Ecmc Education Inc.

“The Zenith Education Group, Inc. whistleblower policy requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of the Corporation are to practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations. The policy provides for reporting mechanisms of potential illegal practices or violations of corporate policies, and prohibits repercussions for good faith reporting of suspected violations under the policy. In addition, ECMC Group, Inc. has a code of ethics and business conduct policy that is affirmed annually by all ECMC Group, Inc. and affiliated companies' officers and employees. There is a provision incorporated into the code of ethics and business conduct policy that binds all employees that states there can be no repercussions for good faith reporting of potential illegal practices or violations of corporate policies. ECMC Group, Inc. has established an anonymous whistleblower telephone hotline and website administered by an outside vendor. The hotline and website are available and accessible to Zenith Education Group, Inc. directors, officers, employees and vendors.”

“Zenith Education Group, Inc. HAS ONE MEMBER. THE MEMBER IS ECMC GROUP, INC. A DELAWARE, non-stock, nonprofit CORPORATION EXEMPT UNDER SECTION 501(C)(3). THERE ARE NO STOCKHOLDERS.”

“ECMC GROUP, INC. HAS THE RIGHT TO ELECT AND/OR APPROVE ALL THE DIRECTORS OF THE Zenith Education Group, Inc. BOARD OF DIRECTORS.”

“ECMC GROUP, INC., THE SOLE MEMBER OF Zenith Education Group, Inc., RETAINS THE FOLLOWING AUTHORITY OVER Zenith Education Group, Inc.: 1. TO AUTHORIZE AMENDMENTS TO THE ARTICLES OF INCORPORATION AND BYLAWS. 2. TO APPROVE THE STRATEGIC AND FINANCIAL PLANS. 3. TO ELECT AND/OR APPROVE THE MEMBERS OF THE BOARD OF DIRECTORS. 4. TO OVERSEE COORDINATION OF PROGRAMS AND SERVICES OFFERED. 5. TO AUTHORIZE FORMATION, GOVERNANCE AND DISSOLUTION.”

“All members of the board of directors and executive management are provided a copy of form 990 to review and provide comments prior to filing. All members of the board of directors and executive management are provided with a copy of the final version of form 990 before it has been filed.”

“OFFICERS, DIRECTORS AND Key EMPLOYEES ARE REQUIRED TO REAFFIRM ON AN ANNUAL BASIS THEIR UNDERSTANDING OF THE COMPANY'S Conflict of Interest Policy. THE AFFIRMATION SPECIFICALLY REFERENCES THAT THE INDIVIDUAL WILL COMPLY WITH THE DIRECTIVES OF THE Corporation's Conflict of Interest Policy. It also references the individual's fiduciary duty to the corporation, responsibility not to disclose confidential, proprietary information and understanding that as a charitable organization the corporation must diligently avoid in fact and in appearance any conflict of interest in order to maintain the trust of the public. The policy is reviewed annually. MONITORING AND ENFORCEMENT OF THE POLICY are ACCOMPLISHED THROUGH THE REAFFIRMATION PROCESS. IN CASES WHERE A POTENTIAL CONFLICT IS DISCLOSED TO THE Board, Committee or Board's Designee, procedures are in place to determine whether a conflict of interest exists and to address a conflict of interest. THE BOARD member WILL BE REQUIRED TO EXCUSE THEMSELVES FROM the process ON MATTERS WHERE THEY MAY HAVE A CONFLICT OF INTEREST.”

“The following describes the Educational Credit Management Corporation (ECMC), Zenith Education Group, Inc. and ECMC Group, Inc. executive compensation methodology. The Governance & Compensation Committee of the ECMC Group, Inc. Board of Directors is wholly comprised of independent, outside directors. In 2016, the Committee retained executive compensation experts from Grant Thornton, a global compensation consulting organization, through Arnold & Porter LLP to identify appropriate CEO and senior executive compensation packages. Arnold & Porter LLP provided a written opinion on the reasonableness of this compensation. The market analysis performed by Grant Thornton for Arnold & Porter LLP includes salary and incentive data from an appropriate peer group under IRS regulations and includes both nonprofit and for-profit entities.”

“The following describes the Educational Credit Management Corporation (ECMC), Zenith Education Group, Inc. and ECMC Group, Inc. executive compensation methodology. The Governance & Compensation Committee of the ECMC Group, Inc. Board of Directors is wholly comprised of independent, outside directors. In 2016, the Committee retained executive compensation experts from Grant Thornton, a global compensation consulting organization, through Arnold & Porter LLP to identify appropriate CEO and senior executive compensation packages. Arnold & Porter LLP provided a written opinion on the reasonableness of this compensation. The market analysis performed by Grant Thornton for Arnold & Porter LLP includes salary and incentive data from an appropriate peer group under IRS regulations and includes both nonprofit and for-profit entities.”

“No documents are made available to the public.”

“On August 8, 2017, Zenith Education Group, Inc. announced the launch of DBA Altierus Career College or Altierus Career Education, and retirement of DBAs Everest College, Everest University and Everest Institute. The new DBA name reflects the college's updated and expanded offerings in high-demand medical, trades, technology and business industries, including efforts to ensure that students are well-matched with career choices and develop the soft skills local employers value most. [www.altierus.org]”

“$4,475,654. On January 1, 2016 approximately 175 Zenith Education Group, Inc. employees in the information technology, finance and accounting, human resources, and other corporate support departments were hired into ECMC Shared Services Company, LLC, a wholly owned subsidiary of ECMC Group, Inc. Additionally, the related property, equipment, and leasehold improvements of approximately $2.91 million and prepaid expenses and other assets of approximately $1.57 million were transferred into ECMC Shared Services Company, LLC, a wholly owned subsidiary of ECMC Group, Inc.”

“Transfer of net assets. - -4475654;”