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[Insert School Name]s Employee Code of Ethics and Conduct

EMPLOYEE CODE

OF

ETHICS

AND

CONDUCT

APSCU is providing this Model Code to assist members in their corporate compliance efforts. This is not intended to be used as an off the shelf document without additional review. Rather, it is important to tailor the Model Code to include your corporate policies and add any relevant information. Please remember that a Code of Ethics and Conduct is just one part of an effective corporate compliance program. Materials on the Compliance and Ethics Library portion of the regulatory page of the APSCU website can help you establish and maintain other parts of your comprehensive program. The information provided in this model code is not legal advice and should not be construed as such.

LEADERSHIP LETTER The CEO or owner should write a short letter to employees explaining the Code of Ethics and Conduct. This section sets the tone and shows importance of the commitment to ethical behavior in the workplace. The letter should discuss the core values and direction of the company or school. A personalized letter in the words of the top leader is important. The letter should discuss the core values and the direction of the company. A sample leadership letter follows on the next page.

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[Insert School Name]s Employee Code of Ethics and Conduct

EXAMPLE

Dear Employees, [Insert school name] is proud of its reputation as a school that strongly values integrity, respect, and truthfulness. This reputation enables us to produce successful students, maintain the confidence of the employers that hire them, and retain the highest quality employees. [Insert school name]s Employee Code of Ethics and Conduct outlines the general ethical standards that all of our employees are expected to live by. While this Code does not address all ethical concerns that you may face during your employment, I hope it will give you the information you need to make ethical decisions on a daily basis. And, I hope you will feel comfortable asking for guidance whenever you need help. When you face an ethical dilemma, I hope you will use the front page test. If you would not want your children and parents to see an article on the front page of your hometown newspaper describing an action you took or failed to take, let that be your guide. We can all sleep better at night knowing that we all act ethically during the day. Thank you for helping [insert school name] continue its commitment to a workplace that sets a positive example for our students and community.

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[Insert School Name]s Employee Code of Ethics and Conduct

Sincerely, CEO

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[Insert School Name]s Employee Code of Ethics and Conduct I. INTRODUCTION This Employee Code of Ethics and Conduct (Code) details [insert school name]s policies for employees. [Insert school name] is committed to a quality business and reputation that values integrity, respect and truthfulness, and a strong commitment to the highest ethical standards. These principles apply to employee interactions with students, the employers that hire them, coworkers, vendors, government and regulatory agencies and the general public. This Code applies to [Insert school name], its Board of Directors, [collectively employees]. [Insert school name] employees must be familiar with this Code and adhere to its guidelines. This Code is not a comprehensive guide of all ethical issues that employees may face, but merely highlights specific problems. In dealing with ethical problems not detailed in this Code, employees are expected to use common sense and their best moral judgment. If an employee has ethical questions, please contact [insert appropriate representative]. This policy may be modified or updated at any time. [Insert school name] welcomes employee suggestions on changes in this Code. II. COMPLIANCE APPLICABLE LAWS REGULATIONS

WITH

AND

[Insert school name] has a policy to observe all laws, rules, and regulations of government agencies and authorities. This specifically includes requirements under the Higher Education Act, as amended, regulations of the United States Department of Education, the policies of accrediting agencies, as well as other state and federal laws. If federal, state or local law exists that is either contradictory or stricter then this policy, employees must apply the law. III.CONFLICTS III.C INTEREST

OF

[Insert school name] employees must avoid having a personal, business, financial, or other interest, activity or relationship, outside [insert school name] that has or may be in conflict with [insert school name] or its students. Any material transaction or relationship that may give rise to an actual or perceived conflict of interest should be discussed with [insert appropriate representative]. Conflicts of interest may include, but are not limited to, the following situations: Outside Employment- employees should not perform work or render direct consulting or managerial services for an organization that competes or

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[Insert School Name]s Employee Code of Ethics and Conduct does business with [insert school name] without appropriate approval from management. Having a personal, social, or romantic relationship with a student or prospective student. Managers or supervisors may not engage in a sexual, romantic, or dating relationship with subordinate employees. Accepting loans or gifts of entertainment, food, or cash of $50 or more from students, subordinate employees, regulatory or any outside concern that does or seeks to do business with or is a competitor to [insert school name]. Obtaining a personal financial benefit in any sale or loan of company property. Performing services for students outside those consistent with [insert school name]s mission of providing higher education and career training programs. Using or disclosing any confidential information gained during employment for an employees personal benefit or the benefit of others, including a future employer. EMPLOYMENT PRACTICES

IV.

For a comprehensive description of Employment Practices, please refer to the Employment Personnel Manual. Discrimination and Harassment [Insert school name] prohibits discrimination and harassment of students or employees whether or not the incidents occur on [insert school name] premises and whether or not the incidents occur during business hours. [Insert school name] follows federal, state, and local law to ensure equal recruitment, employment, compensation, development and advancement opportunity for all qualified individuals, and prohibits deliberate harassment based on federally protected categories of race, color, religion, sex, national origin, age, or disability.

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[Insert School Name]s Employee Code of Ethics and Conduct Workplace Violence- [Insert school name] does not tolerate workplace Violence violence including threats, threatening behavior, harassment, intimidation, assaults or similar conduct. Weapons Policy- [Insert school name] employees may not carry firearms or Policy other weapons on [Insert School name] facilities unless obtaining prior permission. Illegal Drugs and Alcohol Policy [Insert school name] employees must not distribute, possess or use illegal or unauthorized drugs or alcohol on [insert school name] property, or in connection with [insert school name] business. V. BOOKS RECORDS

AND

Accurate and Complete Business Records - Employees must act in good faith not to misrepresent material facts in [insert school name]s books and records or in any internal or external correspondence, memoranda, or communication of any type, including telephone or electronic communications. Financial Reporting- All [insert school name] funds, assets, liabilities and Reporting receipts must be recorded in accordance with generally acceptable accounting procedures. There cannot be any off the books accounts. Proper Maintenance of Records- [Insert school name] maintains documents in accordance with all applicable laws and regulations. If [insert school name] employees receive a subpoena, a request for records or other legal papers or if we have reason to believe that such a request or demand is likely, the law requires [insert school name] to retain all relevant records and contact the [insert appropriate representative]. Cooperation with Auditors- [Insert school name] employees must cooperate fully with internal and outside auditors during examination of [insert school name]s books, records, and operations. VI. ADMISSIONS PROCESS

Business Communications- Employees must not make public statements regarding Communications issues or matters of [insert school name] about which they are not authorized spokespersons.

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[Insert School Name]s Employee Code of Ethics and Conduct Advertising and Marketing- [Insert school name]s policy takes necessary Marketingsteps to assure that all advertised products or services in any of its literature, exhibits or other public statements is true, supported by documentation, and does not mislead customers. VII. USE COMPANY RESOURCES

OF

For a comprehensive description of [insert school name] policy on use of company resources, please see the Employment Personnel Manual. Internet and Electronic Mail Policy Employees may use Internet and send and receive electronic mail solely for business purposes. [Insert school name] electronic mail system is a company resource, and [insert school name] reserves the right to read, view and copy any email communications. Employees must take reasonable care not to disclose confidential information, or acquire unauthorized information over the Internet.

Equipment and Supplies- All equipment and supplies purchased by [insert Supplies school name] remain [insert school name] property, including but not limited to office supplies, office furniture, fax machines, computers, software, hardware, supplies and equipment, and may not be used by [insert school name] employees for personal reasons. Political Activity- [Insert school name] encourages employees to participate Activity in the political process on their own time. Employees may not use [insert school name]s resources, reputation or assets to support a political candidate. Non-work Related Interests- [Insert school name] employees may not use Interests [insert school name] facilities to promote non- [insert school name] or nonwork related interests of the employee or of third parties without prior consent of their supervisor. Proper Use of Organizational Assets- [Insert School name] employees may only use, Assets transfer, or dispose of funds or assets for the lawful and legitimate business purposes for which they were approved by [insert School name]s [insert appropriate representative]. VIII. PRIVACY CONFIDENTIALITY 7

AND

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[Insert School Name]s Employee Code of Ethics and Conduct Confidential Information- [Insert school name] employees must exercise care to avoid disclosing non-public, internal, secret, or proprietary information related to [insert school name] or its students to unauthorized persons, either within or outside [insert school name] during employment or afterwards, except as such disclosure is legally mandated or approved by [insert school name]. Employee Access to Confidential Information- Only [insert school name] Information employees that truly need to know confidential information to conduct their business have access to confidential information and must take necessary steps to keep this information private and confidential. Confidential Information of Employees- Employment and medical records Employees of [insert school name] employees are confidential and private. Medical Records may only be disclosed if the employee provides a written release or required by applicable law. Financial Information of Current and Former Students must be protected as required by privacy laws and regulations. Requirements under The Family and Education Rights and Privacy Act of 1974, as amended (FERPA)- FERPA includes limitations on student (FERPA) educational records that institutions can disclose without the students prior written consent or written consent of the parent if the student is under 18 years of age. FERPA requirements apply to current and former students of [insert school name]. For further explanation of FERPA policy, please refer to [insert appropriate manual], or the FSA handbook. IX. RESOURCES: a. Contact Information i. Schools Human Resources department ii. Ombudsman, if applicable iii. 24 hour employee hotline, if applicable iv. Legal Department/ General Counsel v. Outside Counsel vi. Company-wide representative in chain of schools X. COMPLIANCE CODE

WITH THE

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[Insert School Name]s Employee Code of Ethics and Conduct All [insert school name] employees must know this Code and adhere to its guidelines. If questions arise please contact [insert appropriate representative]. Supervisors- Supervisors must take reasonable care to assure that Supervisors subordinate employees are complying with these guidelines. Supervisors are responsible for misconduct by employees if the supervisor orders misconduct; ratifies the conduct, even by inaction; the supervisor has direct authority and knows of the conduct but fails to act appropriately; or should have known with reasonable diligence that the actions occurred. XI. REPORTING ACTUAL SUSPECTED VIOLATIONS CODE

OR

OF THE

Requirement to Report Actual or Suspected Violations of the Code: Employees must report any actual or suspected violations of this Code to [insert appropriate representative]. Failure to report any actual or suspected violations of the Code is in itself a violation of this Code. Non-Retaliation Policy: Employees will not be retaliated against or subject Policy to any form of reprisal for raising a good faith concern under this policy or participating in an investigation into any such concerns. Retaliation is a serious violation of this Code and should be reported immediately. Investigation of Alleged Violations of the Code: All inquiries, complaints, and reports will be promptly investigated. Employees are expected to cooperate in the investigation. Reasonable measures will be taken to preserve confidentiality of the claim and the identity of anyone who reports a suspected violation or participated in the investigation. If you are unsure whether a violation has occurred, [insert school name] encourages you to seek advice from [insert appropriate representative] before acting. 24 hour Hotline- (if applicable)- [insert school name] has established a toll-free Company hotline. If you have any question or concern, you may call the employee hotline 7 days a week, 24 hours a day. Your question will be considered confidentially. XII. ZERO-TOLERANCE POLICY TOWARD VIOLATIONS CODE

OF THE

[Insert school name] takes a zero-tolerance approach to violations of this Code, failure to report actual or suspected violations of the Code, or retaliation against whistleblowers. Employees that are found to have violated this Code or retaliated against whistleblowers will have their employment with [insert school name] terminated.

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[Insert School Name]s Employee Code of Ethics and Conduct

ACKNOWLEDGEMENT FORM

FOR

CODE

OF

CONDUCT

AND

ETHICS

I have read and am familiar with [Insert School name]s Employee Code of Ethics and Conduct. I will comply with and enforce the policies in this Code in its entirety. I understand my responsibility to promptly report any incident of misconduct or perceived misconduct that I may experience or witness. I further understand that [insert schools name] takes a zero-tolerance approach to violations of this Code, and that violations of the Code or retaliation against whistleblowers will result in termination of employment. By signing this acknowledgement I am indicating that I have read and will abide by [Insert School Name]s Employee Code of Ethics and Conduct.

_______________________ Employee Signature _______________________ Name of School/ Subsidiary

_______________________ Employee name (printed) _______________________ Date

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