CODE OF CONDUCT

Midway Paris Beauty School recognizes that ensuring the integrity of the student financial aid process is critical to providing fair and affordable access to higher education in New York. Therefore, the Institution has formalized the following guiding principles that shall be effective immediately and must be adopted by each Institution location. These guidelines are designed to avoid any potential for a conflict of interest between Midway Paris Beauty School, its students or their parents in the student financial aid process. Accordingly, each location shall take all reasonable steps to adhere to the following principles in the Institutions financial aid operations:

1. All Midway Paris Beauty School employees should receive no personal benefit. No officer, trustee or employee of Midway Paris Beauty School shall accept anything of more than nominal value 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 Midway Paris Beauty School may:

• a. conduct non-Institution business with any Lending Institution and, subject to state law, receive value in connection with such non-Institution business, so long as such value is not intended to influence the officer, trustee or employee in conducting Institution business;
• b. conduct Institution business and, subject to state law, receive value on behalf of Midway Paris Beauty School that is unrelated to the student 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. Midway Paris Beauty School employees should not serve on lender advisory boards for remuneration. No officer, trustee or employee of Midway Paris Beauty School who makes financial aid decisions for Midway Paris Beauty School or who is employed in, supervises or otherwise has responsibility or authority over Midway Paris Beauty School financial aid office shall receive any remuneration for serving as a member or participant of an student loan advisory board of a Lending Institution or any reimbursement of expenses for such service. Any officer, trustee or employee of Midway Paris Beauty School who serves as a member or participant of a Lending Institution board shall recuse himself or herself from any board discussions regarding Midway Paris Beauty School financial aid operations.

• a. staff Midway Paris Beauty School's financial aid office at any time; or
• b. communicate with Midway Paris Beauty School's students or their parents in such a manner as to create the impression that the Lending Institution is an employee or agent of Midway Paris Beauty School in connection with Midway Paris Beauty Institution's student financial aid operations, including through the use of mascots, logos, etc. Finally, Midway Paris Beauty School shall not enter into any agreement with a Lending Institution to provide alternative (i.e., non-federal or "opportunity") student loan programs if the provision of such alternative loan programs prejudices other students or parents.

3. Midway Paris Beauty School should make appropriate use of any Preferred Lender Lists. If Midway Paris Beauty School decides to promulgate a list or lists of preferred or recommended lenders for student loans or similar ranking or designation ("Preferred Lender List"), the selection of Lending Institutions for inclusion on the Preferred Lender List shall be based on the best interests of Midway Paris.