Student Loan Code of Conduct

Policy Statement

Prism Career Institute, as a participant in federal loan programs, is required to have a code of conduct applicable to the institution’s officers,
employees, and agents. The code of conduct requirements are set forth in the Higher Education Opportunity Act (HEOA) signed into law on August 14,
2008.

Reason for Policy

The HEOA program participation agreement, which must be executed by all institutions participating in Title IV financial aid programs including student loan programs, requires a code of conduct with which the institution’s officers, employees, and agents shall comply. Such code must prohibit a conflict of interest with the responsibilities of an officer, employee, or agent of an institution with respect to such loans, and include the provisions set forth in the HEOA related to conflicts. The law further specifies that the code shall be displayed prominently on the institution’s website and that
all employees and agents with responsibilities related to such loans be annually reminded (and review) the code of conduct.

Code of Conduct

Prism Career Institute hereby adopts the following provisions from the HEOA, Section 493 as its Code of Conduct Related to Student Loan Activities and
will annually inform all institutional officers, employees, and agents with responsibilities for student loan activities and decisions of the
provisions of this code. This code is supplemental to existing university policies related to conflicts of interest and commitment.

(1) BAN ON REVENUE-SHARING ARRANGEMENTS.-

(A) PROHIBITION.-The institution shall not enter into any revenue-sharing arrangement with any lender.

(B) DEFINITION.-For purposes of this paragraph, the term ‘revenue-sharing arrangement’ means an arrangement between an institution and a lender under
which-

(i) a lender provides or issues a loan that is made, insured, or guaranteed under this title to students attending the institution or to the families
of such students; and

(ii) the institution recommends the lender or the loan products of the lender and in exchange, the lender pays a fee or provides other material
benefits, including revenue or profit sharing, to the institution, an officer or employee of the institution, or an agent.

(2) GIFT BAN.-

(A) PROHIBITION.-No officer or employee of the institution who is employed in the financial aid office of the institution or who otherwise has
responsibilities with respect to education loans, or agent who has responsibilities with respect to education loans, shall solicit or accept any gift
from a lender, guarantor, or servicer of education loans.

(B) DEFINITION OF GIFT.-

(i) IN GENERAL.-In this paragraph, the term ‘gift’ means any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a
monetary value of more than a de minimus amount. The term includes a gift of services, transportation, lodging, or meals, whether provided in kind, by
purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred.

(ii) EXCEPTIONS.-The term ‘gift’ shall not include any of the following:

(I) Standard material, activities, or programs on issues related to a loan, default aversion, default prevention, or financial literacy, such as a
brochure, a workshop, or training.

(II) Food, refreshments, training, or informational material furnished to an officer or employee of an institution, or to an agent, as an integral part
of a training session that is designed to improve the service of a lender, guarantor, or servicer of education loans to the institution, if such
training contributes to the professional development of the officer, employee, or agent.

(III) Favorable terms, conditions, and borrower benefits on an education loan provided to a student employed by the institution if such terms,
conditions, or benefits are comparable to those provided to all students of the institution.

(IV) Entrance and exit counseling services provided to borrowers to meet the institution’s responsibilities for entrance and exit counseling as
required by subsections (b) and (l) of section 485, as long as-

(aa) the institution’s staff are in control of the counseling, (whether in person or via

electronic capabilities); and

(bb) such counseling does not promote the products or services of any specific lender.

(V) Philanthropic contributions to an institution from a lender, servicer, or guarantor of education loans that are unrelated to education loans or any
contribution from any lender, guarantor, or servicer that is not made in exchange for any advantage related to education loans.

(VI) State education grants, scholarships, or financial aid funds administered by or on behalf of a State.

(iii) RULE FOR GIFTS TO FAMILY MEMBERS.-For purposes of this paragraph, a gift to a family member of an officer or employee of an institution, to a
family member of an agent, or to any other individual based on that individual’s relationship with the officer, employee, or agent, shall be considered
a gift to the officer, employee, or agent if-

(I) the gift is given with the knowledge and acquiescence of the officer, employee, or agent; and

(II) the officer, employee, or agent has reason to believe the gift was given because of the official position of the officer, employee, or agent.

(3) CONTRACTING ARRANGEMENTS PROHIBITED.-

(A) PROHIBITION.-An officer or employee who is employed in the financial aid office of the institution or who otherwise has responsibilities with
respect to education loans, or an agent who has responsibilities with respect to education loans, shall not accept from any lender or affiliate of any
lender any fee, payment, or other financial benefit (including the opportunity to purchase stock) as compensation for any type of consulting
arrangement or other contract to provide services to a lender or on behalf of a lender relating to education loans.

(B) EXCEPTIONS.-Nothing in this subsection shall be construed as prohibiting-

(i) an officer or employee of an institution who is not employed in the institution’s financial aid office and who does not otherwise have
responsibilities with respect to education loans, or an agent who does not have responsibilities with respect to education loans, from performing paid
or unpaid service on a board of directors of a lender, guarantor, or servicer of education loans;

(ii) an officer or employee of the institution who is not employed in the institution’s financial aid office but who has responsibility with respect to
education loans as a result of a position held at the institution, or an agent who has responsibility with respect to education loans, from performing
paid or unpaid service on a board of directors of a lender, guarantor, or servicer of education loans, if the institution has a written conflict of
interest policy that clearly sets forth that officers, employees, or agents must excuse themselves from participating in any decision of the board
regarding education loans at the institution; or

(iii) an officer, employee, or contractor of a lender, guarantor, or servicer of education loans from serving on a board of directors, or serving as a
trustee, of an institution, if the institution has a interest policy that the board member or trustee must excuse themselves from any education loans
at the institution.

Sanctions

Violations of this policy, including the failure to avoid a prohibited activity or disclose a conflict of interest in timely manner, will be dealt with
in accordance with applicable university policies and procedures, which may include disciplinary actions up to and including termination from the
institution.

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