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School of Medicine
Financial Aid Code of Conduct
St. George's University ("SGU") recognizes that ensuring the integrity of the student financial aid process is critical to providing fair and affordable access to higher education. These guidelines are designed to avoid any potential for a conflict of interest between SGU, its students or their parents in the student financial aid process. Accordingly, SGU shall adhere to the following principles in SGU's financial aid operations:
1. SGU employees should receive no personal benefit.
No Trustee, Director, Manager, Subsidiary, Officer, Employee or Assign of SGU 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, a trustee or employee of SGU may: (a) conduct non-SGU business with any Lending Institution and, subject to law, receive value in connection with such non-SGU business, so long as such value is not intended to influence the trustee or employee in conducting SGU business; (b) conduct SGU business and, subject to law, receive value on behalf of SGU 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 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 law, receive travel reimbursements and other things of like value from the tax-exempt organization for such activities.
2. SGU employees should not serve on lender advisory boards for remuneration.
No Trustee, Director, Manager, Subsidiary, Officer, Employee or Assign of SGU of SGU who makes financial aid decisions for SGU or who is employed in, supervises or otherwise has responsibility or authority over SGU's financial aid office shall receive any remuneration for serving as a member or participant of a student loan advisory board of a Lending Institution or any reimbursement of expenses for such service. Any trustee or employee of SGU who serves as a member or participant of a Lending Institution board shall recuse himself or herself from any board discussions regarding SGU's financial aid operations.
3. SGU should not provide any advantage to a Lending Institution.
SGU 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 student loan activities, including but not limited to revenue-sharing, printing costs or below-cost computer hardware or software. Likewise, SGU shall not allow any Lending Institution to: (a) staff SGU's financial aid office at any time; or (b) communicate with SGU's students or their parents in such a manner as to create the impression that the Lending Institution is an employee or agent of SGU in connection with SGU's student financial aid operations, including through the use of mascots, logos, etc. Finally, SGU 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.
4. SGU should make appropriate use of any Preferred Lender Lists.
If SGU decides to promulgate a list or lists of preferred or recommended lenders for student loan 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 SGU's students and their parents without regard to the financial interests of SGU. In addition, any Preferred Lender List shall clearly explain:
SGU shall review any Preferred Lender List on an annual basis to determine that the information appearing on the list is accurate and that any website links are still viable.
1. Lending Institution is any entity (other than an institution of higher education or a governmental entity such as the U.S. Department of Education) involved in the making, holding, consolidating or processing of any student loans.
2. The University may accept any assistance that is authorized by 34 C.F.R. 682.200(b)(5)(i) (definition of "Lender").