Code of Conduct for Education Loan Practices

Amended and Restated as of June 11, 2010

All trustees, officers, employees, and agents of Johnson & Wales University and all of its campuses, departments, units, and related organizations are required to act lawfully, ethically, and with integrity and to avoid actual or potential conflicts of interest in connection with “education loans” to prospective, current or former students and their families. In addition to compliance with the university’s Code of Ethics and Conflict of Interest policies, they must abide by this code of conduct and all applicable federal and state laws, rules, and regulations in their communications and interactions with lending institutions, as well as in their communications and interactions with prospective, current, and former students and their families regarding "education loans."

1. Definitions As used in this Code of Conduct, these terms will have the following meanings:

• "Education loan" means any loan made for the express purpose of financing the postsecondary education expenses of a student the university, including loans made though federal financial aid programs and loans made by banks, companies, or other private lenders, but not including open-ended credit arrangements such as credit card debt or loans secured by a mortgage.
• "Borrowers" means prospective, current, or former students of the university or their family members who may or have received one or more education loans.
• "Financial aid employees" means employees or agents of the university who work in student financial services (including in the Financial Aid, Billing & Collections, and Financial Planning departments) or who have any responsibilities with respect to education loans.
• "Lender" means any bank, institution, government agency, or other lender which provides or issues education loans to borrowers and any company or entity which guaranties or services education loans.

2. Revenue Sharing Prohibited Neither the university nor any employee on behalf of the university may accept or agree to accept any fee, payment (including a share of revenue or profits), or anything else of value from a lender if the university recommends the lender or its loan products directly or indirectly to borrowers.

3. Permitted Practices The university and its employees on behalf of the university may accept and/or receive from lenders the following:

• Standard materials (such as brochures), activities (such as workshops), or programs (such as training programs) on default aversion or prevention, financial literacy, or other education loan issues.
• Food, refreshments, training, and informational materials furnished as an integral part of a training session contributing to the professional development of the employee(s) and designed to improve the service of a lender, guarantor, or servicer of education loans.
• Favorable terms, conditions, or benefits on an education loan to an employee or student employee if such terms, conditions, or benefits are comparable to those provided to all students at the university.
• Entrance and exit counseling for borrowers as long as university staff are in control of the counseling and the counseling does not promote the products or services of any specific education lender.
• Staffing assistance for: (i) professional development training for financial aid administrators, (ii) providing educational counseling materials to borrowers (as long as the materials clearly identify any lender who provided, prepared, or helped prepare the materials), and (iii) financial aid related functions on a short term basis during emergencies such as officially declared national or natural disasters, and other emergencies identified by the US Secretary of Education.
• Philanthropic contributions to the university that are not made in exchange for any advantage related to education loans from the lender.
• State education grants, scholarships, or financial aids funds administered by or on behalf of a state.

4. Prohibited Gifts and Compensation Except for the practices listed in Section 3 above, neither the university nor any financial aid employee shall solicit or accept anything having a value in excess of ten dollars from any lender including, without limitation, the following:

• Gifts, gratuities, or favors;
• Discounts, loans, advanced payments, or reimbursement;
• Services;
• Entertainment, hospitality, transportation, lodging, or meals;
• Compensation for consulting or contracting to provide services to or on behalf of a lender relating to education loans; and
• Staffing assistance for call center or financial aid office operations.

5. Gifts to Family Members Prohibited Financial aid employees will be held responsible if a family member or other person with whom the employee has a relationship receives a gift from an education lender, guarantor, or servicer and the employee knows about the gift and has reason to believe the gift was given because of the position of the employee.

6. Consulting and Other Services Financial aid employees may not receive any fee, payment, or other financial benefit from a lender in exchange for consulting or providing services to or on behalf of a lender relating to education loans.

7. Lender Boards of Directors Employees who work in the university’s financial aid office may not serve on a board of directors of a lender at any time. Other employees who have responsibility for education loans may serve on the board of directors of a lender only in accordance with the university’s written conflict of interest policy requiring employees to recuse themselves from participating in any decisions of the board regarding education loans at the university. University employees with no responsibility for education loans may serve on a lender’s board of directors without such restrictions.

8. Lender Advisory Boards Financial aid employees may serve on an advisory board of a lender or a lender group or commission only if the financial aid employee does not receive payment or anything of value from the lender other than reimbursement for reasonable expenses incurred in serving on the advisory board, group, or commission.

9. University Trustees University trustees who are officers, employees, or contractors of a lender must recuse themselves from any decision regarding education loans at the university.

10. Assignment and Certification of Education Loans Neither the university nor any employee on behalf of the university may assign a borrower’s loan to a particular lender through award packaging or other methods, nor may they refuse or delay certification of any education loan based on the borrower’s selection of a particular education lender or guarantor.

11. Funds to Make Education Loans Neither the university nor any employee on behalf of the university may request or accept funds from a lender to be used to make educations loans to borrowers (including funds for an opportunity loan pool) in exchange for concessions or promises such as a specified number of education loans, a specified loan volume, a preferred lender arrangement, or the payment to the lender of points, premiums, additional interest, or financial support.