The Code of Conduct establishes that:

Employees shall not enter into any revenue-sharing arrangement with

any lender where the lender provides or issues a Title IV loan to the student

or student’s family in exchange for the school recommending the lender or

the lender’s loan products in exchange for a fee or material benefit including

profit or revenue sharing that benefits the school or a school’s employee or

agent.

Employees shall not solicit or accept any gift in the form of a gratuity,

favor, discount, entertainment, hospitality, loan, service, transportation,

lodging, meals, reimbursement, or other item having a monetary value of

more than a de minimis (nominal) amount from a lender, guarantor, or

servicer. Certain items and services are exempt from the definition of “gift”

as outlined in Addendum A.

Employees must not accept any fee, payment, or other financial

benefit (including the opportunity to purchase stock) from a lender as

compensation for any type of consulting arrangement or other contract to

provide services to a lender or on behalf of a lender. Exceptions may include

service as outlined in Addendum B.

The school shall not request or accept funds from any lender for

private education loans including funds for an opportunity pool loan to it

students in exchange for the school providing promises of a specified loan

number or volume or a preferred lender arrangement for educational loans.

Employees shall not assign, through award packaging or other

methods, a first-time borrower’s loan to a particular lender or refuse or delay

processing of a loan based on the borrower’s selection of a lender or

guarantor.

Employees shall not accept or request any assistance with call center

or financial aid office staffing from any lender except as allowed by law.

Employees who serve on an advisory board, commission, or group

established by a lender, guarantor, or group of lenders or guarantors, shall be

prohibited from receiving anything of value from the lender, guarantor,

group of lenders or guarantors. However, the employee may be reimbursed

for reasonable expenses incurred in serving on the advisory board,

commission, or group.

Addendum A: Exceptions to the term “gift”.

Materials, activities, or programs related to loan issues, default aversion,

default prevention or financial literacy, such as a brochure, a workshop, or

training.

Food, refreshments, training, or informational material furnished to an

officer or employee of the school or to an agent as a apart to a training

session designed to improve the service of a lender, guarantor, or servicer of

education loans to the school if such training contributes to the professional

development of the school’s staff.

Favorable terms, conditions, and borrower benefits on an education loan

provided to a student employed by the school if the same terms, conditions,

or benefits are comparable to those provided to all students at the school.

Entrance and exit counseling as long as the school’s staff is in control of

the counseling (whether in person or via electronic capabilities) and the

counseling does not promote the products or services of any specific lender.

Philanthropic contributions to a school from a lender, servicer, or

guarantor that are unrelated to education loans and not made in exchange for

any advantage related to education loans.

Education grants, scholarships or financial aid administered by or on

behalf of a State.

Addendum B: Exceptions to “contracting arrangements”.

Paid or unpaid service on a Board of Directors of a lender, guarantor,

or servicer of education loans by an officer or employee of a school who is

not employed in the financial aid office and who does not have

responsibilities with respect to education loans or an agent who does not

have responsibilities with respect to education loans.

Paid or unpaid service on a Board of Directors of a lender, guarantor,

or servicer of education loans by an officer or employee of a school who is

not employed in the financial aid office but who does have responsibilities

with respect to education loans as a result of a position held at the school or

an agent who has responsibilities with respect to education loans if the

school has a written conflict of interest policy that clearly sets forth the

requirement that officers, employees, or agents must recuse themselves from

participating in any decision of the Board with regard to education loans at

the school.

Service by an officer, employee, or contractor of a lender, guarantor,

or servicer of education loans on a Board of Directors or as a trustee of a

school if the school has a written conflict of interest policy the Board

member or trustee must recuse himself/herself from any decision with regard

to education loans at the school