Code of Conduct ::: Nelnet
 

Nelnet Code of Conduct

Letter from Jeff Noordhoek to Nelnet Associates:

I believe our corporate vision to make educational dreams possible is a noble one. Our vision is created with the purpose of helping people better themselves through education, and it is the number one reason I come to work everyday. If you think of the countries in the world today that are great nations, and conversely of the nations that are struggling, you can generally trace a country's success or failure back to the educational opportunities of that nation's populace.

The Nelnet Code of Conduct is not meant to be all-encompassing. It is not written to cover every workplace or ethical dilemma you will face, but it is meant to help you recognize potential issues and understand how to deal with them. In our day-to-day business dealings, each of us relies on our good judgment and experience to ensure we make the right decisions to fulfill our vision. It's our responsibility to our customers, our associates, and to the communities in which we live and work to act with integrity in every situation. Of course, common sense suggests that business conduct issues are not always black and white. This is where the Nelnet Code of Conduct can help. While no document can address every possible issue that you may encounter while performing your job, we have designed the Code to provide you a starting point with very clear avenues of escalation when you have concerns related to your work.

Nelnet's Code of Conduct applies to and serves as a guide for each of us -- sales, marketing, operations, shared services, management, and board members -- as we strive to do business with the highest degree of honesty and integrity. This document not only summarizes key policies, but provides practical applications that you can use as a guide and reference. I encourage you to become familiar with these policies, and look to our Web site for more details about the values and principles we consider critical to a successful organization. We will continue to amend this document as new regulations and guidelines are adopted.

Each of us is responsible for adhering to a high standard of conduct. I have committed to these principles, and by working at Nelnet you need to do the same.

Jeff Noordhoek, President, Nelnet

 

Nelnet Enterprise Code of Conduct:


1. Comply with laws, regulations and Nelnet standards: we must comply with the spirit, not just the letter, of relevant laws, regulations and Nelnet standards as outlined in this code and other Nelnet policies. We expect Nelnet associates to deal fairly with all Nelnet stakeholders.

2. Speak up: we must speak up if we suspect any actual, planned or potential behavior that may breach any laws, regulations or Nelnet standards.

3. Reject bribery and corruption: we must not give or accept bribes or engage in any form of corruption.

4. Avoid being compromised by gifts and entertainment: we must not offer, give or accept inappropriate gifts or benefits, as defined later in this document, to or from third parties.

5. Prevent fraud and financial misrepresentation: we must comply with laws, regulations and Nelnet standards on financial integrity and fraud prevention.

6. Avoid conflicts of interest: we must take steps to avoid conflicts of interest. If we identify potential conflicts of interest, we must take action to resolve and manage them in an open and honest manner.

7. Protect and ensure proper use of company assets: we must protect Nelnet's assets and ensure that they are used efficiently and for legitimate business purposes.

8. Know the SEC rules and trade only when you cannot be considered to possess insider information: we must comply with Nelnet's Securities Trading Policy.

9. Accurately represent Nelnet always and never mis-sell or misrepresent Nelnet products or services: we must comply with laws, regulations and Nelnet standards on mis-selling and advertising.

10. Resolve customer complaints quickly and fairly: we must ensure that all complaints are resolved quickly, fairly and recorded appropriately.

11. Respect confidentiality and protect data: we must respect laws, regulations and Nelnet standards governing confidentiality of information and data protection.

12. Treat our people fairly: we must treat our colleagues with fairness and respect, help them to grow, enable individuals to make a difference and teams to win.

13. Be open and honest with our regulators: we must demonstrate exemplary governance wherever we are.

14. For FFELP Business Segments, comply with the Student Loan Code of Conduct. There are specific guidelines for those involved in student lending activities as noted later in this document.

15. For Fee-Based Business Segments, comply with the Fee-Based Business Segment Guiding Principles as noted later in this document.

Click here for complete Enterprise-wide Nelnet Code of Conduct: Leading by Example, which includes our Student Loan Code of Conduct.

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