Marketing and Communications Policyd3vq3bu6rx453k.cloudfront.net/.../MarketingAndCommunicationsPoli… · Marketing and Communications Policy ... The following is a synopsis of advertising

Regulatory Compliance January 4, 2016 V2.5 Page 1

Marketing and Communications Policy

Policy Owner: DVG Regulatory Compliance


Contents I. Policy Statement ........................................................................................................................................ 4

II. Scope and Application ............................................................................................................................... 4

III. Purpose .................................................................................................................................................... 4

IV. Definitions ................................................................................................................................................ 4

V. Marketing and Communication Regulations ............................................................................................ 5

A. Advertising and Communications ..................................................................................................... 5

B. General Requirements ...................................................................................................................... 6

C. Prohibited Activities .......................................................................................................................... 7

VI. Gainful Employment Disclosure Requirements ....................................................................................... 7

A. Student Consumer Information ........................................................................................................ 8

B. Program Home Pages ........................................................................................................................ 8

VII. Misrepresentation .................................................................................................................................. 9

VIII. Accreditation........................................................................................................................................ 10

A. Carrington College Institutional Accreditation ............................................................................... 10

B. Carrington College Programmatic Accreditation ............................................................................ 11

XI. Admissions Staff / Recruiter Titles ......................................................................................................... 11

XII. Advertising Approval or Authorization to Operate ............................................................................... 11

XII. Required Approvals ............................................................................................................................... 12

A. Approved Assets Usage ................................................................................................................... 12

B. Branded Search Terms Usage ......................................................................................................... 12

C. Marketing and Communications Approval Process ........................................................................ 12

D. Public Speaking and Presentations ................................................................................................. 14

a) Payment for External Speaking Engagements ............................................................................ 15

E. Approval of Internal Mass Communications .................................................................................. 16

XIV. Advertising Approved Programs .......................................................................................................... 17

A. Advertising for Online Programs ..................................................................................................... 18

B. Placement of Advertising ................................................................................................................ 18

C. Program Options ............................................................................................................................. 18

D. Degree Nomenclature ..................................................................................................................... 19

XVI. Advertising in Languages other than English ....................................................................................... 19


XVII. Logo Usage and Naming Conventions ................................................................................................ 19

IX. Use of Copyrighted Material .................................................................................................................. 20

X. Use of Trademarks .................................................................................................................................. 20

XVIII. State Specific Requirements .............................................................................................................. 21

XIX. Enrollment Promotions ........................................................................................................................ 22

XX. Scholarships .......................................................................................................................................... 24

XXI. Using References to Financial Aid, Scholarships, and Grants in Advertisements ................................ 25

XXII. Using Military, Veterans’ Affairs or GI Bill® References in Advertisements or Student-Facing

Materials ..................................................................................................................................................... 21

XXIII. Sweepstakes and Contests ................................................................................................................ 25

A. Sweepstakes .................................................................................................................................... 25

B. Contests .......................................................................................................................................... 26

C. Raffles.............................................................................................................................................. 26

D. Trademarks ..................................................................................................................................... 26

E. Official Rules ................................................................................................................................... 26

F. Contacting Sweepstakes and Contest Entrants .............................................................................. 27

XXV. Terms and Phrases to Avoid ............................................................................................................... 27

XXVI. Superiority Claims, Substantiation, Footnote Disclosures, Testimonials/Endorsements ................. 28

A. Claims .............................................................................................................................................. 28

B. Claim Substantiation ....................................................................................................................... 28

C. Footnote Disclosures ...................................................................................................................... 29

D. Testimonials and Endorsements ..................................................................................................... 29

XXVII. Do Not Contact and CAN-SPAM Compliance.................................................................................... 31

XXVIII. Surveys ............................................................................................................................................. 31

XXIX. Web Marketing and Vendor Compliance .......................................................................................... 32

XXX. Speaking Up ........................................................................................................................................ 33


I. Policy Statement DeVry Education Group (DVG) and its institutions are committed to operating in compliance with State,

Federal and accrediting agency advertising, marketing, and recruitment requirements, and to ensuring

that colleagues and third parties acting on behalf of our institutions do not misrepresent our institution,

programs, policies or services.

II. Scope and Application This policy applies to all DVG, Carrington Colleges Group Inc., Carrington College colleagues as well as

any third parties developing public facing materials and communications on behalf of the institution.

III. Purpose The purpose of this policy is to ensure that colleagues and third parties are aware of their

responsibilities regarding development, approval and placement of publications and promotional items

that could be encountered by prospective students and the public.

IV. Definitions Abusive adj. An abusive act or practice: materially interferes with the ability of a consumer to

understand a term or condition of a consumer financial product or service or takes unreasonable

advantage of: a lack of understanding on the part of the consumer of the material risks, costs, or

conditions of the product or service; the inability of the consumer to protect its interests in selecting or

using a consumer financial product or service; or the reasonable reliance by the consumer on a covered

person to act in the interests of the consumer [Consumer Financial Protection Bureau]

Advertise v. 1. To make public announcement of, esp. to proclaim the qualities or advantages of so as to

increase sales 2. To make generally known 3. To call the attention of the public to a product or business

[Webster]

Agent n. One that acts or has the authority to act; or that acts as the representative of another

[Webster]

Communication n. The exchange of ideas, messages, or information [Webster]

Deceptive adj. A representation, omission, act or practice is deceptive when 1. The representation,

omission, act, or practice misleads or is likely to mislead the consumer 2. The consumer’s interpretation

of the representation, omission, act, or practice is reasonable under the circumstances 3. The misleading

representation, omission, act, or practice is material [Consumer Financial Protection Bureau]

Market n. To offer for sale [Webster]

Misleading Any statement made in writing, visually, orally, or through other means that has the

tendency or likelihood to deceive or confuse [Final Program Integrity Rules, Department of Education]


Misrepresent v. To represent falsely; to give an untrue or misleading idea of [Webster]

Recruit n. To fill up the number of with new members [Webster]

Represent v. To function as the official and authorized delegate or agent for; to act as a spokesperson

for [Webster]

Statement n. Any communication made in writing, visually, orally or through other means [Final

Program Integrity Rules, Department of Education]

Unfair adj. An act or practice is unfair when 1. It causes or is likely to cause substantial injury to

consumers 2. The injury is not reasonably avoidable by consumers 3. The injury is not outweighed by

countervailing benefits to consumers [Consumer Financial Protection Bureau]

V. Marketing and Communication Regulations The following is a synopsis of advertising and marketing regulations published in federal and state

education agency statutes and rules that are the basis for the Carrington College Marketing and

Communications policy.

A. Advertising and Communications Advertising and communications include any printed, published, recorded, broadcast, electronically

transmitted, or publicly presented information that markets or describes the institution for any purpose.

It includes any form of public notice however disseminated or utilized by an institution of higher

education.

Included is virtually every publication and promotional item that could be encountered by prospective

students from recruitment and promotional activities. Examples include, but are not limited to:

Billboards

Blogs on institutional webpage

Brochures

Call center scripts

Catalogs

Direct mail

Disclosures

Digital advertising including billboards, transportation center signs, and bulletin boards

Flyers posted on bulletin boards

Internet/online advertising (includes digital display, landing pages)

Newsletters and other school publications

Magazine and newspaper ads

Posters

PowerPoint presentations and training desks, including talking points


Press releases or announcements

Radio, video and television advertisement scripts prior to recording

Recruitment and Student Finance presentations and scripts

Signage

Student communications and newsletters sent via direct mail, the student portal, email or text

Surveys/Sweepstakes

Telephone directories

Telephone “on-hold” messaging

Web pages

B. General Requirements Institutions must hold the appropriate internal and external approvals before announcing,

advertising, or otherwise conveying the beginning of classes, a date for opening, announcing

new programs, or soliciting students for enrollment.

The correct name of the institution, as it appears in the institution’s approval to operate, must

appear in all advertising.

The full legal name, address and phone number of the institution is included in advertising and

other promotional materials.

The institution clearly indicates that education is offered, not employment.

Only testimonials reflecting current practices, conditions or employment opportunities are used

in promotional materials.

Television and radio advertisements shall disclose if a person portraying a student is an actor by

indicating, “This is a dramatization.”

References to financial assistance availability shall include the phrase, “Student loans, grants,

and scholarships are available to those who qualify.”

The level of educational programs provided shall be clearly indicated.

For courses offered by distance education, the method of delivery must be described.

All media advertising and other informative or promotional materials shall truthfully represent

the characteristics of the institution.

Advertisements shall clearly note the availability of more extensive information in the catalog.

References to accreditation shall name the agency and shall be limited to accreditation currently

held by the institution.

The institution must be able to substantiate from its own records any advertised claims,

whether express or implied. Substantiation must exist prior to making the claim and records

must be maintained for the duration of the institution’s use of the claim.

Superiority claims are not considered appropriate, given that education is an intangible service.

For information available through the Internet the institution must provide access to licensure

and accreditation information on its first page.

Electronic links or contact information for each licensing and accrediting agency must be

included on the institution’s web site and in its catalog.


Advertising must avoid conveying any false, misleading or exaggerated impressions about the

institution, its outcomes, staff, or services.

Any description of the institution’s relationship with DVG should refer to the school as “a part of

DeVry Education Group.”

C. Prohibited Activities No institution or representative of an institution shall:

Make or cause to be made any statement that is in any manner untrue or misleading, either by

actual statement, omission, or intimation.

Engage in any false, deceptive, misleading, abusive, or unfair act in connection with any matter,

including the institution’s advertising and promotion, the recruitment of students, the offer or

sale of a program of instruction, course length, course credits, educational materials, training

and instruction, the collection of payments, or employment services.

Induce a person to enter into an agreement for a program of instruction by offering to

compensate that person to act as the institution’s representative in the solicitation, referral, or

recruitment of others for enrollment in the institution.

Advertise or indicate in any promotional material that programs of study are offered without

including the location where instruction is given.

Solicit students for enrollment by causing any advertisement to be published in “help wanted”

columns in any magazine, newspaper or other publication or use “blind” advertising that fails to

identify the institution.

Advertise that the institution or program is accredited unless it has been formally recognized as

meeting the standards established by the referenced accrediting agency.

Represent directly or by implication that there is a substantiated demand for persons

completing a program unless the institution can document such claims with valid data.

Directly or implicitly promise or guarantee employment.

Solicit student testimonials under actual or perceived duress.

Use financial aid as an inducement to enroll.

Use quantitative superlatives, such as biggest, largest, or highest [graduate employment] rate, in

its advertising unless the terms are qualified in the advertisement itself and the institution has,

in its possession, evidence to support its claim.

State or imply an endorsement by the U.S. Government, the President, or any other federal,

state or local government official.

Describe the institution as being a subsidiary or division of DeVry Education Group.

VI. Gainful Employment Disclosure Requirements Federal Program Integrity Gainful Employment rules require specific disclosures on the institution’s

website.


A. Student Consumer Information From the school’s main home page, viewers must have access to the Student Consumer Information

page containing the following information:

Annual Disclosure documents

Transfer Credit policy

Voter Registration information

Student diversity information

Institutional graduation rates

Graduate Employment rates

Plans to improve academic programs

Links to each program home page

State specific disclosures

Carrington’s Student Consumer Information page for campuses in AZ, ID, NM, NV, OR, TX, and WA can

be found at carrington.edu/cc/sci.

Carrington’s Student Consumer Information page for campuses in CA can be found at

carrington.edu/ccc/sci.

B. Program Home Pages Links to the Gainful Employment pages containing the following program specific disclosures are

required on each program’s home page:

On-time graduation rate of program completers

Graduate employment statistics

Classification of Instructional Program (CIP) code

Standard Occupational Classification (SOC) code(s)

Links to individual occupation listed on O*Net

Link to Occupational Outlook Handbook

Median loan debt for program completers

Program cost information

Program specific advertisements containing any detail more than the program name must include the

following disclosure:

For comprehensive consumer information, visit [insert direct link to program home page].

If an advertisement mentions details for multiple programs, in lieu of links to each program’s home

page, a link to the student consumer information page may be used.

Note: These requirements are applicable for web marketing vendors and their affiliates.


Programs Direct Links to Gainful Employment Pages

Criminal Justice carrington.edu/cc/cj

Dental Assisting carrington.edu/cc/da

Dental Hygiene carrington.edu/cc/dh

Health Studies carrington.edu/cc/hs

Massage Therapy carrington.edu/cc/mt

Medical Administrative Assistant carrington.edu/cc/maa

Medical Assisting carrington.edu/cc/ma

Medical Billing and Coding carrington.edu/cc/mbc

Medical Laboratory Technician carrington.edu/cc/mlt

Medical Radiography carrington.edu/cc/mr

Nursing Bridge carrington.edu/cc/nb

Pharmacy Technology carrington.edu/cc/pt

Physical Therapist Assistant carrington.edu/cc/pta

Physical Therapy Technology carrington.edu/cc/ptt

Practical Nursing carrington.edu/cc/pn

Registered Nursing carrington.edu/cc/rn

Registered Nursing LVN to RN carrington.edu/cc/lvn2rn

Respiratory Care carrington.edu/cc/rc

Surgical Technology carrington.edu/cc/st

Veterinary Assisting carrington.edu/cc/va

Veterinary Technology carrington.edu/cc/vt

Vocational Nursing carrington.edu/cc/vn

VII. Misrepresentation Federal Program Integrity regulations prohibit misrepresentation in any form and define the term

“misleading” to include any statement made in writing, visually, orally or through other means or

omissions that have the tendency or likelihood to deceive or confuse. Institutions are accountable for

the actions of their employees, representatives, agents and vendors. Areas at high risk for

misrepresentation include, but are not limited to:

Accreditation: status, type, agency; nature of accreditation

Articulation agreements with other institutions

Availability/frequency of program and course offerings

Costs: attendance, books, supplies, uniforms

Credential conferred upon program completion

Earnings potential: expected income of program graduates

Employability of graduates

Equipment: nature, age and availability

Facilities: description, size, location

Faculty: number, availability, qualifications, training and experience

Financial aid: program availability, accuracy of information, including scholarships


Graduate employment: career services, statistics, pre-conditions for employment in field

Licensing requirements: state requirements for licensure in specific occupations Program quality

Program requirements and policies; grounds for dismissal

Rights and responsibilities of students receiving financial assistance

Refund and withdrawal policies

Relationships with outside entities and impact on employment of graduates

Relationship with the U.S. Department of Education

Services and facilities available to students with disabilities

State approval to operate and confer degrees

Student loan debt

Student services: availability of services, tutoring

Testimonials

Transfer Credit policies

Written agreements with other institutions to provide institutional coursework, services

All colleagues and vendors are required to complete DVG Responsible Communications training to

ensure understanding of and compliance with federal regulations.

VIII. Accreditation The accreditation of an institution or program of study is considered a significant indication of quality

postsecondary education. To achieve accredited status, the institution must demonstrate a high level of

performance, integrity and quality that conforms to the standards set by its accrediting agencies. As a

result, accreditation becomes a factor in decisions made by a variety of entities including employers,

other colleges and universities, and students seeking higher education.

A. Carrington College Institutional Accreditation Carrington College is accredited by the Accrediting Commission for Community and Junior Colleges,

Western Association of Schools and Colleges (ACCJC/WASC). WASC is an institutional accrediting body

recognized by the Council for Higher Education Accreditation and the U.S. Department of Education. To

discuss Carrington College’s institutional accreditation, use the following rules:

Carrington College is the accredited entity

ACCJC/WASC accreditation is institutional, not programmatic

If accreditation is mentioned, the approved accreditation statement must be included

The accreditation information may appear in the copy or as a footnote

Approved ACCJC/WASC Accreditation Statement

Carrington College is accredited by the Accrediting Commission for Community and Junior Colleges,

Western Association of Schools and Colleges (ACCJC/WASC), 10 Commercial Blvd., Suite 204, Novato, CA


94949, (415) 506-0234, an institutional accrediting body recognized by the Council for Higher Education

Accreditation and the U.S. Department of Education. Additional information about accreditation,

including the filing of complaints against member institutions, can be found at www.accjc.org.

B. Carrington College Programmatic Accreditation In addition to institutional accreditation, some Carrington programs at specific campuses are

programmatically accredited. If programmatic accreditation information is included, it must be stated

exactly as required by the accreditor. For current programmatic accreditation statements, please refer

to the academic catalog at www.carrington.edu/carrington-college/catalog/.

Also, to ensure that printed materials are not outdated quickly, add the following clause at the end of

the statement:

Carrington reserves the right to update information as it becomes available. Information is current at the time of printing [“posting” if online]. For the most updated accreditation information, visit carrington.edu/accreditation.

Prohibited Accreditation Statement Examples

Accredited degrees

Degrees or programs are accredited by ACCJC/WASC

“Fully accredited” or “full accreditation”- these statements must not be used since partial accreditation is not

possible.

IX. Admissions Staff / Recruiter Titles It is a violation of Florida, Massachusetts, Minnesota, Nebraska and Oregon regulations for any agent

responsible for recruiting students to use the titles “counselor” or “advisor,” as these terms imply that

the individual recruiter is acting on the students’ behalf instead of the school’s. In these states, the title

Admissions Advisor is replaced with the title Admissions Representative.

Marketing and other communication materials used nationally or in FL, MA, MN, NE and OR should

contain the term Admissions Representative.

X. Advertising Approval or Authorization to Operate Institutions must hold the appropriate state and accrediting agency approval before announcing,

advertising, or otherwise conveying the beginning of classes, a date for opening, announcing new

programs, or soliciting students for enrollment.

http://www.accjc.org/

http://www.carrington.edu/carrington-college/catalog/


When approval to operate is received, a complete approval notice must appear in the institution’s

catalog. See the academic catalog at http://carrington.edu/carrington-college/catalog/ for current

approval statements.

XI. Required Approvals

A. Approved Assets Usage Before any materials are developed, colleagues must check to see if existing, pre-approved materials can

be utilized. Compliance must review and approve any Carrington College branded creative as well as

non-branded creative that links to or is associated with Carrington College prior to going live in the

marketplace.

B. Branded Search Terms Usage Use of the Carrington College brand is prohibited for all search marketing activity. Bidding on or having

advertising appearing under any Carrington College branded keywords (or combinations thereof) are

strictly prohibited, unless Carrington College provides authorization to do so in writing. This restriction

includes bidding on Carrington College branded terms as well as the use of any of these branded terms

in search headlines, ad copy, and display URLs in both paid search and organic search listings. Questions

should be directed to Todd Hanle at [email protected].

C. Marketing and Communications Approval Process Training and public presentations (including talking points) as well as other recruitment, student finance and public- or student-facing communications must be routed for approval by the appropriate institutional contact before being routed for regulatory review. Anytime a claim is made, a separate document that lists the substantiation must be provided (screenshot, URL, etc.) as a citations document along with the materials being submitted for approval.

Online vendors creating ads on behalf of Carrington College must route materials for approval to

Christian Caiazza, Manager, Affiliate Marketing at [email protected], who will seek approval from

DVG Regulatory Affairs. In addition, any materials that use a third-party trademark or copyrighted

materials must be reviewed and approved by DVG Legal. Please refer to the approval process below and

allow two business days for regulatory review.

Request Initiator

Content Review

Content Approval &

Maintenance

Brand Review

Brand tone Personality,

Style & Logos

Regulatory Review

Compliant & Responsible

Communications

http://carrington.edu/carrington-college/catalog/

mailto:[email protected].

mailto:[email protected]


The request initiator submits requests via inMotion (web-based marketing automation software

solution) or via email to the subject matter expert (SME) for content accuracy, who provides any

necessary edits.

Note: The request initiator is responsible for incorporating edits provided by each reviewer and

maintaining copies of approved materials for audit purposes.

The content review is the first step of the review process and is the responsibility of the appropriate

SME. The SME ensures the communication being routed does not duplicate an existing communication

and that there is value in adding this new communication. If the SME determines that the new

communication is necessary, they are charged with ensuring that content related to their area of

expertise is accurate.

Validation of statistics, facts and figures, and message clarification occurs at this stage of the review

process. All content, even if maintained/owned by other departments, must be validated prior to brand

review. Once all content has been approved by the appropriate SMEs, the communication can move to

Step 2 – Brand Review.

The brand review is the second step of the review process and is the responsibility of the marketing

team. Regardless of whom develops the communications (internally or externally), all items must be

reviewed to ensure adherence to brand guidelines. Use of logos, conformity with visual standards and

tonality of language are reviewed at this juncture and the brand reviewer may request content edits to

maintain integrity of communications. Once the communication is brand approved, the communication

will be routed to Step 3, Regulatory Review.

The regulatory review is the third step in the process and ensures the content complies with all

applicable regulations. The regulatory reviewer will rely upon the content review to confirm accuracy of

all content. The regulatory review is conducted mainly by the DVG Regulatory Compliance department.

Materials including information about student finance, scholarships, and military or veterans require an

additional level of review by the DVG Regulatory Affairs department. Each department‘s service level

agreement requires reviews to be completed within 2 business days of receipt. In some instances,

Regulatory Compliance will identify the need for legal review of materials, which could extend the

Brand Review

Request Initiator

Content Review

Regulatory Review


review timeline by 2 additional business days. Once these reviews are completed, the results of the

reviews will be routed back to the requestor via email.

Examples where the 3 step approval process is required:

Carrington branded document templates (Word, PowerPoint, etc.) from the brand guidelines

website where the user creates headlines, sub-heads and body copy on pre-approved

templates.

Generic templates from marketing library website where the user creates headlines, sub-heads,

and body copy.

Communications for events targeted to prospective students - Open House, lecture series,

programmatic information sessions, etc.

Student facing communications created by local staff regarding monthly events/activities to

learn more about student finance, FAFSA and scholarships.

Examples where the 3 step approval process is not necessary:

Student communications for general information (i.e., campus closing announcement due to

weather or other circumstances).

Student to student communications without Carrington logo/template – clubs, social activities,

etc.

Artwork or signage outlining facility layout (e.g., finding the bathroom).

D. Public Speaking and Presentations To ensure that DeVry Education Group’s reputation is maintained and to safeguard proprietary

information related to business operations, requests to speak or present at external, public events

must be approved before the presentation or event takes place.

This requirement applies to all colleagues, directors and officers of DeVry Education Group and its family

of institutions.

Colleagues are required to protect confidential information belonging to DeVry Education Group at all

times, including when speaking to external audiences on behalf of DeVry Education Group, or when

speaking as a subject matter expert employed by DeVry Education Group. Confidential information can

include ideas, organizational plans, student records, copyrighted material, trademarks and other

information gathered or generated as part of our operations and educational efforts. Material, non-

public information must not be provided to anyone outside of the organization. Information is non-

public if it has not been disseminated to the public generally (i.e., enrollment data, internal projections,

financial results, graduate employment statistics).

Colleagues must obtain permission from their manager before accepting an external speaking

engagement. Whether the engagement is based on their employment with DeVry Education Group or is

otherwise related to the work performed as a DVG colleague (i.e., commencement speaker, conference


presenter, discussion or panel member, etc.), permission is required. Upon receipt of manager approval

to participate, any materials used in association with the event must be submitted for compliance

approval. PowerPoint presentations should be placed on preapproved templates.

Following manager approval, the requestor submits the presentation, name and title of the presenter,

and a description of the event to the compliance mailbox:

[email protected]. All materials such as visual aids in PowerPoint

presentation slides, including speaker notes, must be submitted and approved.

Unless a colleague has been designated as a spokesperson for DeVry Education Group, the following

disclaimer must be included on the presentation slides and materials:

The views and opinions expressed in these materials are limited to that of the presenter(s)

and do not necessarily represent the views and opinions of DeVry Education Group.

Note: The request initiator is responsible for maintaining copies of approved materials for audit

purposes. Please allow a minimum of two business days for review by each person whose approval is

needed.

Examples where approval is necessary:

A DVG colleague is presenting information about a DVG institution to a local civic organization, or at a trade association conference.

o A location leader is presenting at a National Urban League event. o An academic dean is speaking at an APSCU conference. o A member of senior leadership is called to testify before a state or federal education

committee. o A community outreach director presents information on a specific program. o A CMO is asked to join a panel discussion at a conference

Examples where approval is not necessary:

A faculty member presents to an academic body on subject matter that applies ONLY to their discipline and does not contain information regarding the institution or broader DVG policies.

An accounting professor presents to his/her relevant professional association on teaching new accounting standards.

Commencement speech delivered by student

a) Payment for External Speaking Engagements

i. When Speaking on Behalf of Carrington: The speaking engagement must be done as a part of the

colleagues’ regular or expected duties with Carrington, or as part of a documented performance

plan. In this instance, payment (honorarium) for an external speaking engagement should not

exceed reimbursement or advanced payment for reasonable travel expenses (i.e. transportation,

lodging, meals, etc.). Such expenses must be consistent with the duration and nature of the



speaking engagement and cannot extend beyond that required to conduct the speaking

engagement. Any payment offered beyond covering reasonable travel expenses should be

directed to the DeVry Education Group Scholarship Fund or another charity that DeVry Education

Group supports.

ii. When Speaking as a Subject Matter Expert Employed by Carrington: The speaking

engagement must not be done as a part of the colleagues’ regular duties with Carrington, or as

part of a documented performance plan, but rather based on his/her expertise in a particular

subject matter related to the work performed as a Carrington colleague. In this instance, a

colleague must take personal/vacation time for the speaking engagement. Additionally, the

colleague must ensure that the time required for the speaking engagement does not interfere

with his/her duties as a Carrington colleague. Any compensation obtained when speaking as a

Subject Matter Expert is not governed by or subject to this policy.

E. Approval of Internal Mass Communications Internal mass communications from leadership regarding the institution, academic programs, and

student outcomes must be routed for compliance approval prior to distribution. The focus of the review

is to ensure consistent tone and messaging and appropriate subject matter. The process is expedited to

provide same-business-day response in most cases.

What internal communications need to be routed for approval?

Internal mass communications that meet all three of these requirements must be routed for approval:

1. The content is about the subjects specified below.

2. The sender is an institutional leader, as described below.

3. The recipients: the communication is going to a large group of colleagues as specified below.

Before hitting “send” on an email to a large group of people, ask yourself these three questions:

1. What is the content? The following subject matter is in scope for internal mass communication review:

The nature of educational programs (accreditation, state authorization, academic policy changes, program requirements, etc.).

Availability or eligibility for financial aid

Tuition and program costs

Student outcomes (graduation rates, retention rates, default rates, etc.)

Graduate employment rates or outcomes

Major organizational changes (campus or program closures, new programs)

Training for covered colleagues (admissions, student finance)

Directives given to covered colleagues about how to perform their jobs

Enrollment results

Student finance results


2. Who is the sender? These home office, regional, and location leaders’ communications are in scope for internal mass communication review:

Institutional presidents and their direct reports

Regional vice presidents and regional directors

Metro or campus leaders (metro president, campus president, executive director, deans (for medical and veterinary schools))

Note: messages sent “on behalf of” any covered sender must be routed for approval.

3. Who are the recipients? These recipient groups are in scope for internal mass communication review (generally more than 20 people):

a. Groups outside of the sender’s direct reports b. Entire campuses c. Entire functions (across campuses) d. Large Outlook group lists

What internal communications do not need to be routed for approval?

Communications to large groups that do not include content about the subject matter areas described above

Communications to individuals or small groups (e.g., the sender’s direct reports, or to select individuals on other teams)

Transmittal emails or other communications that do not contain new content about the subject matter areas described above, but merely quote or attach previously approved content without additional commentary

Privileged or otherwise confidential material (which should not be sent via mass communication in the first place)

How do I obtain approval for and send an internal mass communication?

Send the proposed communication to the compliance mailbox: [email protected]

The SLA for response is the same business day.

Messages submitted late in the day or after close of business will be addressed on the following business day.

The response will include an approved version of the message.

If further discussion is warranted, compliance will contact the sender directly.

When the approved internal mass communication is distributed, copy the Compliance mailbox:

[email protected]

XII. Advertising Approved Programs Advertising for a new program may be conducted only after the appropriate approving agencies

(jurisdiction approving agency, U.S. Department of Education, healthcare board, accrediting agency,




etc.) have granted approval for a new program or location and management has issued an “OK to

Recruit” notification.

Not all programs are approved to be offered at all locations, therefore advertising for a specific location

or group of locations within a metro may include only the programs approved for that location or metro.

Advertising for a specific program within a multiple-location metro implies that the program is approved

for all locations. If the program is not approved for each location included on the ad, this must be

disclosed. It is acceptable to disclose via footnote: Program availability varies by location.

Please refer to the academic catalog and licensing chart that indicates which programs are approved and

offered at each campus. The chart is updated and distributed periodically by the Accreditation, Licensing

and International Services department; contact [email protected], for copies or to be added to the

distribution list.

NOTE: It is the responsibility of those creating marketing and other communications to check with the

Licensing Department to ensure that the appropriate approval is in place prior to routing the item for

Compliance approval.

A. Advertising for Online Programs Advertising for online programs is dependent upon online program approval status. When developing

advertisements that refer to online programs, consult the Online Recruitment heat map to ensure

appropriate approvals are in place. The heat map is distributed periodically. Please contact

Accreditation, Licensing and International Services at [email protected] for copies or to be added to

the distribution list.

Note: An institution shall not advertise, or indicate in promotional material, without including the fact that the educational programs are delivered by means of distance education if the educational programs are so delivered.

B. Placement of Advertising State regulations prohibit institutions of higher education from advertising in the Help Wanted column

in any magazine, newspaper, or other publication, including websites. “Blind” advertising that fails to

identify the institution is also prohibited.

Advertising on job-search websites, such as monster.com or careerbuilder.com, is allowed as long as the

ad copy and placement on the site make it clear that education is being offered, not employment. Ads

should be in education related areas or within the banner sections of the website. Ads should never

appear intermingled within job postings.

C. Program Options Some programs have options students may choose from to focus their coursework on a particular area

of interest. The naming conventions for these choices are driven by credit hours in the options and state




regulations, and vary by location. Please refer to the academic catalog to ensure that the correct

terminology is used for each program option and location.

D. Degree Nomenclature Degree nomenclature is also governed by state regulations and varies by program and location. Because

of the variables, program award levels are referred to in generic terms such as certificate or associate

degree in all advertising. Please refer to the academic catalog for program/location specific variables.

XIII. Advertising in Languages other than English Marketing and communications created in other languages are permitted if the following requirements

are met:

English version is routed for Compliance approval.

A third party, not involved in the development of the piece, must provide the following

acknowledgement of accuracy:

The [insert language]-language version of this piece has been developed by [insert name

of individual/ agency] and contains the same information as the original English text.

Facts and figures have not been modified and are accurate, to the best of our

knowledge.

This acknowledgement can be submitted via email. If a hard copy is submitted it must be signed

and dated by the reputable person or entity. The marketing or public relations manager/director

must retain a copy of the acknowledgement along with the related approval documents for

auditing purposes.

The advertisement must include the following statement:

“The translation is provided as a service for [insert language]-speaking individuals and is

for reference only. Should any discrepancies exist between the [insert language] and an

English version, the English version prevails. Programs and services are provided only in

English.”

If the equivalent words or meaning are not available when translated, back translation is

required and must be approved by Compliance.

XIV. Logo Usage and Naming Conventions

The Carrington College logo may only be used in jurisdictions where Carrington College is approved

to operate. Logo guidelines for Carrington College and downloadable logos are available at

brand.carrington.edu/. Contact Todd Hanle at [email protected] for additional logo guidance.

http://brand.carrington.edu/



XV. Use of Copyrighted Material Copyright notices should be used on all marketing and communications to protect any materials in

which DVG owns the copyright. DVG automatically owns the copyright in works created by colleagues in

the scope of their employment, such as course handouts, shells, course curricula in all formats,

websites, etc. and in works made for hire by independent contractors. If you have any questions about

copyright ownership, check with DVG Legal department.

An acceptable copyright notice includes the word “copyright” or ©, the date of first publication

(the date that the work was first distributed to the public or offered for sale), and the name of

the copyright owner. It may be followed by additional language, such as, “all rights reserved.” If

the work contains material created over multiple years, for example, a website, the years of first

publication may be noticed as “2006-2016.” The following example is an acceptable copyright

notice:

©2016 Carrington College. All rights reserved.

The copyright notice should be placed at the bottom of the first page or on the title page, on the

CD or DVD containing copyrighted work, at the bottom of website pages, or at the beginning of

presentations being played from CDs/DVDs. For advertisement materials, it should be placed on

the bottom or side of the printed materials, or on the countdown clock for TV commercials.

For resources on how to properly mark copyrighted materials owned by the various DVG organizations,

and for how to properly use copyrighted materials owned by third-parties, please see the guidelines on

the DVG Legal page of the DVG Commons. If you have questions about copyrights, please contact

Jennifer Glombicki in the DVG home office Legal department at [email protected].

XVI. Use of Trademarks Proper use of Trademarks is also required, whether they are marks owned by third-parties, or marks

owned by DVG organizations. Guidance for the use of trademarks is provided on the Legal page of the

DVG Commons. Questions should be addressed to Jennifer Glombicki in the DVG home office Legal

department at [email protected].



XXII. Using Military, Veterans’ Affairs or GI Bill® References in

Advertisements or Student-Facing Materials All messaging related to financial aid (including scholarships, grants, etc.) must be approved by

Regulatory Affairs prior to use.

All marketing messaging – whether developed internally or by a vendor – must be approved by Regulatory Affairs prior to use.

Use of the term “GI Bill” is restricted under federal trademark law. The following restrictions apply to preparation of any materials using the term “GI Bill”:

o Only institutions eligible to receive VA education benefits; state approving agencies; and recognized Veterans service organizations are permitted to use the term “GI Bill.” No other third-parties may use the term.

o Institutions permitted to use “GI Bill” are prohibited from using the term in any manner that directly or indirectly implies a relationship or affiliation with, or endorsement by, the U.S. Department of Veterans Affairs.

o Use of the term “GI Bill” must include the registered trademark symbol (®) at the upper right corner of the trademark.

o The trademark attribution notice must also be prominently visible: "GI Bill® is a registered trademark of the U.S. Department of Veterans Affairs (VA). More information about education benefits offered by the VA is available at the official U.S. government website: www.benefits.va.gov/gibill.”

o The registered symbol is not required every time the mark appears in a single document or on a webpage; however, it must appear in the most prominent place at first usage, such as in a title or header/sidebar, as well as in the first use in the text, on all individual documents or webpages.

o Additional restrictions will be vetted during the regulatory compliance review of the materials.

XVIII. State Specific Requirements Arkansas – A school shall not use the words “free” or “guarantee” for advertising or sales promotion

purposes.

Arizona – Restricts use of the words “free” and “guarantee” in print materials and advertisements.

Consult Regulatory Compliance for guidance.

Florida – An institution shall not use the word “free” or its synonyms in reference to any equipment,

tuition, books, or other items in conjunction with recruiting or advertising.

Georgia – The institution does not use the word “free” to describe any item or service included as part

of the school’s programs, placement services, preliminary testing or interviews.

Illinois – Use of salary information or dollar figures that are indicative of earning potential for graduates

is prohibited.

http://www.benefits.va.gov/gibill


Louisiana – The word “free” shall not be used for items or services provided “without additional

charge,” but only when there is unconditional access without cost or obligation of any type. Almost

everything a school offers to its students is normally paid for, at least in part, by students.

Massachusetts – Representing a commodity or service as “free” when in fact such commodity or service

is regularly included as part of the course of instruction or service is an unfair and deceptive trade

practice.

Oklahoma- Local ads placed in Oklahoma must contain the school name, street address, and phone

number.

Utah – An institution does not use such words as “guarantee” or “free” in either its printed publications,

television nor radio copy, nor person-to-person solicitations unless such is a fact.

XIX. Enrollment Promotions The use of fee waivers is prohibited in a number of jurisdictions in which Carrington College operates.

States that allow fee waivers

Colorado Louisiana Nevada Vermont

Delaware Maine New Jersey Virgin Islands

Guam Maryland North Carolina Virginia

Hawaii Massachusetts North Dakota Washington state

Idaho Michigan Pennsylvania Washington D.C.

Illinois Minnesota Puerto Rico Wisconsin

Indiana Mississippi Rhode Island Wyoming

Iowa Missouri South Carolina

Kansas Montana South Dakota

Kentucky Nebraska Texas

States that DO NOT allow fee waivers

Alabama Connecticut New York Utah

Alaska Florida Ohio West Virginia

Arizona Georgia Oklahoma


States that allow fee waivers

Arkansas New Hampshire Oregon

California New Mexico Tennessee

While some states restrict the waiver of fees, other promotions may be offered.

Note:

Student Referral Promotion gifts are prohibited in all states.

Consult DVG Regulatory Compliance for guidance specific to new initiatives.

States that allow other enrollment promotions

Alabama1 Kentucky New Hampshire1 Vermont

Colorado Louisiana2 New Jersey Virgin Islands

Connecticut1 Maine North Carolina Virginia

Delaware Maryland North Dakota Washington state

Georgia2 Massachusetts4 Oregon5 Washington D.C.

Guam Michigan Pennsylvania West Virginia8

Hawaii Minnesota Puerto Rico Wisconsin

Idaho Mississippi Rhode Island Wyoming

Illinois Missouri South Carolina6

Indiana3 Montana South Dakota

Iowa Nebraska Texas

Kansas3 Nevada Utah7

States that DO NOT allow other enrollment promotions

Alaska California New York Tennessee

Arizona Florida Ohio

Arkansas New Mexico Oklahoma


1 Tuition and fees must be uniformly applied to all students within the school and class. Fee waivers are not

permitted unless all students within the school and class receive a waiver.

2 The institution must not deviate from the advertised cost of programs offered.

3 Scholarships must be bona fide reductions in tuition and issued under specific, published criteria. See Regulatory

Requirements for Scholarships posted in the DVG Commons for additional details at DVG Commons > Regulatory

Policies > DVG Regulatory Requirements for Scholarships.

4 Representing an offer to be limited as to time or otherwise when it is in fact the school’s regular offer is an unfair

and deceptive trade practice.

5 Outside the regular student financial aid process, there shall be no discounting of tuition as an incentive to enroll.

6 Total tuition for any specific program shall be the same for all persons enrolled at the same time.

7 An institution shall not use loans, scholarships, discounts, or other such enrollment inducements, where such

result in unfair or discriminatory practices.

8 Schools shall not advertise any tuition, fees, or charges in amounts other than those currently on file with the state

or advertise them without showing the total costs.

XX. Scholarships A scholarship is an award of financial aid for a student to further his/her education that does not have to

be repaid. Scholarships are awarded based upon various criteria, which usually reflect the values and

purposes of the donor or founder of the award.

Scholarships may be implemented when there are specific criteria for student eligibility and selection

procedures precisely disclosed within an institution’s policy. All students within the enrollment period

that the scholarship is offered must be eligible to apply under the same circumstance.

The institution must maintain verifiable records including detailed and complete data when students are

granted a scholarship. Records kept on file at the institution for review must include copies of

applications, selection committee meeting notes, and copies of scholarship award notices.

Scholarships may not be offered unless they are bona fide awards issued under specific criteria

published in the institution’s policies. Promotion of scholarships is considered a monetary incentive to

enroll, which is prohibited in a number of states. See section XIX. Enrollment Promotions for additional

guidance on the promotion of scholarships.

For full regulatory guidance on scholarships, go to: DVG Commons> Regulatory Policies > DVG

Regulatory Requirements for Scholarships.


XXI. Using References to Financial Aid, Scholarships, and Grants in

Advertisements Any messaging related to financial aid (including scholarships, grants, etc.) must be approved

prior to use. Please submit all requests to: [email protected].

approval from DVG Regulatory Affairs.

Financial aid information must be accurate and verified by DVG Regulatory Affairs.

References to financial assistance availability shall include the phrase, “Student loans, grants,

and scholarships are available to those who qualify.”

References to federal financial aid programs may not be combined with information about state

grants or institutional aid.

Ads implying that a prospective student can determine their financial aid eligibility must include

the tools to determine eligibility.

o If this information is not immediately available, a Regulatory Affairs-approved email

must be sent with the pertinent information within minutes of the prospective student

requesting eligibility information.

o The inquiry form for the original ad must notify the student that the email will be sent.

Financial aid references must be transparent and may not give an impression that the

information is presented by a government entity.

References to financial aid programs may not imply that all program costs can be covered with

financial aid; that financial aid does not include student loans; or that there may be no student

payment obligation.

Marketing materials with scholarship and/or grant messaging should have twice as much content related to the university and its features than the scholarship/grant programs described. This is commonly known as the “2/3rd 1/3rd rule”.

References to “FAFSA” must include the registered trademark symbol (®) at the upper right corner of the trademark, and must include the following statement on the same page that FAFSA is mentioned:

“FAFSA® is a registered trademark of the U.S. Department of Education.”

If there is more than one term on that particular page, you can simply combine them in the statement.

“FAFSA® and NSLDS® are registered trademarks of the U.S. Department of Education.”

XXIII. Sweepstakes and Contests Sweepstakes and contests may be held for marketing/promotional purposes if the following legal

disclosure requirements are met. These disclosures may appear at the bottom of the page in smaller

print, as long as it is legible.

A. Sweepstakes Use the following language when the value of a sweepstakes prize is $100 or more:


No purchase necessary to enter. Limit one entry per person. Must be 18 or older and a legal resident

of the United States to win. Void where prohibited. Odds of winning depend on number of entrants.

Winning entries will be chosen at random from all entries timely received; decision of the Sponsor is

final. Entries must be received by [insert date]. To review the complete Official Rules, go to [insert

link to rules or otherwise indicate where entrants can find rules]. For additional information or a list

of winners, contact [insert name].

All requests for sweepstakes must be submitted to DVG Legal for review.

B. Contests Use the following disclosure when the value of a contest prize is $100 or more:

No purchase necessary to enter. Limit one entry per person. Must be 18 or older and a legal resident

of the United States to win. Void where prohibited. Winning entries will be judged and selected from

all entries timely received; decision of the Judge(s) is final. Entries must be received by [insert date].

To review the complete Official Rules, go to [insert link to rules or otherwise indicate where entrants

can find rules]. For additional information or a list of winners, contact [insert name].

All requests for contests must be submitted to DVG Legal for review.

C. Raffles Do not refer to promotions as raffles (purchasing a chance to win a prize). In most jurisdictions, raffles

are illegal.

D. Trademarks If promotional materials describe a trademarked prize, the third-party trademark is required. For

example:

iPod is a registered trademark of Apple, Inc. All rights reserved. Apple, Inc. does not endorse,

sponsor, or support this <<Sweepstakes/Contest – use correct term>> in any manner.

When a third-party’s trademark is used in the text of Official Rules, it must be properly marked - iPod®,

since this mark is registered. An unregistered mark must be labeled accordingly – MarkTM or MarkSM.

See the DVG Legal page in the DVG Commons for additional information on the use of third-party

trademarks. For assistance to determine whether a mark is registered, contact Jennifer Glombicki in the

DVG Legal department via email [email protected].

E. Official Rules Official rules must be published in connection with Sweepstakes and Contests. Guidelines and

templates for the respective Official Rules are located on the DVG Legal page in the DVG Commons.

Signature lines and opt-in disclaimers are not required on electronic landing pages, business reply cards

or other physical marketing pieces. Simply having a prospective student complete these forms



establishes a sound business relationship by which admissions representatives can legally call regarding

degree programs. This rule applies in all markets and in all states.

F. Contacting Sweepstakes and Contest Entrants To contact sweepstakes or contest entrants by phone, follow these requirements to ensure compliance

with various telemarketing regulations:

Sweepstakes and contest entry forms must include an “opt-in” check box.

Opt-in language must be included on all forms. It must clearly state that the entrant will be

contacted via phone by a Carrington representative. Use the following language:

“Yes, please have someone call or email me about Carrington certificate and/or degree

programs.”

Modifications to this language are permissible, but must state that the school will contact the entrant by

phone.

Contest and sweepstakes entries may not be taken over the phone.

If an entrant does not wish to be contacted by phone, direct mail can be used to contact.

Always check with Compliance before implementing any sweepstakes or contest.

XXV. Terms and Phrases to Avoid Terms and Phrases to AVOID USE INSTEAD

Get a job Prepare for a career in [insert field of

study]

Start your career Start preparing for your career or

Prepare for your career

Job placement

Career placement

Placement rate

Career assistance

Graduate employment services

Employment rate

Fully accredited [Insert school name] is accredited

Get a degree

Degrees

With a degree

Earn a degree

Degree programs

By earning a degree

Counselor/counseling and Advisor/advising

“Counselor” is a protected title. Persons must hold credential as a

licensed counselor to use this title in some states.

Representative/Specialist


Terms and Phrases to AVOID USE INSTEAD

It is a violation of certain state regulations for any agent

responsible for recruiting students to use the titles “counselor” or

“advisor,” as these terms imply that the individual recruiter is

acting on the students’ behalf instead of the school’s.

Discount/ reduced rate/ reduction Group-specific tuition rates (military,

alumni, corporate partner, etc.)

State-of-the-art

Cutting-edge

Highly advanced or high tech

Advanced technology

Latest technology Leading trends in technology

Will

The term “will” implies a guarantee. Remember that a student’s

ultimate degree of success depends on factors that are not under

the direct control of the institution, therefore we provide high

quality education but we do not promise that an individual student

will succeed nor guarantee that a career search will be successful.

Can or May

Designed to prepare

One-on-one Individual attention

Act Now

Time is Running Out

Hurry!!!!

These terms imply a false sense of urgency.

State when the offer expires

XXVI. Superiority Claims, Substantiation, Footnote Disclosures,

Testimonials/Endorsements

A. Claims A claim is a specific representation made in an advertisement about the institution or service. All

reasonable interpretations of an advertisement should be substantiated. Keep in mind that the

message the ad is intended to convey and how a consumer might interpret the ad could differ.

Superiority claims are not appropriate, given that education is an intangible service. Subjective

superlatives cannot be satisfactorily documented and should not be used. These include but are not

limited to: best, greatest, largest, newest, longest, most successful.

B. Claim Substantiation Substantiation refers to underlying data or evidence to prove advertising claims. Objective statements

or claims that tend to imply superiority may be used only when truthful and when measured by

independent experts in accordance with generally understood and acceptable standards.


Good practice is to disclose the quantity and type of substantiation upon which the claim relies as part

of the main advertising claim. If not practical, place the disclosure in a clear and conspicuous footnote.

Remember that disclaimers are only effective at reducing risk if they are designed to be readable. If a

court or state AG or enforcement agency believes that the page has been arranged to discourage

reading the disclaimer, then we don’t get “credit” for including it – we land in the same position as if we

had no disclaimer at all.

The institution must be able to substantiate from its own records any advertised claims, whether

express or implied. “Express claims” refer to those claims that are made directly in the advertising.

“Implied claims” refer to those claims which, while not directly stated in the advertising, a reasonable

consumer would interpret the advertising as making.

Supportive evidence and the underlying data to substantiate claims must be available for review for the

duration of time the claim is advertised and the subsequent document retention period. The FTC

requires advertisers to have a reasonable basis for making a claim before the claim is made. Evidence to

support each claim must be submitted for compliance review with the draft advertisement.

When routing materials for compliance approval, attach a separate document that includes the

following:

The claim being made

Screenshot(s) of each claim being made

Highlighted information that substantiates the claim within the source. When possible, please select a source that doesn’t require a subscription to the site such as creating a

login and password.

C. Footnote Disclosures Disclosures made in footnotes must be clear and conspicuous. Disclosures help limit the way a

consumer interprets an advertisement by explaining the substantiation used or the limitations on a

claim. The information contained in a footnote should explain the information that is contained in other

parts of an advertisement – it should not contradict it.

A disclosure modifies a claim -- it does not completely alter the claim. For example, if the main claim

states that there are no restrictions on an offer, then a footnote that disclosed restrictions on an offer

would likely be found to be ineffective because it contradicts the main claim.

The location and prominence of a footnote should be readily noticeable by consumers. The text

contained in the footnote should be of a size and contrast that are easy to read and understand.

D. Testimonials and Endorsements Testimonials and endorsements encompass both statements made by students and statements made by

experts, or organizations, about the institution’s programs.


Testimonials may not be solicited under duress or in a situation in which duress may be implied, nor may

the institution require students to make endorsements or testimonials to participate in a program.

Marketing plans to solicit student testimonials must be reviewed with regulatory compliance staff prior

to launch and specific documentation requirements must be followed.

The individual making the testimonial and their affiliation with the university, if any, should be clearly

identified. Student testimonials should include the student’s year in school and program or college.

Alumni testimonials should include the year of graduation and the name of the program completed.

When using a testimonial or endorsement, any ‘material connections’ the institution provides to the

endorser must be disclosed (e.g. free product, payment, opportunity to be on television, etc.). One

exception is the use of a celebrity or sports star to endorse a service. Consumers expect these figures to

be paid to offer their endorsement of the institution, so an explicit disclosure may not be needed.

Testimonials claiming specific results usually will be interpreted to mean that the endorser’s experience

reflects what others can also expect. Statements like “Results not typical” or “Individual results may

vary” won’t change that interpretation. That leaves advertisers with two choices:

1. Have adequate proof to back up the claim that the results shown in the ad are typical, or 2. Clearly and conspicuously disclose the generally expected performance in the circumstances

shown in the ad

For example don’t create a national advertising campaign centered on a professor meeting a

student at their place of work for a tutoring session. The generally expected performance is for

instructors to be available during office hours or via email within a certain agreed upon SLA

Also when using an example of a professor babysitting a student’s child during class the

marketing material should clearly show that the generally expected performance is that children

are not allowed in class.

Testimonials and endorsements made by third parties who are compensated or receive free products

and/or services must be disclosed both by the institution and the blogger. The institution is responsible

for ensuring the compensated blogger makes the necessary disclosure.

All colleagues and vendors are required to complete compliance training to ensure understanding of and

compliance with state and federal regulations, Carrington College Marketing and Communications

Policy, advertising and responsible communication. For additional information on claims, substantiation,

footnote disclosures and testimonials/endorsements, see the DVG Legal page in the DVG Commons or

contact Jennifer Glombicki at [email protected].



XXVII. Do Not Contact and CAN-SPAM Compliance Anyone making recruitment-related phone calls or sending email on behalf of the institution must

comply with DeVry Education Group’s Do Not Contact (DNC) policy.

The DNC policy prohibits calls to persons registered on the Federal DNC Registry, State DNC lists or the

Internal DNC lists maintained by DeVry unless there is an existing business relationship (EBR) with the

consumer. EBR exemptions override national or state DNC listings and permit a callable window

depending on the applicable state or federal rule. However, presence on an internal DNC list does not

override an EBR.

Failure to comply with Do Not Contact legislation can have serious consequences. Violations can result

in extensive fines and public relations damage.

CAN-SPAM (Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003) establishes

requirements for senders of commercial email. An email is considered commercial when all or part

contains advertising or marketing material. The act provides consumers the right to ask that DeVry

Education Group, or its educational institutions to stop emailing them.

Email campaigns must comply with CAN-SPAM regulations. Marketing messages must be routed for

approval to ensure that the required CAN-SPAM compliance elements are present:

a. Accurate header information b. Non-deceptive subject line that includes at least part of the institution’s name c. Clear identification of the commercial purpose of the email d. Physical address of the sender e. An email opt-out mechanism that is active for 30 days f. Opt-out suppression within 10 days g. Other state-specific requirements as applicable

Persons placing recruitment calls or sending emails are required to read and understand the DeVry

Education Group Do Not Contact Policy and complete Do Not Contact training. The Do Not Contact

training is required for new hires, an annual requirement for current employees, and available on

request by contacting the Ethics and Compliance Services (“ECS”) department at

[email protected].

Questions related to Do Not Contact or CAN-SPAM compliance should be directed to

[email protected].

XXVIII. Surveys Regulatory Compliance and Consumer Insights approval is required for most surveys fielded to

prospective students, rejected applicants, students and alumni. Branded surveys of the general public

may also require approval prior to fielding. Review the Surveying Operating Procedures posted in the




DVG Commons for full regulatory guidance and limited exceptions to the approval process. The

procedures are found at: DVG Commons > Regulatory Policies > Surveying Operation Procedures.

XXIX. Web Marketing and Vendor Compliance All ads, banners, landing pages, school search listings and descriptions must be routed for compliance

approval before going live on public websites. This includes all third-party, sub-contracted vendors

that may be used by primary web marketing companies. Approved content may not be altered after

compliance approval has been granted.

Do not repeat or copy program or policy information from main institution websites; link to the

information so that as changes are made, the correct copy is always displayed.

Websites, landing pages and inquiry forms developed for Carrington College must only reference the

programs and policies of that institution. For example, it is not appropriate to include information about

another DVG institution on a Carrington College website, landing page, or inquiry form.

Vendors are prohibited from generating inquiries or referrals through means that, in Carrington College

or DVG’s judgment, could be reasonably interpreted as coercive, inappropriately incentivized,

misleading, invalid, improperly automated, or fraudulent, including through the use of:

a) Adware generated traffic. Including, but not limited to, advertisements that appear on Federal,

State, or local government websites and advertisements that appear on any Carrington College

website or form;

b) blind links (where users are misled and are unaware they will be navigating to Carrington

College’s website or inquiry forms);

c) requiring a consumer to click on a link or complete an inquiry generation form in order to obtain

some inducement or other benefit or result or to perform another function, such as leaving a

webpage or closing a window;

d) permitting a vendor, or its employees, contractors or agents, to click on a link or fill out an

inquiry generation form, unless such a process is a necessity for call-center based inquiry

generation efforts;

e) using bots, macro programs, Internet agents or other automated means to generate inquiries,

impressions or clicks; or

f) technology that disallows access to properties that possess branded Carrington College content.

Such technology could be defined as but is not limited to blocking of IP addresses, Robots.txt,

and/or Firewalls.

For general questions, requirements and concerns regarding the Carrington College website please

email: [email protected].


XXX. Speaking Up Carrington College is committed to encouraging and promoting a culture of compliance with the law and

organizational policy, and to upholding the highest standards of professional conduct, everywhere we

operate. If you are ever in doubt as to the right course of action, or if you have observed a violation of

this policy, you are encouraged to consult with your manager. Many matters can be resolved by speaking

directly with your manager.

However, if you are not comfortable bringing your question or concern to your manager, or if you have

done so already and have not received a satisfactory answer, you have several other options. You may

contact:

Another manager in your line of management

Your DVG VP, Audit, Ethics & Compliance Services

Your DVG Legal representative

Your Human Resources business partner

Alternatively, you may report your question or concern through the Ethics and Compliance Services

HelpLine or HelpSite. Both the HelpLine and HelpSite are available twenty-four hours a day, seven days a

week, every day of the year. When you contact the HelpLine or HelpSite, you have the option of

remaining anonymous. You also have the option of submitting your question or concern in your native

language. For more information about the HelpLine or HelpSite, please visit:

www.speakupdevry.ethicspoint.com.

DeVry Education Group will not tolerate retaliation against a colleague who, in good faith, asks

questions, raises concerns, or reports suspected wrongdoing. At the same time, DVG will not tolerate

concerns or allegations that are raised in bad faith. Colleagues who engage in retaliation or bad-faith

reporting are subject to disciplinary action, up to, and including, termination of employment.

NOTE: This policy is updated and redistributed as necessary. Contact Jaime Butler, Senior Regulatory

Compliance Analyst, at [email protected] with questions or concerns.

http://www.speakupdevry.ethicspoint.com/

http://www.speakingupatdevry.ethicspoint.com./

http://www.speakingupatdevry.ethicspoint.com./


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