OUR APPROACH

1. Truthfulness and Transparency. Truthfulness and transparency in education abroad policies may include, but are not limited to, issues such as:
   • Appropriate disclosure of the decision-making processes that guide practices, policies and education abroad operations;
   • Openness with respect to program development; partnership agreements; criteria for program approval and recommendation; eligibility and permission to study abroad; applications; admission; fees; financial aid; refund policies, academic, grading, and credit policies; applicable codes of conduct; petition and appeals processes; and grievance procedures;
   • Clear, accurate and consistent communication appropriate to relevant constituencies;
     • Marketing, advertising and promotional materials should:
     • Provide relevant program information and materials that are current, accurate and complete; especially key information such as program price, what the price includes or excludes, program dates, and the availability of academic courses or special opportunities described in the promotional materials;
     • Convey a properly balanced and accurate description of the program and its activities, opportunities, challenges and the availability of or lack of support structures to avoid creating unrealistic expectations;
     • Depict the host culture accurately and in a manner that avoids either unnecessarily negative or unrealistically positive portrayals;
     • Avoid unfair and misleading statements;
     • Focus on the program’s strengths, avoiding disparaging or misleading statements about the programs of others.
2. Responsibility to Students. Program quality, academic integrity, and student health and safety are all enhanced when program providers and academic institutions take steps such as the following:
   • Prepare students to make well-informed decisions and to participate beneficially in education abroad programs;
   • Exercise reasonable cost control measures and fair and open billing procedures;
   • Provide appropriate support for students prior to, throughout and following their education abroad experience;
   • Inform students that in addition to rights they have individual responsibilities including a duty to inform themselves of institutional and program expectations, conditions or restrictions concerning their conduct;
   • Make students aware of and direct them to written codes of student conduct early in the program selection or application process;
   • Inform students about the level of in-country support, if any, that will or will not be available;
   • Protect students’ rights and privacy as required by legal and ethical considerations and explain any limitations on confidentiality;
   • Assist students with special needs to understand what reasonable accommodations can be provided and, where appropriate, suggest reasonable alternatives;
   • Clearly communicate grievance procedures, make them readily accessible to students and external constituencies, and provide access to an avenue outside of the education abroad office and apart from the program in which they are participating;
   • Inform students about program assessment and evaluation processes, how to participate, how the data will be used, provide them the option of participating anonymously or provide them opportunity of opting out of the evaluation process;
   • Make students aware that:
     • They are subject to local laws and should expect no immunity or other special treatment by local authorities;
     • There may be limitations on their rights while abroad and that some rights protected under their home country law may not be recognized or protected;
     • They have individual responsibility to inform themselves about the limitations of rights and the impact of foreign laws or restrictions and to conduct themselves accordingly;
     • They have the responsibility to undertake reasonable efforts to familiarize themselves with the host country including its language and to be sensitive to and respectful of host society and community cultural norms.
   • Proactively assist students in identifying, applying for and obtaining financial aid, taking care that:
     • Policies and practices regarding the awarding or transfer of student financial aid for study abroad are communicated clearly and readily accessible;
     • Employees involved in marketing, recruitment, and administration of education
     • Financial aid and scholarships awarded by education abroad programs are applied in a manner beneficial to the student.
3. Relationships with Host Societies. Institutions and provider organizations should be aware of and sensitive to host community cultural norms and expectations in program planning and execution, including:
   • An awareness of and efforts to minimize any negative impact on the host society and community;
   • Orientation of participants that imparts information needed to avoid conduct that could have a negative impact on themselves, the host country, or the image of their home country. This may include:
     • Local laws and the cultural setting, such as formal and informal differences in the practice of speech, religion, political participation, gender relations, etc.;
     • Potential economic, political, and personal risks faced by institutions and persons in countries where international educational cooperation may create controversy or conflict.
   • The creation and enforcement of a code of conduct that appropriately consider host locale societal and cultural norms and environmental conditions;
   • Reciprocal opportunities that benefit the sending and receiving country’s educational institutions, students and broader communities should be explored;
   • Establishing and maintaining policies and relationships that support environmentally responsible program management, including but not limited to:
     • Fostering an awareness of and minimizing harmful individual and program-related environmental and social impact;
     • Considering and preparing for the environmental, economic, and social consequences of the presence (or departure) of the program, in both program design and management.
   • Soliciting community input and utilizing local experts, resources, goods and services, when appropriate.
   • Supporting local community assets such as schools, libraries, health programs, and conservation projects, when feasible.
4. Best Practices. Identifying and adopting relevant best professional practices such as the following can assist organizations and institutions in enhancing and improving their education abroad activities and processes:
   • Undertaking reasonable steps to be informed of and to comply with applicable home and host country law;
   • Avoiding arrangements that violate laws or accepted business practices of the home or host country in programming and execution;
   • Establishing and maintaining reasonably safe conditions for living, working and studying abroad and informing participants of conditions beyond the institution’s or organization’s control;
   • Maintaining clear environmental standards;
   • Making available, as appropriate, up-to-date written protocols, policies, procedures and job descriptions;
   • Exercising due diligence in cost control and adopting clear and responsible billing procedures for program participants;
   • Establishing and making known protocols concerning records creation (including electronic formats), as well as what information will be collected and recorded, how and by whom that information may be used, how long it will be kept, and how it will be disposed;
   • Maintaining sufficient financial resources to meet the obligations and exigencies of each program and making reasonable provisions for handling unanticipated obligations;
   • Enforcing guidelines on research by participants consistent with home institutional protocols for conducting research, including human subject research, as well as any additional requirements of the host country;
   • Taking, but not limited to, the following steps on behalf of employees:
     • Adopting and following hiring policies that conform with the context of the laws of the home and host societies in a manner designed to assure a fair and qualified pool of applicants;
     • Providing employees and education abroad program directors with appropriate training relevant to their responsibilities;
     • Providing a safe working environment;
     • Fostering an environment of respect for all employees;
     • Being sensitive to diversity issues, needs, and responsibilities;
     • Not tolerating sexual harassment or other harassment of employees
     • Providing employees and participants access to a process for reporting a grievance or perceived internal wrongdoing without fear of reprisal;
     • Maintaining and making available a clear, written non-discrimination policy;
     • Not unlawfully discriminating in employment or admissions on the basis of race, color, religion, sex, sexual orientation, marital status, national origin, age, ancestry, familial status, or on any other unlawful basis.
       • Host society laws and community attitudes on discrimination should be taken into account in program planning and site selection;
       • Participants should be advised where home and host country legal, societal or cultural expectations differ in ways that could threaten their well-being or safety.
     • Supporting, protecting and insuring against liability for employees acting in good faith in the execution of their responsibilities.
   • Periodically reassessing lists of approved programs, where they exist, in light of new information and institutional evolving priorities.
   • Managing provider – institution relations according to the following principles:
     • Institutions and/or provider organizations that desire to establish a relationship or to work together should commit to an open and positive working relationship respectful of one another’s preferences, practices, and policies;
     • Formal program site visits are important to program oversight and improvement but require transparency, good faith and prior communication and agreement on the specific purpose and goals of the visit, its duration and schedule and any cost-sharing between the program and the visitor;
     • If there is to be a formal evaluation, it should be conducted according to predetermined criteria which may vary depending on the length, intensity, and purpose of the visit;
     • See Appendix A for more specific guidance.
5. Conflicts of Interest. A potential conflict of interest exists when personal or institutional interests, whether financial or non-financial, may be seen as competing with the best interests of the students or inconsistent with best professional practices.
   • Institutions and provider organizations should have a Conflict of Interest policy and procedures for addressing conflicts of interest or their appearance;
   • A Conflict of Interest policy should effectively manage relevant conduct;
   • Conflicts which cannot be appropriately managed or waived after full disclosure to all parties concerned should be eliminated;
   • If conflicts of interest cannot be resolved, individuals and/or institutions should recuse themselves from the matter at hand;
   • The Conflict of Interest policy should create and enforce guidelines to properly manage the potential conflicts of interest which might result from officers or employees:
     • Accepting gifts or gratuities in any form which could reasonably create the appearance of a conflict;
     • Consulting with or serving on the advisory or governing boards of any other entity.
   • Any uncertainty should be resolved in a manner that reflects best practices of the field and advances the best interests of the participating students;
   • See Appendix B for more specific guidance.

Appendix A:  Program Site Visits

1. Formal site visits for the review of and familiarization with education abroad programs are among those tools which help to maintain and improve program quality, to provide accurate and needed information to students and in the exercise of due diligence toward bolstering participant safety.
2. Successful site visits are based on clear communication between the program provider or institution and the visitor in advance of the actual visit. This communication should include but not be limited to establishing mutual agreement on:
   • the specific purpose and goals of the visit;
   • the qualifications of the visitor and resident staff, e.g. director, advisor, faculty;
   • the schedule and duration of the visit;
   • the opportunity for unmediated contact between the visitor and students/faculty/ administrators;
   • any cost-sharing between the program and the visitor;
   • the gifts, hospitality or honoraria provided;
   • the criteria and confidential nature or possible use or dissemination of any planned formal evaluation of the program.
3. The visit, hospitality, or any honoraria do not imply, require or guarantee endorsement or approval of the program;
4. Comments about specific personnel should be made to the program operator or provider confidentially and separately from the main report unless otherwise agreed;
5. The program sponsor should be offered an opportunity to respond to any site-visit report as appropriate;
6. Culturally appropriate behavior is expected at the program site;
7. The visitor should not abuse the hospitality of the local program;
8. Appropriate activities include visits to classes, facilities, home-stays, internship placements, co-curricular activities, and field study events.
9. Among the materials that might be requested to assist a site visit are:
   • student programs and course evaluations,
   • orientation materials,
   • syllabi and course materials,
   • faculty and staff backgrounds,
   • information on co-curricular and student life programs and resources,
   • health and safety information,
   • emergency plans,
   • director’s reports (if they are appropriate and not internal documents).

Appendix B: Conflicts of Interest 

1. A potential conflict of interest exists when personal or institutional interests, whether financial or otherwise, may compete or be seen to be competing with the best interests of the students or inconsistent with best professional practices.
   • Institutions and provider organizations should have a conflict of interest policy and procedures for addressing conflicts of interest or their appearance;
   • If conflicts of interest cannot be resolved, affected individuals and/or institutions should recuse themselves from the matter at hand;
   • Conflicts which cannot be appropriately managed or waived after full disclosure to all parties concerned should be eliminated;
   • Gifts, Gratuities, Discounts, Rebates and Compensation
     • Any other than nominal benefits exchanged between the provider organization and the institution or its staff should be appropriately disclosed;
     • Institutions should have a process for reporting gifts of more than nominal apparent value;
     • Gifts or other items or services of more than nominal value should not be given or accepted under circumstances from which it might be reasonably inferred that the intent or effect is to impair objectivity;
     • Any rebate, commission, or discount provided by a provider organization should benefit the students directly.
2. Honoraria, Consultancies and Service on Advisory and Governing Boards
   • Provider organizations and institutions should have policies that address compensation (such as honoraria and consulting fees), gifts, gratuities, discounts, and rebates where it could be reasonably inferred that they would impair objective and fair decision making about any aspect of education abroad operations, including but not limited to affiliation, approval of study abroad programs, and student enrollment in such programs;
   • Service on advisory boards while providing valuable feedback as well as quality oversight of education abroad programs can create the appearance of a conflict. These may be managed by actions such as full disclosure of the specific purpose, goals and terms of the service; of how costs are to be borne and of any compensation, hospitality or honoraria provided;
   • The role of a governing board differs from an advisory board in its influence, responsibility, and accountability to an organization, moving beyond providing advice and counsel. As such, the guidelines for service on governing boards are subject to ethical considerations which are guided by generally accepted principles of ethical board management, and thus not included here.