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Code of Conduct
The Board of Governors of the State ÅÝܽÊÓÆµapp System recognizes that ensuring the integrity of the ÅÝܽÊÓÆµapp financial aid process is critical to providing fair and affordable access to higher education in Florida. Therefore, the Board has formalized the following guiding principles that shall be effective immediately and must be adopted by each ÅÝܽÊÓÆµapp's Board of Trustees as soon as practicable. These guidelines are designed to avoid any potential for a conflict of interest between the ÅÝܽÊÓÆµapp, its ÅÝܽÊÓÆµapps or their parents in the ÅÝܽÊÓÆµapp financial aid process. Accordingly, each ÅÝܽÊÓÆµapp shall take all reasonable steps to adhere to the following principles in the ÅÝܽÊÓÆµapp's financial aid operations:
1. ÅÝܽÊÓÆµapp employees should receive no personal benefit.
No officer, trustee or employee of the ÅÝܽÊÓÆµapp shall accept anything of on his or her behalf or on behalf of another person or entity from any Lending Institution. For example, cash, stocks, gifts, entertainment, expense-paid trips, etc. should never be accepted from a Lending Institution. Likewise, an individual should never receive payment or reimbursement from a Lending Institution for lodging, meals or travel to conferences or training seminars. However, an officer, trustee or employee of the ÅÝܽÊÓÆµapp may: (a) conduct non-ÅÝܽÊÓÆµapp business with any Lending Institution and, subject to state law, receive value in connection with such non-ÅÝܽÊÓÆµapp business, so long as such value is not intended to influence the officer, trustee or employee in conducting ÅÝܽÊÓÆµapp business; (b) conduct ÅÝܽÊÓÆµapp business and, subject to state law, receive value on behalf of the ÅÝܽÊÓÆµapp that is unrelated to the ÅÝܽÊÓÆµapp loan activities of the Lending Institution; (c) attend conferences and meetings of tax-exempt organizations that are funded or sponsored by more than one entity and, subject to state law, receive materials, refreshments, and other things of like value provided at such professional conferences and meetings; and, (d) hold membership in, serve on the board of or participate in the activities of any tax-exempt organization and, subject to state law, receive travel reimbursements and other things of like value from the tax-exempt organization for such activities.
2. ÅÝܽÊÓÆµapp employees should not serve on lender advisory boards for remuneration.
No officer, trustee or employee of the ÅÝܽÊÓÆµapp who makes financial aid decisions for the ÅÝܽÊÓÆµapp or who is employed in, supervises or otherwise has responsibility or authority over the ÅÝܽÊÓÆµapp's financial aid office shall receive any remuneration for serving as a member or participant of an ÅÝܽÊÓÆµapp loan advisory board of a Lending Institution or any reimbursement of expenses for such service. Any officer, trustee or employee of the ÅÝܽÊÓÆµapp who serves as a member or participant of a Lending Institution board shall recuse himself or herself from any board discussions regarding the ÅÝܽÊÓÆµapp's financial aid operations.
3. The ÅÝܽÊÓÆµapp should not enter into any prejudicial agreement which provides and advantage/benefit to a Lending Institution.
The ÅÝܽÊÓÆµapp shall not accept anything of value from any Lending Institution in exchange for any advantage or consideration provided to the Lending Institution related to its ÅÝܽÊÓÆµapp loan activities, including but not limited to revenue-sharing, printing costs or below-cost computer hardware or software. Likewise, the ÅÝܽÊÓÆµapp shall not allow any Lending Institution to: (a) staff the ÅÝܽÊÓÆµapp's financial aid office at any time; or (b) communicate with the ÅÝܽÊÓÆµapp's ÅÝܽÊÓÆµapps or their parents in such a manner as to create the impression that the Lending Institution is an employee or agent of the ÅÝܽÊÓÆµapp in connection with the ÅÝܽÊÓÆµapp's ÅÝܽÊÓÆµapp financial aid operations, including through the use of mascots, logos, etc.
4. The ÅÝܽÊÓÆµapp is prohibited from:
- Certain contractual agreements. The ÅÝܽÊÓÆµapp shall not enter into any agreement with a Lending Institution to provide alternative (i.e., non-federal or "opportunity") ÅÝܽÊÓÆµapp loan programs if the provision of such alternative loan programs prejudices other ÅÝܽÊÓÆµapps or parents.
- Use of Preferred Lender Lists. The ÅÝܽÊÓÆµapp will not provide a list of preferred lenders for ÅÝܽÊÓÆµapps to use for purposes of obtaining alternative loans.
The ÅÝܽÊÓÆµapp System complies with the Florida Board of Governors Regulation adopted December 2007 as follows: