Financial Aid Code of Conduct

Amridge University’s Financial Aid Code of Conduct in accordance with the Higher
Education Opportunity Act (HEOA) (H.R. 4137) signed in to law on August 14, 2008,
prohibits conflicts of interest with the responsibilities of officers, employees, and agents
of the University in association with a Federal Student Aid loan program. The University
will publish and enforce with respect to the FSA loan program the Financial Aid Code of
Conduct annually on its website and inform all officers, employees, and agents.

Ban on Revenue-Sharing Arrangements

The University bans revenue-sharing arrangements with any lender. The
University defines “revenue-sharing arrangement” per the HEOA: any arrangement
between an institution and a lender under which the lender makes Title IV loan to
students attending the institution (or to the families of those students), 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 or to its officers, employees, or agents.

Ban on Employees of the Amridge University Financial Aid Office Receiving Gifts
from a Lender, Guaranty Agency or Loan Servicer

The University bans employees of the financial aid office receiving gifts from a
lender, guaranty agency or loan servicer. No officer or employee of an institution’s
financial aid office (or an employee or agent who otherwise has responsibilities with
respect to educational loans) may solicit or accept any gift from a lender, guarantor, or
servicer of education loans. A “gift” is defined as any gratuity, favor, discount,
entertainment, hospitality, loan, or other item having monetary value of more than a de
minimus amount.

However, a gift does not include (1) a brochure, workshop, or training using
standard materials relating to a loan, default aversion, or financial literacy, such as a
brochure, workshop or training; (2) food, training, or informational material provided as
part of a training session designed to improve the service of a lender, guarantor, or
servicer if the training contributes to the professional development of the institution’s
officer, employee or agent; (3) favorable terms and benefits on an education loan
provided to a student employed by the institution if those terms and benefits are
comparable to those provided to all students at the institution; (4) entrance and exit
counseling as long as the institution’s staff are in control of the counseling and the
counseling does not promote the services of a specific lender; (5) philanthropic
contributions from a lender, guarantor, or servicer that are unrelated to education loans or
any contribution that is not made in exchange for advantage related to education loans,
and; (6) State education grants, scholarships, or financial aid funds administered by or on
behalf of a State.

Ban on Contracting Arrangements

The University bans contracting arrangements. No officer or employee of an
Amridge University’s financial aid office (or employee or agent who otherwise has
responsibilities with respect to education loans) may accept from a lender, or an affiliate
of any lender, any fee, payment, or other financial benefit as compensation for any type
of consulting arrangement or contract to provide services to or on behalf of a lender
relating to education loans.

Prohibition against Steering Borrowers to Particular Lenders or Delaying Loan

The University has a prohibition against steering borrowers to particular lenders
or delaying loan certifications. For any first-time borrower, Amridge University may not
assign, through the award packaging or other methods, the borrower’s loan to a particular
lender. In addition, Amridge University may not refuse to certify, or delay the
certification, of any loan based on the borrower’s selection of a particular lender or
guaranty agency.

Prohibition on Offers of Funds for Private Loans

The University has a prohibition on offers of funds for private loans. Amridge
University may not request or accept from any lender any offer of funds for private loans,
including funds for an opportunity pool loan, to students in exchange for providing
concessions or promises to the lender for a specific number of Title IV loans made,
insured, or guaranteed, a specified loan volume, or a preferred lender arrangement. An
“opportunity pool loan” is defined as a private education loan made by a lender to a
student (or the student’s family) that involves a payment by the institution to the lender
for extending credit to the student.

Ban on Staffing Assistance

The University bans staffing assistance. Amridge University may not request or
accept from any lender any assistance with call center staffing or financial aid office
staffing, except that a lender may provide professional development training, educational
counseling materials (as long as the materials identify the lender that assisted in preparing
the materials), or staffing services on a short-term, nonrecurring basis during emergencies
or disasters.

Ban on Advisory Board Compensation

The University bans advisory board compensation. An employee of Amridge
University’s financial aid office (or employee who otherwise has responsibilities with
respect to education loans or financial aid) who serves on an advisory board, commission, or group established by a lender or guarantor (or a group of lenders or guarantors) is prohibited from receiving anything of value from the lender, guarantor, or group, except
for reimbursement for reasonable expenses incurred by the employee for serving on the