Updates

Dear Colleagues,

Accurate and reliable books and records are essential to our operations, reputation, and credibility. The FCPA and other applicable laws require that a company maintain books, records, and accounts that, in reasonable detail, accurately reflect the transactions and dispositions of the company. As a result, we must be extremely careful when transactions involve payments or other benefits to government officials or commercial partners,  accurately record all payments to public officials or commercial partners, and always avoid using  “off book” accounts.

At Laureate, all records — including financial accounts, student grades, expense reports, and time sheets— whether electronic or written, must accurately and fairly reflect the underlying events or transactions. Among the most important Laureate records are the contracts through which we commit our resources and agree to specific actions.

Ensuring the accuracy of our books and records is everyone's responsibility, not just that of the accounting and finance departments.

To fulfill this responsibility, we must:

• Never falsify any document.
• Record all non-financial information and financial transactions in the appropriate accounts, departments and accounting periods.
• Comply with all internal controls.

If you suspect any falsification or manipulation of records, please report it to your Local Compliance Officers, or use the confidential Laureate Ethics Helpline.

Sincerely,
Laura Paredes