices designed to promote equal employment opportunity for job applicants and employees without regard to age, race, color, religion, qualifying disability, sexual orientation, gender, gender identity, gender expression, national origin, U.S. military obligation or protected veteran status, marital status, pregnancy, genetic information or any other legally protected category.

To implement this policy, the Companies will continue to:

Recruit, hire, develop and promote individuals in all job classifications in accordance with this equal opportunity policy;

Make selection decisions according to the principles of equal opportunity by using jobrelated and non-discriminatory job requirements; and

Ensure that all personnel practices and programs including, but not limited to, compensation, benefits, transfers, training, job assignments, performance management, and terminations of employment will be administered without regard to the protected categories listed above.

All officers, directors, managers, and supervisors are responsible for the implementation of our equal employment opportunity policy.

Through these individuals and with your help, the Companies are committed to providing a work environment that supports these principles in our daily actions. Individuals who engage in conduct that violates this policy will be subject to corrective action, up to and including termination of employment. An employee who is impacted by or observes a potential violation of this policy should report it to his or her supervisor, Human Resources, or another member of management. The Companies prohibit retaliation of any kind against individuals who have made good faith reports or complaints of violations or possible violations of this policy. 

The following employee resources are also available to report a concern:

Human Resources at 866.513.9692; select Option 4

Anonymous Employee Hotline at 877.776.0996

Anonymous Employee Website at https://tcbi.alertline.com

Equal Employment Opportunity Commission at www.eeoc.gov

For employees in Maine – Maine Human Rights Commission at www.maine.gov/mhrc

California Department of Fair Employment and Housing at www.dfeh.ca.gov

If you have questions regarding this policy, feel free to contact Human Resources at [email protected].