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The Code sets out principles of integrity and ethical behavior, and our responsibilities to each other, our students, suppliers, stockholders, and the public. It covers such topics as accurate records, proper use of assets and information, conflicts of interest, and bribery and corruption. The Code sets a baseline: it does not cover every issue that may arise, but it provides basic principles and a methodology to help guide us in the attainment of this common goal. The Code establishes common standards for Laureate Education, Inc. and for all the institutions that form the Laureate International Universities network. Following these standards will help maintain the stellar reputation of our institutions and of the network, to the benefit of all the member institutions.
Yes. The Code applies to all Laureate Education, Inc. employees and to all full and part-time faculty and staff at Laureate International Universities network institutions. The Code is important for all of us because we are all associated with our particular institution and with the Laureate network. All of our actions reflect on the reputation of these institutions and help earn the trust that others have in us.
Your Local Compliance Officer is an employee at your institution or in your region who has been designated to address questions about the Code, to receive reports of possible misconduct, to help resolve issues, and to provide certain approvals under the Code. The name and contact information for your Local Compliance Officers is posted here.
Yes, most notably in situations involving potential conflicts of interest. In any work situation in which our personal activities and relationships interfere, or may appear to interfere, with our ability to act in the best interest of Laureate or our institution, we must disclose the situation to our supervisor and Local Compliance Officer (LCO) and take steps to get it resolved. One example is where we are in a position to select a supplier and one of the candidates is a company managed or owned by a relative. The Code also requires prior approval from our LCO before we may serve as an officer or director of any for-profit company or higher-education institution outside of Laureate. And our Policy on Gifts, Meals, Entertainment, Sponsored Travel, and Other Business Courtesies also requires LCO approval before we may give or receive business courtesies that exceed certain monetary thresholds. Consult the Code and other Laureate policies for other circumstances that may require prior approval. Also, charitable contributions generally should be made only to organizations recognized by law as charitable. exceptions must be approved by the General Counsel. We must ensure appropriate due diligence on any charitable organization prior to making a charitable contribution. Our Charitable Contributions Policy establishes additional approval and other requirements for contributions of US$10,000 or more.
Administration of the Code is the responsibility of Laureate Education Inc.’s Chief Ethics & Compliance Officer (CECO) and those designated by the CECO, including the Local Compliance Officers. Laureate takes all reports of potential Code violations seriously and will investigate. The CECO or those designated will assess the situation and determine the appropriate course of investigation. Anyone being investigated for a potential Code violation will have an opportunity to be heard prior to any final determination.
In general, the CECO or those designated, after consultation with relevant Human Resources and management personnel, will determine whether a person has violated the Code and the disciplinary action, if any. Any violation of applicable law or the Code will result in discipline, up to and including termination of employment or contractual relationship.
No. We value and respect all those who raise concerns. We will take all reasonable steps to maintain the confidentiality of reporters, and we will not allow anyone to be treated badly because they have raised an issue honestly. Any retaliation against a person who raises a concern honestly, or participates in an investigation, is a violation of the Code and will be dealt with accordingly. If you believe that you or someone you work with has been retaliated against, report the matter.
The Laureate Ethics Helpline is a confidential resource to raise questions or concerns about conduct that might violate our Code of Conduct and Ethics, other global policies, or the law. This includes issues such as accurate books and records, proper use of assets and information, conflicts of interest, bribery and corruption, and discrimination and harassment.
You can provide as much or as little information as you wish, but the more information you provide the better able we will be to follow up with your concern. Whether you contact the Helpline by phone or the web, you will be asked a series of questions to determine the nature of your concern, what you observed, and who might be involved. If you submit information through the web, you can attach documents with additional information.
Yes. You will not be required to identify yourself in order to ask a question or raise a concern through the Helpline. We encourage you to identify yourself, however, as it will facilitate investigation and further communication. If you make your identity known, we will take every reasonable precaution to keep your identity confidential, consistent with conducting a thorough and fair investigation.
Yes. Anyone about whom a report is made will have an opportunity to respond to any allegations against them, but we may not be able to tell you who raised the allegation.
You do not have to be certain that what you observed is a violation of the Code or the law; you only have to report honestly what you observed. (Knowingly making a false accusation is a violation of the Code.) If you think that you might have observed a violation, it is better to report the matter than ignore it and risk possible harm to others, your institution, or Laureate.
If you provide your name and contact information, we will be able to contact you directly if necessary. In addition, when you make a report, you will be given a report number and code that will allow you to check back in to the Helpline to receive or provide additional information, even if you choose to remain anonymous.
The Helpline is staffed by a professional service provider. Whether you submit information by phone or the web, the service provider will forward the information to Laureate Corporate Compliance personnel. If you have asked a question, we will respond to you with an answer. If you report possible misconduct, appropriate personnel will investigate the matter, decide whether the Code or the law has been violated, and take appropriate action. During the course of the investigation, we may ask you for additional information.
In most cases, the Ethics & Compliance team conducts the investigation. Where the risks dictate, outside investigators may conduct the investigation.
Local management and Laureate Corporate Compliance personnel generally make these decisions jointly. In more serious cases, the Laureate Corporate Ethics & Compliance Committee, or even the Audit Committee of Laureate’s Board of Directors may be involved.
Our Code of Conduct does indeed contain a strong prohibition on bribery and corruption, establishing that we do not pay bribes, even if it means we may lose money or delay a project. The Anti-Corruption Policy repeats this prohibition, but supplements it with important definitions and additional information to help ensure we always do the right thing. In addition, the Anti-Corruption Policy acts as a framework for a more general Anti-Corruption Program that includes education, communication, and a series of more specific Guidelines that address various corruption-related issues.
A government official is any officer or employee of any governmental entity at any level, as well as officers and employees of companies or institutions owned or controlled by the state. Examples include educational regulatory officials, government personnel responsible for issuing licenses and permits, and employees of public high schools.
No, the prohibition on bribery applies to bribery of private parties as well, but particular emphasis is placed on bribery of government officials in the Policy because the risks of corruption are often greater when dealing with government officials.
Contact your Local Compliance Officer before beginning any negotiation to hire a current or recent government employee as a Laureate employee or contractor. Depending on the circumstances under which a contract or employment offer is made, there may be a perception of a bribe. Critical to this determination will be the nature of the candidate’s current or former government position. Note also that many governments place limitations on the ability of government officials to take certain private sector positions shortly after they leave government service.
No. Payments of this sort, even if small, and even if they seem necessary to placate officials who are slowing the process deliberately, are Illegal bribes in most countries. Contact senior management and your Local Compliance Officer, who will work with you to find other solutions to the problem. In most cases, the government will issue the permit if we remain patient. In other instances, we may have to escalate the problem to higher levels of government. Remember, we don’t pay bribes, even if it means we may lose money or delay a project.
Consult your Local Compliance Officer. The arrangement may be legitimate, but raises a risk of corruption if any of the televisions are for the personal use of the administrator. Any arrangement with the hospital must be described in a written agreement containing appropriate anticorruption language, and the televisions must be delivered to and used by the hospital rather than the administrator personally. See our Policy for Securing Clinical Rotations and Other Student Placements for more information.
Do not make the payment. This could be considered by applicable anti-corruption laws, such as the FCPA, as a bribe. Contact senior management and company legal counsel. There may be an action that we can take to minimize disruption while we wait. And we should use legitimate contacts and relationships we have at more senior levels of government to resolve the situation appropriately.
Accompanying the Anti-Corruption Policy, we also have the Gifts, Meals, Entertainment, Sponsored Travel and Other Business Courtesies Policy, U.S. Policy on Government-Related Business Courtesies, Political Contributions, and Lobbying, and another set of Policies concerning the engagement of Third Parties and the precautions we must take to ensure that no one is paying a bribe on our behalf.
Charitable Contributions are defined as Charitable Donations or Charitable Sponsorships made on behalf of Laureate. Charitable Donations are monetary or in-kind contributions to a charitable organization and Charitable Sponsorships are monetary or in-kind support of an event benefiting a charitable organization. For more information see our Charitable Contributions Policy.
The Sponsor is responsible for ensuring appropriate due diligence on any charitable organization prior to making a Charitable Contribution. If the Sponsor has any questions on conducting appropriate due diligence, he or she can contact the local compliance officer or compliance department. For proposed Charitable Contributions of US$10,000 or more, the Sponsor must contact Laureate’s Chief Ethics & Compliance Officer for assistance with due diligence.
Charitable Contributions should be made only to benefit organizations recognized by law as charitable. Exceptions must be approved by the Chief Ethics and Compliance Officer or the Chief Legal Officer.
No. We must always record expenses in the accounting period in which they were incurred.
Don’t do it. Recording enrollments in the system before they occur is falsification of our records. Laureate reports enrollment numbers to the public, and they must be accurate. Falsification of this sort is grounds for dismissal.
The requirement of accuracy applies to every document or electronic record used in our operations, including our financial accounts, invoices, payment records, expense reports, time records, and submissions such as applications and resumes. It also includes all records that we maintain regarding students, including grades, attendance records, and documentation related to tuition payments.
No. We should all strive for accuracy in the preparation of any record, but honest mistakes happen. Only intentional misrepresentation, falsification, or inaccurate recording is a Code violation.
Laureate Education Inc. is a U.S. headquartered company fully subject to U.S. antitrust laws. The reach of these laws is such that actions related to institutions affiliated with Laureate Education may also be subject to these laws. Moreover, most countries have competition laws that are similar in fundamental respects to U.S. law.
The legal relationship between Laureate institutions generally allows them to have discussion and reach agreements on such issues.
What is fair dealing and why is it important?
Fair dealing means dealing honestly with Laureate’s students, suppliers, competitors, and each other. We must not take advantage of anyone through manipulation, concealment, misrepresentation of facts, or any other unfair dealing. Fair dealing is important for ensuring we are Here for Good for our students and partners.
No. But if you have a relative that owns or works for a company that Laureate is doing business with, or is considering doing business with, notify your supervisor or Local Compliance Officer. If your relative owns the company, you should have nothing to do with any decision to do business with the company, nor should you be involved in dealing with the company on Laureate’s behalf. If your relative works for the company, you may also have to recuse yourself, depending on the work that your relative is doing for the company.
No. It is natural to form friendships with people with whom we work closely or over an extended period. But we must never allow those friendships to influence, or appear to influence, us in acting in the best interest of Laureate. If there is any chance that your friendship with a supplier would bias your decision on whether, or how, you would work with that supplier, or if it might appear that way to others, notify your supervisor or Local Compliance Officer.
Not without Local Compliance Officer approval. If the business partner will not be attending the event, the tickets are a gift, not entertainment, and the US$50 limit applies under thePolicy on Gifts, Meals, Entertainment, Sponsored Travel, and Other Business Courtesies. As the two tickets are worth US$100, they are over the limit and must be approved.
It may be possible for your Local Compliance Officer to establish a pre-approval process within a limited period of time, for meals or entertainment of certain types, as long as they remain within certain pre-established limitations.
Yes. Remember, if your institution has established more strict limitations on gifts from students, you should follow those.
No. If you are representing Laureate when you give the gift, or provide the meal, the courtesy would be viewed as coming from Laureate, and the perception of improper influence (that is, a bribe) would remain.
No. The Guidelines apply only to receipt and provision of courtesies with parties outside the organization.
Not if each gift is worth less than the presumptive limit. If you are planning on giving gifts worth more than US$50, then each gift must be approved, but you can obtain all approvals at once by sending a list of gifts and recipients to your Local Compliance Officer with an explanation of why it is reasonable to exceed the limits in these cases.
Your Local Compliance Officer must approve all offers to pay for travel, including those associated with speaking engagements. In general, offers from professional organizations will be approved. The greater danger of improper appearance arises when a vendor or potential vendor offers to pay for travel.
You should politely decline. If returning a gift would offend the giver, or the circumstances preclude its return, you may accept the gift, but should notify your Local Compliance Officer. Your Local Compliance Officer can arrange to donate the item to charity, or to distribute or raffle the item among a large group of personnel. One common solution to receipt of large gift baskets is to share the contents of the basket with your entire department.
You still need to report the situation after the meeting to your Local Compliance Officer, to evaluate if a post facto exception applies considering that in real life situations policy limits may be occasionally exceeded. You should, however, attend to the general prices at a restaurant before inviting someone there, or accept an invitation. If it is clear that this is the sort of restaurant where meals regularly exceed our limits, don’t extend or accept an invitation without first talking to your Local Compliance Officer. In addition, while at the meal, avoid ordering expensive wine or other items that would clearly put you over the limits.
You should follow the more strict limitations.
Use your best judgment, and perhaps do some Internet research. If you are still uncertain what to do, check with your Local Compliance Officer.
Then you should not be entertaining them. That anyone would object to a record of their attendance at a meal or other event indicates that there is an issue with appearances, and reason to be concerned. If we cannot do something transparently, we should not do it.
Contact your manager, your Local Compliance Officer, or use the Laureate Ethics Helpline at www.LaureateEthics.net.
Offering and receiving gifts, meals, entertainment, and other business courtesies is a legitimate business practice that can strengthen relationships and demonstrate our appreciation. But these courtesies also can create the appearance of an attempt to influence (that is, a bribe) if they are too elaborate, too frequent, or are given under circumstances where it may look like they are payment for some favor from the recipient. The Policy describes certain baseline principles about giving and receiving courtesies, and establishes presumptive limits on the value of courtesies that we may give or receive. We may exceed these limits with the approval of our Local Compliance Officer in particular situations, but staying within the limits will ensure that we are not creating the appearance of an attempt to influence.
Yes. The most comprehensive sanctions regimes relate to Cuba, Iran, North Korea, Syria, and the following regions of Ukraine: Crimea, Donetsk, and Luhansk.
Certain Arab countries have participated in a boycott of businesses and institutions in Israel. Businesses and institutions headquartered in some Arab countries may ask questions of Laureate regarding our transactions with Israel entities. We cannot respond to these questions, and must report them to Legal or our Local Compliance Officer.
Money laundering is the process of concealing or disguising the identity of illegally obtained proceeds so that they appear to have originated from legitimate sources. Money laundering is often used to support crime or terrorism. Laureate is committed to complying fully with all applicable anti-money laundering laws.
No. While your intentions are good, only authorized individuals may speak for Laureate. Instead, notify a member of the Corporate Communications Department or your local Communications Department about the article so that appropriate steps can be taken to respond. Please see our Social Media Policy for more information on online media and social networks.
Talk to your manager about it. You may have misunderstood what you were being asked to do, or your manager may have overlooked relevant facts or circumstances. If this does not resolve the matter, or you don’t feel comfortable raising the issue with your manager, speak up. Under no circumstances should you take any action that violates the Code. If you violate the Code, the fact that your manager asked you to do something will not protect you against disciplinary action.
The Code is a foundational document. It is meant to establish basic global standards and general principles of appropriate conduct, not to be a comprehensive set of workplace policies. The Code works in conjunction with local policies, many of which cover similar subjects. We must follow both the Code and local policies. Where there is a conflict, we must follow the stricter standard.
Not necessarily. It depends on the nature of the institution. Check with your Local Compliance Officer before accepting any such invitation.
Laureate’s competitors are for-profit institutions of higher education, whether on-line or classroom, that are not part of the Laureate network.
Maybe. If your job at Laureate does not involve dealing with the company whose stock you own, there is no issue. However, if you deal with the company on behalf of Laureate, or are involved in a vendor selection process where that company is a candidate, you should disclose your stock ownership to your supervisor or Local Compliance Officer. In most cases, you will need to recuse yourself from interaction with the company on behalf of Laureate.
It means that Laureate’s business might benefit from pursuing the opportunity, such as acquiring a piece of land adjacent to a Laureate institution or licensing a relevant trademark.
I have to select a new supplier to provide certain technology services on campus. My brother owns a technology company that I know will do a good job, and he’ll give us a good price. Can I hire my brother’s company?
You should not be involved in the selection process, as it might appear to others that you are favoring your brother rather than making an objective decision. You should notify your supervisor and Local Compliance Officer of your potential conflict of interest, and remove yourself from the decision-making process. Others can make the selection decision, and if your brother’s company offers good service at a good price, he will be seriously considered.
I am an accountant, and one of the vendors with whom I occasionally interact has asked me to do some part-time accounting work for them in the evening and on weekends. I would like the extra money. Can I accept the job offer?
No. Accepting a job from a vendor with whom you interact on behalf of Laureate might create the appearance that the vendor is trying to influence your decision making on behalf of Laureate.
Not without first checking with your Local Compliance Officer or someone in Legal. Even though a journal article or other document may be publicly available on the Internet, it may still be protected by copyright laws that prohibit download or printing and further distribution.
If your institution has a policy that is more restrictive than the Code of Conduct, you must follow your institution’s rule. In this example, you should not use the office phone for personal use.
Yes. Limited personal use of Laureate systems is acceptable if it does not interfere with your ability to do your job, Laureate operations, or the operation of our systems.
Not necessarily. You should only share confidential information with other employees who are authorized to see it and need to know the information as part of their job.
Consult with IT Security before entering into a contract with the vendor or transferring any personal data to them. IT Security can ensure that the necessary protections are in place. For more information, please consult with your Local Compliance Officer or Legal, and the IT Security Department. Refer to the Laureate Data Privacy Policy.
The law and Laureate policy prohibit the purchase or sale of Laureate stock or other securities, directly or indirectly, based on material nonpublic information. If we have material nonpublic information about Laureate, we must not engage in transactions involving Laureate securities or pass on information until this information has been released to the public.
Material information is information that would be expected to affect the investment or voting decisions of a reasonable investor or stockholder. Non-public information is information that has yet to be announced to the public through an authorized disclosure. Material non-public information may include potential acquisitions, marketing strategies, senior management changes, and financial results.
You can ask:
You can also use the confidential Laureate Ethics Helpline at www.LaureateEthics.net, or call the Helpline toll-free using one of the numbers listed on the website.
It is important that you speak up. Raising concerns allows Laureate the opportunity to deal with the issue and correct it, ideally before it becomes a violation of the law or a risk to others. You can raise the issue to the same people you can go to with a question about the Code. You also can use the Laureate Ethics Helpline. For employment-related issues such as harassment, discrimination, bullying or other interpersonal conflicts, you can also contact Human Resources or raise the issue with your supervisor.
Laureate has created a separate Code of Conduct and Ethics for Suppliers that is more suitable for suppliers than employees. For more information on our expectations of suppliers in this area, and some exceptions, visit Supplier Code.
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