Policies

1.1 Code of Conduct

Applies to: students, including students in college in high school classes. Approved by: the President. Reviewed: October 2026.

NewU is a community in which intellectual growth, learning from others, mutual tolerance, and respect for freedom of thought and expression come first. A student who joins NewU accepts the rights and responsibilities below. Each student is responsible for their own actions and respects the rights of others.

Scope

This Code applies to student conduct regardless of time or place: on campus, in online classes, in Populi and other NewU systems, at NewU events, and in NewU-related communications, including email, messaging, and social media.

Rights of Students

Every student has:

• the right to access and take part in the academic and non-academic opportunities NewU offers, subject to applicable standards or requirements;
• the right to freedom of thought and expression (see Open Expression);
• the right to be free from discrimination on any basis listed in Anti-Discrimination and Equal Opportunity; and
• the right to a fair process before NewU finds the student responsible for a violation (see Student Discipline).

Responsibilities of Students

Students behave responsibly on campus and online. Responsible behavior includes, but is not limited to, the following:

• Do your own academic work. Submit original work, cite sources, and use AI tools only as the syllabus permits, under Academic Integrity and Artificial Intelligence and Generative Tools.
• Attend classes, complete assignments, and meet class requirements (see Attendance).
• Treat classmates, faculty, and staff with civility and respect, online and in person. Disagreement and informed debate are valued. Demeaning, intimidating, threatening, or violent behavior has no place at NewU.
• Respect the health and safety of others. Acts or threats of physical violence against another person (including sexual violence) and disorderly conduct are prohibited. Violence is behavior that causes harm to a person or damage to property, or causes fear for one's own safety or the safety of others.
• Weapons of any kind are prohibited on campus. Do not bring firearms, explosive materials, or other dangerous articles to any NewU event without NewU's authorization.
• Respect the right of fellow students to take part in NewU organizations and in relationships with other students without fear, threat, or act of hazing.
• Do not infringe the rights of other students. NewU condemns hate speech, epithets, and racial, ethnic, sexual, and religious slurs. The content of student speech or expression is not by itself a basis for discipline; speech may be subject to discipline when it violates the law or a NewU policy. Bullying, harassment, threats, and intimidation are prohibited (see Anti-Harassment and Discriminatory Conduct).
• Do not steal, damage, deface, or misuse the property or facilities of NewU or of others. Do not disrupt NewU computing services or interfere with others' use of them (see Acceptable Use of University Systems).
• Be honest and truthful in dealings with NewU, about your own identity (for example, your name or Social Security number), and in the use of NewU and other identification.
• Obtain and maintain adequate health insurance while enrolled at NewU.
• Do not use illegal drugs. Do not use alcohol at any NewU event, or tobacco or vaping products in NewU settings, as set out in Substance Use and Smoke-Free Environment.
• Do not record, capture, or redistribute class sessions, and follow the rules in Photo, Video, and Recording and Acceptable Use of University Systems.
• Follow the Protection of Minors policies. Their rules bind adult students through this Code whether or not any individual notice is given.
• Comply with NewU policies and with federal, District of Columbia, and other applicable law.

Reporting Safety Concerns

Report safety concerns, including concerns about another student, to a faculty member or to the Chief Student Journey Officer (CSJO) at [email protected]. If anyone is in imminent danger, call 911 first, then notify the CSJO. NewU does not retaliate against anyone who reports a concern in good faith.

Dress Code

The dress code is casual. Students dress in a manner consistent with good hygiene, safety, and good taste, on campus and on camera. Use common sense.

Violations

Conduct violations are handled under Student Discipline. Academic violations are handled under Academic Integrity.

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1.2 Student Discipline

Applies to: students, including students in college in high school classes. Approved by: the President. Reviewed: October 2026.

This policy sets out a simple, fair process for responding to student conduct violations.

Scope

This policy covers non-academic conduct violations by enrolled students, including violations of the Code of Conduct, the Protection of Minors policies, Virtual Learning Environment Safety, Photo, Video, and Recording, Acceptable Use of University Systems, and Substance Use and Smoke-Free Environment. Academic Integrity and Academic Standing govern academic matters. Reports of harassment, discrimination, or retaliation are investigated and decided under Anti-Harassment and Discriminatory Conduct; any sanction on a student then follows this policy. Mandated external reporting of suspected child abuse or neglect follows Mandated Reporting and does not wait for, or depend on, this process.

Reporting

Anyone may report a suspected violation in writing to the Chief Student Journey Officer (CSJO) at [email protected]. Reports made to other NewU offices or personnel are referred to the CSJO. A report is not a finding: a student is presumed not responsible until this process establishes otherwise.

Inquiry

• The CSJO promptly evaluates each report. If no violation could have occurred, the CSJO closes the matter.
• Otherwise, the CSJO gives the student written notice of the report and its allegations, conducts a fact-finding inquiry, may interview any witness, and gives the student an opportunity to respond.
• The student may be accompanied by an advisor in meetings about the matter.
• Except in extraordinary circumstances, the CSJO makes every effort to complete the inquiry within 60 days of the report.
• For a student in college in high school classes, the CSJO notifies the partner school where the student is enrolled. For a minor student, the CSJO also informs the parent or legal guardian, and gives them an opportunity to respond before any sanction beyond a verbal warning, where Privacy and Education Records permits.
• While a report is reviewed, NewU may immediately restrict a student's access to classes, systems, or other students when safety or the protection of a minor requires it.

Standard of Evidence

A student is found responsible only on clear and convincing evidence.

Resolution by Agreement

At any time before a decision, the student may accept a proposed sanction by written agreement with the CSJO. The agreement ends the matter. Statements made while discussing an agreement are not used as evidence of responsibility, although they may lead to further inquiry.

Sanctions

Sanctions are proportionate to the conduct and may take into account prior violations and the sanctions imposed in similar cases. Available sanctions include:

• Warning: a verbal or written admonition for minor misconduct.
• Written reprimand: written censure, with notice that continued or repeated violations lead to more serious sanctions.
• Behavioral expectations agreement: written expectations signed by the student.
• Restitution: reimbursement for damage to, loss of, or misappropriation of property, or compensation for injury, by payment, property, or service. Restitution is not used for academic integrity violations.
• Disciplinary probation: for a stated period or indefinitely. A further violation during probation may lead to suspension or, in especially serious cases, expulsion.
• Short-term suspension: suspension from classes for up to five instructional days.
• Long-term suspension: separation from NewU for more than five instructional days, until a stated date, with loss of all rights and privileges of student status. The student may return when the suspension ends.
• Expulsion: permanent termination of student status and permanent separation from NewU, for the most serious misconduct or for continued serious misconduct after probation or suspension.

Conduct that endangers others or violates the law may lead to suspension or expulsion without earlier steps. Charges and refunds after a suspension or expulsion follow Tuition, Fees, and Refunds.

Who Decides

The CSJO decides sanctions up to and including short-term suspension. The President decides long-term suspension and expulsion. Each sanction is documented in writing and given to the student (and, for a minor student, to the parent or legal guardian where Privacy and Education Records permits) with an explanation of the violation, the sanction, its effective dates, and the route to dispute it.

Disputes

A student who disputes a finding or a sanction may file a written grievance under Student Grievance and Appeals. Subject to that policy's internal process, nothing in this policy limits a student's right to complain to the Middle States Commission on Higher Education (MSCHE) or the District of Columbia Higher Education Licensure Commission (HELC).

Fulfilling Sanctions

Students comply with every sanction. Failure to comply is itself a violation of the Code of Conduct. The CSJO monitors compliance.

Records and Confidentiality

The CSJO keeps records of all reports, inquiries, agreements, and sanctions as education records under Privacy and Education Records and Records Retention and Destruction. Except as the law provides otherwise, disciplinary proceedings, the identity of the people involved, and all files, statements, and findings are confidential, subject to NewU's mandated reporting obligations. Breaching that confidentiality is itself a violation of NewU policy.

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1.3 Anti-Discrimination and Equal Opportunity

Applies to: everyone (students and everyone acting for NewU). Approved by: the President. Reviewed: October 2026.

NewU admits, educates, employs, engages, and serves people on the basis of their qualifications and abilities, without unlawful discrimination, and seeks qualified students, faculty, and staff of diverse backgrounds.

Policy

NewU does not discriminate on the basis of race, color, national origin (including accent), ancestry, ethnicity, religion, sex, gender, gender identity or expression, sexual orientation, age, disability, marital or family status, family responsibilities, pregnancy, genetic information, personal appearance, political affiliation, source of income, veteran or military status, or any other characteristic protected by federal, District of Columbia, or other applicable law, in:

• admission and enrollment;
• access to programs, classes, scholarships, and activities;
• academic assessment, grading, and discipline;
• employment and contracting decisions, including hiring, engagement, compensation, evaluation, promotion, training, and termination; and
• NewU services and facilities.

This policy applies to all NewU programs and activities, on campus, online, and off campus.

Legal Framework

This policy reflects the protections of the District of Columbia Human Rights Act, the Americans with Disabilities Act (Title III, public accommodations), and other applicable federal and District of Columbia law. Harassment, including sexual harassment and sexual violence, is prohibited and handled under Anti-Harassment and Discriminatory Conduct.

Reasonable Accommodation

NewU provides reasonable accommodations to qualified students, employees, and contractors with disabilities, consistent with the District of Columbia Human Rights Act and the Americans with Disabilities Act.

• Students request accommodations under Accommodations for Students with Disabilities.
• Employees and contractors request accommodations from the HR office at [email protected]. The President decides, including questions of direct threat and undue hardship.
• NewU accommodates a qualified person so that the person can perform the essential functions of the role, unless the accommodation would create an undue hardship for NewU, or the person would pose a direct threat to themselves or others that reasonable accommodation cannot eliminate.

Reporting Discrimination

Anyone may report discrimination to the Chief Student Journey Officer (CSJO) at [email protected]. A report about the CSJO goes to the President at [email protected]. Reports are reviewed, investigated, and decided under the process in Anti-Harassment and Discriminatory Conduct.

Non-Retaliation

Retaliation against anyone for raising a discrimination concern, requesting an accommodation, or taking part in an investigation is prohibited. It is addressed under Anti-Harassment and Discriminatory Conduct and Whistleblower and Non-Retaliation.

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1.4 Anti-Harassment and Discriminatory Conduct

Applies to: everyone (students and everyone acting for NewU), and vendors and visitors in NewU settings. Approved by: the President. Reviewed: October 2026.

Harassment is a form of discrimination prohibited by law and by NewU. This policy prohibits harassment and discriminatory conduct based on any characteristic listed in Anti-Discrimination and Equal Opportunity, prohibits sexual misconduct, and sets a clear, fair, and prompt process for responding. The Chief Student Journey Officer (CSJO), at [email protected], receives every report under this policy.

Scope

This policy applies in every NewU setting, on campus, online, and at NewU events, and to every allegation against a student, employee, faculty member, contractor, or volunteer, regardless of where the conduct occurred. Conduct by vendors, applicants, partners, and visitors that affects NewU students or personnel may also be reviewed under this policy.

Definitions

• Harassment: unwelcome verbal, physical, written, or electronic conduct that denigrates or shows hostility toward a person because of a protected characteristic, and that is severe, pervasive, or persistent enough to create an intimidating, hostile, or offensive educational or work environment, or that materially interferes with a person's academic or work performance or opportunities.
• Sexual misconduct: unwelcome conduct of a sexual nature, including sexual harassment, unwelcome sexual advances, requests for sexual favors, sexual assault, dating violence, domestic violence, stalking, and sex-based bullying. It includes unwelcome conduct based on sex, sexual orientation, gender identity, or gender expression that threatens a person's academic or employment status, interferes with their academic or work performance, or creates an intimidating or offensive environment.
• Quid pro quo: conditioning an academic benefit (such as a grade, a recommendation, or a place in an activity), or an employment or contract benefit, on submission to unwelcome sexual conduct.
• Retaliation: any adverse action against a person for making a good-faith report, supporting someone who reports, opposing harassment, taking part in a process under this policy, or exercising rights protected by law.

Harassment may include slurs, epithets, stereotyping, ridicule, offensive jokes and comments, pranks, innuendo, threatening or intimidating acts, and displaying or distributing offensive material, including through the internet, email, social media, or other electronic means.

How Conduct Is Assessed

• Factors include the nature, scope, frequency, and duration of the conduct and the number of people involved.
• The conduct must be objectively intimidating, hostile, or offensive. The perception of the person affected, standing alone, is not enough. Simple teasing, offhand comments, and isolated incidents that are not severe or pervasive do not create a hostile environment.
• Harassment is especially serious between faculty and students, or between supervisors and the people they supervise, because it exploits the power of the position. Harassment between peers is also covered.
• When an issue arises in a strictly academic matter, such as class content, the CSJO handles it in consultation with the Chief Academic Officer (CAO), because it may involve academic freedom. This policy does not restrict expression protected under Open Expression.

Reporting

• Anyone, student or personnel, reports harassment, discrimination, sexual misconduct, or retaliation to the CSJO at [email protected], or to any faculty member or NewU officer, who forwards the report to the CSJO. The HR office ([email protected]) is not a channel for these reports.
• A report about the CSJO goes to the President at [email protected].
• Anonymous reports are accepted and addressed as far as the information allows.
• A report that involves suspected abuse of a minor or a boundary violation also follows Mandated Reporting, in parallel.
• NewU encourages good-faith reports.

Title IX

When Title IX of the Education Amendments of 1972 applies to NewU, the CSJO is NewU's Title IX Coordinator, and NewU applies the procedures Title IX requires.

Interim Measures

The CSJO may offer interim measures to the person reporting and to the person accused, whether or not a formal complaint is filed, including separation in classes, schedule changes, no-contact directives, counseling resources, and academic accommodations. Where safety or the protection of a minor requires it, NewU may immediately restrict a person's access to classes, systems, or students while the matter is reviewed.

Response Process

1. The CSJO reviews each report and, where warranted, opens an investigation.
2. Both parties receive written notice of the allegations and of the process.
3. An investigator without a conflict of interest gathers evidence, interviews the parties and witnesses, and prepares a written investigative summary. Each party has an opportunity to respond.
4. The President evaluates the evidence and issues a written determination with reasons.
5. Either party may appeal in writing within 10 days of receiving the determination, on the grounds of procedural irregularity, new evidence, or conflict of interest. An alternate decisionmaker without a conflict of interest, appointed for the case, decides the appeal in writing. That decision is final within NewU.

A minor student may be accompanied by a parent or legal guardian. Cases involving minors are handled with extra care for the minor's identity, wellbeing, and development. Investigations are prompt and, as far as possible, confidential.

Outcomes

A finding of responsibility may lead to remedial, educational, or disciplinary outcomes: for students, sanctions under Student Discipline, up to expulsion; for employees and contractors, the progressive response in the Code of Ethics and Conduct, up to the end of employment or contract. Interim measures continue as needed.

Coordination with Partners for College in High School Classes

When a report involves a student in college in high school classes, the CSJO notifies the corresponding contact at the partner school, and the two institutions coordinate their responses under their own procedures, protecting any minor and sharing information only as the law permits.

Related Policies

Sex-based discrimination that is not sexual misconduct (for example, exclusion from a program, or a neutral practice with a disparate impact on the basis of sex) is handled under Anti-Discrimination and Equal Opportunity, using the process above. Relationships between people acting for NewU and students are governed by Adult-Student Boundaries and Code of Interactions. Where conduct may also be abuse of a minor or a boundary violation, the CSJO coordinates so that each obligation is met.

Non-Retaliation

Retaliation is prohibited and is a separate violation, which may lead to expulsion or the end of employment or contract. NewU also takes no adverse academic, employment, or contract action against anyone based on an unsubstantiated allegation or rumor of harassment or sexual misconduct. Report retaliation to the CSJO.

Training and Distribution

NewU provides training on preventing harassment and sexual misconduct to students, faculty, and staff. Employees, faculty, other contractors, and volunteers complete the training NewU identifies as required. Those who investigate or decide matters under this policy are trained on sexual harassment, sexual assault, dating violence, domestic violence, and stalking, and on running a process that protects the safety of all parties and promotes accountability. NewU publishes this policy on its policies page and distributes it to students, faculty, and staff each year.

Records

Investigation records are confidential and kept under Records Retention and Destruction.

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1.5 Protection of Minors

Applies to: everyone (students and everyone acting for NewU), and vendors. Approved by: the President. Reviewed: October 2026.

NewU enrolls high school students in college in high school classes, and some of those students are under 18. The Protection of Minors Policy sets the rules that protect them: who may interact with them and how, how classes that include them are run and recorded, what every member of the NewU community must report and to whom, and the orientation required before anyone teaches them. The policy took effect on August 30, 2026, and has four parts:

• 1.5.1 Child Protection and Safeguarding
• 1.5.2 Mandated Reporting of Child Abuse, Neglect, and Boundary Violations
• 1.5.3 Adult-Student Boundaries and Code of Interactions
• 1.5.4 Comingled Minor and Adult Student Environment

The 1.5.5 Minors on Campus policy (effective April 22, 2026) sets when minors may be present on NewU premises and at NewU events.

Class recordings are governed by Photo, Video, and Recording, and online classes by Virtual Learning Environment Safety.

Scope

The Protection of Minors Policy applies in every NewU program, class, platform, system, and setting in which a Minor takes part, online or in person, and to all directors, officers, employees, faculty (including faculty engaged as independent contractors), staff, volunteers, vendors, and students. Its in-person provisions apply whenever a Minor is present at a NewU facility or activity. It supplements the Code of Conduct, Student Discipline, and Anti-Harassment and Discriminatory Conduct policies and controls where a participant is a Minor. A prospective student known to be a Minor is treated under its communications rules. Parents and legal guardians of Minors receive it at enrollment.

Definitions

• Minor: a person under 18 years of age. NewU enrolls no student under the age of 15.
• Covered Adult: any director, officer, employee, faculty member, contractor, volunteer, or vendor acting for NewU.
• Adult Student: an enrolled student 18 years of age or older.
• One-on-One Interaction: any private interaction between one adult and one Minor, in any medium.
• Comingled Environment: any setting, physical or virtual, in which Minors and Adult Students are present together.

Administration and Review

The Office of the President administers the Protection of Minors Policy, may issue procedures under it, and reviews it at least once a year. Questions and internal reports go to the Chief Student Journey Officer (CSJO) at [email protected].

No Retaliation

Retaliation against anyone who reports a concern in good faith or takes part in a review is prohibited and is itself a violation of this policy.

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1.5.1 Child Protection and Safeguarding

Applies to: everyone (students and everyone acting for NewU), and vendors and visitors who interact with a Minor. Approved by: the President. Reviewed: October 2026.

This policy protects Minors from abuse, exploitation, neglect, and avoidable harm in every NewU setting. Safeguarding is the responsibility of every adult who serves NewU.

Scope

This policy applies to every Minor enrolled in a NewU class and to every Covered Adult, Adult Student, and visitor who interacts with a Minor, on campus, in online classes, at NewU events, and on NewU communications channels.

Safer Recruitment and Background Screening

Hiring and engagement decisions for roles that involve contact with Minors follow Background Screening, including reference checks. A Covered Adult whose role includes instructional or recurring contact with Minors completes a background check under NewU's background check procedures as a condition of the engagement, on the timing set in the person's employment or engagement terms.

Compliance Orientation

• Before first instructional contact with a class section that includes a Minor, and every year after that, every faculty member and student-facing staff member completes NewU's safeguarding compliance orientation. It covers the Protection of Minors Policy, mandated reporting, the one-on-one and communications rules, the recording rules, and the confidentiality of student records.
• A volunteer or vendor whose role involves recurring contact with Minors completes the orientation before that contact begins.
• NewU also directs faculty and staff to the District of Columbia's mandated reporter training, which District law requires of mandatory reporters (D.C. Code § 4-1321.08).
• NewU documents completion. The orientation addresses legal and policy compliance; it is not instruction in teaching methods.
• Adult Students are not required to complete the orientation. They receive notice of the Protection of Minors Policy at enrollment and at the start of each term, and its rules bind them through the Code of Conduct whether or not any individual notice is given.

Code of Interactions

Adult-Student Boundaries and Code of Interactions governs how Covered Adults and Adult Students interact with Minors: permitted interactions, prohibited conduct, one-on-one interactions, communications, social media, and relationships. Every Covered Adult and Adult Student is bound by it in full.

Supervision in Person

When a Minor is present at a NewU facility or activity, a Covered Adult avoids being alone with the Minor in a closed or unobservable space. Where an individual meeting is necessary, it takes place in an observable, interruptible setting, such as a room with the door open or with windows. Supervision arrangements follow the hosting institution's procedures.

Supervision Online

Online classes follow Virtual Learning Environment Safety. A Covered Adult does not hold an unscheduled private video session or private chat with a Minor.

Transportation and Off-Site Activities

• NewU does not operate transportation services.
• No adult transports a Minor, except a Covered Adult acting with the written consent of the Minor's parent or legal guardian.
• For a NewU-sponsored off-site activity that includes Minors, NewU obtains the written consent of a parent or legal guardian in advance, covering the itinerary, supervision plan, emergency contact, and any medical considerations, and keeps enough adults present to maintain supervision.
• Overnight activities that include Minors take place only by exception, with the advance approval of the Chief Student Journey Officer (CSJO) and the President and a written supervision and lodging plan for the activity.

Visitors, Vendors, and Volunteers

Non-employees who interact with Minors on campus check in, are screened under Background Screening where ongoing access is contemplated, and are supervised. Vendor personnel doing one-time work have no unsupervised contact with Minors. Guests and Visitors sets the general rules for visitors.

Reporting and Response

Reporting follows Mandated Reporting. The CSJO, at [email protected], coordinates NewU's internal response. NewU cooperates fully with the authorities and with its partners for college in high school classes.

Interim Measures and Discipline

NewU may immediately restrict any person's access to classes, systems, and students while a report or suspected violation is reviewed. Violations by students are handled under Student Discipline, by employees under the Code of Ethics and Conduct, and by contractors under their agreements, up to dismissal or termination of the relationship and referral to law enforcement.

Coordination with Partners for College in High School Classes

NewU and each partner for college in high school classes coordinates safeguarding: parallel reporting where required, prompt mutual notification of incidents and protective measures involving a shared student, and information sharing limited to what the response requires and what the law permits.

Records

Safeguarding records, including investigation files, are restricted records kept under Records Retention and Destruction, with access limited as set out in Mandated Reporting.

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1.5.2 Mandated Reporting of Child Abuse, Neglect, and Boundary Violations

Applies to: everyone (students and everyone acting for NewU), and vendors. Approved by: the President. Reviewed: October 2026.

This policy makes sure that suspected abuse, neglect, exploitation, or boundary violations affecting a Minor are reported to the authorities without delay and addressed inside NewU by the Chief Student Journey Officer (CSJO).

Who Reports

Any person who has reasonable cause to suspect abuse or neglect of a Minor reports it immediately. District of Columbia law (D.C. Code § 4-1321.02) makes teachers and school officials in the District mandated reporters. Where the law of any jurisdiction makes a person a mandated reporter, that legal duty governs the external report. The report is made by the person who develops the suspicion.

Definitions

• Abuse: physical, sexual, or emotional harm or threat of harm to a Minor by an adult or an older minor.
• Neglect: failure of a parent or caregiver to meet a Minor's basic needs (food, shelter, supervision, medical care) in a way that endangers the Minor's health or wellbeing.
• Boundary violation: conduct by an adult toward a Minor that violates Adult-Student Boundaries and Code of Interactions, whether or not it rises to abuse under the law.
• Grooming: a pattern of behavior by an adult intended to build trust with a Minor or a family in order to make future abuse easier.

External Reporting

• Immediate danger: call 911.
• District of Columbia: the Child and Family Services Agency at 202-671-SAFE (7233), or the Metropolitan Police Department.
• A Minor residing in another state: the child protection authority of the Minor's state of residence. NewU keeps, with its partners for college in high school classes, a current list of state reporting contacts.
• Online exploitation: the National Center for Missing and Exploited Children (NCMEC) CyberTipline, 1-800-843-5678.
• Where the suspected abuser is a NewU employee, contractor, or volunteer, the report also goes promptly to law enforcement in the jurisdiction where the conduct occurred.
• Where the conduct occurred online and may involve several jurisdictions, the reporter consults the CSJO, who coordinates reports to the relevant state authorities and, where appropriate, to the NCMEC CyberTipline.
• Where the suspected abuser is a parent or legal guardian, the report follows the procedures of the child protection authority of the Minor's state of residence.

Information Reported

As far as known, the reporter gives: the Minor's name, age, and address; the names and contact information of the parents or legal guardians; the nature and extent of the suspected abuse, neglect, or boundary violation; the identity of the suspected perpetrator; the basis for the suspicion; and the reporter's contact information.

Internal Notification

• In parallel with the external report, the reporter notifies the CSJO at [email protected], who informs the President. If the suspected perpetrator is the CSJO, the reporter notifies the President at [email protected].
• Internal notification does not delay or replace the external report.
• NewU documents the report and the response.

Protection of the Reporter and the Minor

• Reports made in good faith are protected even if not substantiated. No one who reports in good faith is subject to retaliation (see Whistleblower and Non-Retaliation).
• The reporter does not investigate. Investigation belongs to the authorities.
• The Minor is supported, kept safe from the suspected perpetrator while the matter is investigated, and not pressed for more disclosure than safety requires.
• Communications with the family are coordinated with the authorities so as not to prejudice an investigation.

Boundary Violations

Suspected boundary violations that do not rise to abuse are reported to the CSJO in writing. The CSJO investigates, and the outcome is decided under Student Discipline for students and the Code of Ethics and Conduct for employees and contractors, up to expulsion or the end of employment or contract. Where conduct appears to cross into abuse, an external report is made.

False Reports

A report made knowingly false is handled under Student Discipline or the Code of Ethics and Conduct and may be referred to law enforcement.

Confidentiality

Reports and related records are confidential. Access is limited to the CSJO, the President, the investigating authorities, NewU's counsel, and NewU's insurer.

Training

Mandated reporting is part of the safeguarding compliance orientation in Child Protection and Safeguarding.

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1.5.3 Adult-Student Boundaries and Code of Interactions

Applies to: everyone acting for NewU (directors, officers, employees, contractors including all faculty, and volunteers), vendors, and Adult Students. Approved by: the President. Reviewed: October 2026.

This policy sets professional boundaries between adults and Minors in every NewU setting, and NewU's rule on relationships between people acting for NewU and students of any age. Interaction between Adult Students and Minors in shared classes is a normal and valued part of a NewU education. This policy regulates the channel and the conduct, not the collaboration.

Core Principles

• Adult interactions with Minors serve a clear educational, advising, or safety purpose.
• Interactions take place in observable, interruptible settings and on NewU platforms and accounts.
• Adults treat students with respect and keep professional reserve in personal matters.
• An adult who is unsure about an interaction consults the Chief Student Journey Officer (CSJO) at [email protected] before going ahead.

Permitted Academic Interactions

The following are permitted and encouraged, on NewU platforms and accounts: office hours, tutoring, and academic help, individually or in groups; substantive feedback and praise tied to a student's work; academic, transfer, and career advising; letters of recommendation and transfer support through NewU channels; class discussion, breakout rooms, group projects, study groups, and peer review, including faculty-assigned project teams that place Adult Students and Minors together; and institutional recognition and awards. Members of a project team communicate about the work through NewU accounts, including one-on-one. Nothing in this policy requires a Covered Adult or an Adult Student to avoid, ignore, or refuse ordinary academic contact with a Minor.

Rules for All Adults

All adults, Covered Adults and Adult Students alike:

• do not pursue romantic or sexual conduct of any kind with a Minor; such conduct is reported under Mandated Reporting and to the authorities;
• do not initiate private off-platform contact with a student they know or reasonably believe to be a Minor (personal direct messages, social media follows, personal phone, email, or messaging apps, or private meetings); collaboration and communication with a Minor run on NewU platforms;
• do not provide or facilitate alcohol, tobacco, cannabis, vapes, or any illegal substance to a Minor;
• do not transport a Minor, except a Covered Adult acting with the written consent of the Minor's parent or legal guardian; and
• do not share sexual content with a Minor, view sexual content in a Minor's presence, or make sexualized comments.

Additional Rules for Covered Adults

Covered Adults also:

• communicate with a Minor only through NewU accounts and systems, never through personal email, personal phone, personal messaging apps, or personal social media, and do not exchange phone numbers, personal social media handles, or private email addresses with a Minor;
• do not photograph or record a Minor except through NewU's standard class recording (see Photo, Video, and Recording);
• do not arrange to meet a Minor off platform, and do not invite a Minor to a private residence; and
• do not give a Minor gifts of meaningful value, money, or loans, and do not single out a Minor for excessive personal attention, favoritism, or grooming behavior.

One-on-One Interactions and Office Hours

One-on-one academic contact with a Minor is permitted and is conducted so that it is observable and interruptible: it takes place on NewU platforms and accounts, is scheduled through the NewU calendar so that it is visible to academic administration, and occurs in settings NewU records or can review. Individual electronic communication with a Minor runs on NewU systems, where it is retained and reviewable. A Covered Adult does not hold an unscheduled private video session or private chat with a Minor. Group channels that include Minors are moderated by the instructor or another Covered Adult. On campus, one-on-one office hours with a Minor take place in an observable space with the door open.

Physical Contact

Physical contact with a Minor is limited to brief, age-appropriate interactions in public settings, consistent with safety, first aid, or a customary greeting the student has not signaled discomfort with. Massages, lap-sitting, kissing, lingering hugs, and any contact that could reasonably be read as sexual, intimidating, or controlling are prohibited.

Social Media and Professional Networks

Covered Adults and Adult Students do not connect with an enrolled Minor from personal accounts on any social media or messaging platform: no friending, following, connection requests, or direct messages. This includes professional networks such as LinkedIn while the student is a Minor. A Covered Adult who receives a connection request from a Minor declines it or leaves it pending, tells the student why, and invites the student to connect once the student is 18; a letter of recommendation through NewU channels is the substitute in the meantime. Personal social media posts never identify a Minor or show a Minor's image. NewU-run public accounts may be used for program communication under NewU's direction.

Relationships with Students

• No one acting for NewU has a romantic, sexual, or dating relationship with any enrolled or admitted student of any age.
• A relationship that existed before the academic relationship began, such as a spouse who enrolls, is disclosed immediately in writing to the Chief Academic Officer (CAO), who informs the President. The person never teaches, advises, supervises, or evaluates that student. NewU acts to remove the conflict, for example by moving the student to a different class section or assigning a different advisor or evaluator.
• No exception ever applies to a Minor.
• No one acting for NewU has a romantic, sexual, or dating relationship with a former student who was a Minor while enrolled until at least two years after that student's graduation.
• A faculty member who has a personal, financial, or other interest that might conflict with their academic responsibilities to a student discloses it to the CAO, who manages the conflict.
• Failing to disclose a relationship, or entering a prohibited one, leads to discipline up to the end of employment or contract.

Reporting and Response

Suspected boundary violations are reported under Mandated Reporting, and the CSJO investigates. Outcomes may include training, reassignment, suspension, the end of employment or contract, expulsion of a student, and an external report. Retaliation against anyone who reports a possible violation of this policy is prohibited.

Training

Faculty and students familiarize themselves with this policy. Covered Adults complete the orientation in Child Protection and Safeguarding. Faculty also follow Working with Minor Students.

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1.5.4 Comingled Minor and Adult Student Environment

Applies to: students, faculty, and everyone acting for NewU in a class or setting that includes a Minor. Approved by: the President. Reviewed: October 2026.

This policy sets the safeguards that apply because Minors study alongside Adult Students in NewU classes. It covers every NewU class, platform, and setting in which both are present, on campus and online.

Minors in NewU Classes

Minors take college in high school classes through partner institutions, including Dual Academy, and sit in the same class sections as Adult Students, with the same NewU faculty. Class content remains at college level for every student, and every student is held to the same academic standard. Minors and Adult Students discuss, collaborate, and work in groups together in class sessions, breakout rooms, and class activities.

Notice

• Parents and legal guardians of Minors receive the Protection of Minors Policy at enrollment.
• Adult Students receive notice of it at enrollment and at the start of each term. Its conduct rules bind them through the Code of Conduct whether or not any individual notice is given.

Conduct in Shared Classes

All students in shared classes follow the Code of Conduct and Anti-Harassment and Discriminatory Conduct. In particular:

• Group projects, study groups, and out-of-class collaboration take place on NewU platforms whenever practical. Where students arrange to work together outside class, they use NewU email or Populi messaging and meet in public or virtual settings.
• Members of a faculty-assigned project team communicate about the work through NewU accounts, including one-on-one.
• Adult Students do not initiate private messages from personal accounts, social media follows, or off-platform contact with a student they know or reasonably believe to be a Minor.
• Romantic or sexual conduct between an Adult Student and a Minor is prohibited and is reported under Mandated Reporting.
• Adult Students do not provide alcohol, tobacco, cannabis, or any illegal substance to a Minor, on or off NewU premises.
• Adult Students do not transport a Minor.

Faculty Awareness and Privacy

• Faculty are told before the term which students in their sections are Minors, and apply Virtual Learning Environment Safety and Adult-Student Boundaries and Code of Interactions with that knowledge.
• Faculty treat that information as confidential. A student's status as a Minor is shared within NewU only on a need-to-know basis, and faculty do not disclose individual students' ages in front of other students.
• Where a specific assignment, activity, or material would be unsuitable for a Minor, the faculty member consults the Chief Academic Officer (CAO) before assigning it.

Reporting Off-Platform Contact

An Adult Student who becomes aware of attempted or actual off-platform contact with a Minor, or of other conduct that may violate the Protection of Minors Policy, reports it to the Chief Student Journey Officer (CSJO) at [email protected].

Education Records of Minors

NewU education records are postsecondary records. Under the Family Educational Rights and Privacy Act (FERPA), the rights in them belong to the student from enrollment, at any age. Inquiries from parents and legal guardians about a student's records, grades, or performance go to [email protected]; faculty and staff forward any such inquiry there and do not respond to the parent directly. Parent access to grades and attendance follows Privacy and Education Records.

Supervision Outside Class

NewU's responsibility for supervising a Minor is limited to scheduled class sessions and announced NewU programming, on campus or online. NewU does not assume responsibility for supervising Minors outside those times, on or off campus.

Coordination with Partners for College in High School Classes

NewU and each partner coordinate so that conduct policies apply consistently, mandated reports are made in parallel where required, and information about safeguarding incidents is shared as Child Protection and Safeguarding provides.

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1.5.5 Minors on Campus

Applies to: everyone (students and everyone acting for NewU), and every visitor under 18 and the adult accompanying them. Approved by: the President (effective April 22, 2026). Reviewed: October 2026.

NewU University is a degree-granting institution serving adult learners. This policy sets out when and how individuals under the age of 18 ("minors") may be present on NewU's campus or at NewU-sponsored activities. The policy exists to protect minors, to preserve the instructional environment NewU's students pay for, and to maintain compliance with NewU's insurance and lease obligations.

This policy applies to all minors on NewU premises at 1400 16th Street NW or at any NewU-sponsored off-site activity, regardless of the purpose of their visit or their relationship to any NewU community member.

Guiding Principle

Minors are permitted on NewU premises only when their presence is connected to NewU's educational mission: when they are themselves enrolled, when they are prospective students being evaluated for enrollment, or when they are attending an event designed for their participation. Active classrooms are reserved for enrolled students at all times, regardless of the relationship of the minor to any NewU community member.

Enrolled NewU Students Who Are Minors

Degree-seeking students who are under 18 at the time of enrollment or during their studies are permitted on campus for all regular academic purposes. At the time of enrollment, NewU obtains a parent or guardian acknowledgment covering emergency contact, medical consent, and acknowledgment of NewU's adult-learner environment. NewU does not serve alcohol to enrolled minor students at University events and does not house them in any overnight or residential arrangement.

Dual Academy Students and Other Students in College in High School Classes

Minors participating in NewU Dual Academy or taking college in high school classes through any other K-12 partner are permitted on campus solely for program-related academic activities. Participation requires:

• A signed parent or guardian consent and liability acknowledgment;
• A written agreement between NewU and the partner school that addresses supervision, emergency protocols, and allocation of responsibility; and
• Designated NewU staff supervision during any on-campus activity.

Dual Academy students are not permitted on campus outside scheduled program hours without separate authorization.

Prospective Student Visitors

Minors visiting campus for admissions-related purposes, including scheduled tours, information sessions, and shadow visits, are permitted subject to the following:

• The prospective student must be accompanied by one parent, guardian, or authorized group leader;
• A signed visitor waiver must be on file;
• The visit must be scheduled in advance through the Admissions Office ([email protected]) or the Office of the President; and
• The visit is limited to the prospective student and their accompanying adult.

Siblings or other minor children of the accompanying adult are not permitted absent advance written approval from the Office of the President.

Minors at NewU-Sponsored Events Designed for Their Participation

Minors are permitted at NewU-sponsored events specifically designed to include them, for example Dual Academy showcases, family graduation ceremonies for enrolled students, or community events expressly advertised as open to families. A parent or guardian must remain with the minor at all times.

General-audience NewU events that are not specifically designed for minors, including adult-focused lectures, receptions, and professional convenings, are not covered by this section. Minors may not attend such events unless they fall within another permitted category above.

Minors Not Permitted on Campus

Except as specifically provided above, minors are not permitted on NewU premises. This includes:

• Active classrooms. Minors who are not enrolled in the class or participating in an approved Dual Academy activity may not be present in active classrooms, regardless of the relationship of the minor to any NewU community member. This restriction applies without exception because NewU's enrolled students pay for an instructional environment designed for them.
• Children of faculty, staff, and contractors. Employees and contractors may not bring their children to campus, including for "bring your child to work" observances, school holidays, snow days, or childcare gaps. Those needing coverage during such periods use their flexible schedule or remote work.
• Children of students. Students may not bring their children to class or to other instructional activities. Students needing childcare accommodations contact their professor to discuss options, such as attending online.
• Unaccompanied minors. Minors may not be on NewU premises without a parent, guardian, or authorized NewU supervisor as required by their permitted category.

Exceptions

Exceptions to this policy may be granted only in writing by the President, and only where:

• The nature of the visit has been evaluated against NewU's insurance coverage and lease obligations;
• Appropriate documentation is in place; and
• The exception does not set a precedent inconsistent with this policy.

Verbal or email-only permissions do not constitute an approved exception.

Required Documentation

Depending on the category, one or more of the following must be in place before a minor is present on campus:

• Parent or guardian acknowledgment (enrolled minor students);
• Consent for college in high school classes and partner-school agreement (Dual Academy students);
• Visitor waiver, individual or group (prospective student visitors and family-designed events); and
• Written presidential exception (all other cases).

The Office of the President maintains templates for each.

Mandated Reporting and Child Safety

All NewU faculty, staff, and contractors who interact with minors in connection with NewU activities comply with District of Columbia mandated reporter obligations regarding suspected child abuse or neglect, as set out in Mandated Reporting of Child Abuse, Neglect, and Boundary Violations.

Building Access and Landlord Requirements

NewU's lease at 1400 16th Street NW requires NewU to take responsibility for all persons it authorizes to enter the building and limits the permitted use of the premises to general office and classroom use. The landlord reserves the right to exclude any person not known to building management and may at its option require registration. Because NewU is liable to the landlord for the conduct of anyone it authorizes to enter, responsible adults escorting minors under this policy must be able to account for those minors at all times while on NewU premises.

Enforcement

Faculty, staff, or students who bring minors to campus in violation of this policy may be asked to remove the minor immediately and may be subject to disciplinary action. Repeat violations may result in more significant consequences, up to and including termination or dismissal.

Review

The Office of the President reviews this policy annually and updates it as needed to reflect changes in NewU's insurance coverage, lease obligations, applicable law, or institutional circumstances.

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1.6 Virtual Learning Environment Safety

Applies to: students, faculty, and everyone acting for NewU in an online class session. Approved by: the President. Reviewed: October 2026.

This policy keeps NewU's online classes safe, orderly, and appropriate for every student, including the minor students (students under 18) who attend some class sections.

Scope

All NewU instruction delivered online: live class sessions in Google Meet, including online students who join on-campus classes through classroom cameras and microphones; class recordings; Populi; NewU email; and any other online environment NewU uses for teaching.

Account and Identity

• NewU creates a Google account for each student at enrollment, used for Google Meet, class materials, and Populi. Each student uses only their own NewU account; sharing accounts is prohibited. NewU accounts are protected by multi-factor authentication.
• Students display their first name and last initial, or another identifier NewU directs.
• Sign-in with the student's own NewU account and multi-factor authentication, proctored examinations, and faculty-observed assessments, including live participation and capstone presentations, verify that the registered student is the student who takes part in and completes the class.
• Students take examinations electronically in Populi. Where the syllabus calls for remote proctoring, examinations use Populi’s built-in proctoring, at no additional charge.

Camera and Microphone

• Online students who attend a class session live keep their camera on for the full session. Class is a discussion, not a broadcast.
• An instructor may direct cameras off for a particular activity, such as a screen-shared demonstration or an assessment.
• Microphones are muted by default and unmuted to speak, unless the instructor directs otherwise.
• Apart from an instructor's direction for an activity, the camera rule is adjusted only by an accommodation under Accommodations for Students with Disabilities or by the President's approval of a written request.
• Online students and Flex students (high school students taking college classes through Dual Academy Flex) may attend each session live or watch the class recording, subject to the assignment and assessment deadlines of the class (see Attendance).

Technology and Workspace

Online students need a laptop or desktop computer (a phone or tablet is not enough) with the current Google Chrome browser, a working webcam and microphone, an internet connection of at least 5 Mbps download and 5 Mbps upload, and a quiet workspace where they can speak in class. The Student Catalog lists the full requirements.

Classroom Conduct

• Backgrounds and attire are appropriate for a classroom. Virtual backgrounds are permitted.
• Inappropriate language, harassment, hate speech, and disruptive behavior are prohibited and handled under the Code of Conduct and Student Discipline.
• No one shares personal contact information, home addresses, financial information, or identifying images of minor students in shared channels.

Recording

• NewU records every class session, and participants are notified when a session is being recorded. Photo, Video, and Recording sets out how recordings are stored, who may see them, how long they are kept, and how they may be used.
• Only NewU records class sessions. Students do not record, capture, or redistribute any part of a class session (see Acceptable Use of University Systems).
• Instructors do not download class recordings to personal devices and do not share a recording outside the enrolled class section without the prior written approval of the Chief Academic Officer (CAO).

One-on-One Sessions and Communications

• Faculty and staff communicate with students only through NewU accounts and systems: NewU email, Populi, and Google Meet. They never communicate with a minor student through personal email, personal phone, personal messaging apps, or personal social media.
• Office hours take place on NewU platforms and are scheduled through the NewU calendar. No one acting for NewU holds an unscheduled private video session or private chat with a minor student (see Adult-Student Boundaries and Code of Interactions).
• Group chats that include minor students are moderated by the instructor or another adult acting for NewU.

Intruder and Disruption Response

If an uninvited participant joins, or a session is disrupted by inappropriate content or behavior, the instructor:

• removes the participant immediately;
• locks the session, or ends it and reconvenes with a new link;
• preserves the recording, chat log, and participant list;
• reassures students and resumes instruction if appropriate;
• reports the incident to [email protected] and to the Chief Student Journey Officer (CSJO) at [email protected] the same business day; and
• where minor students were exposed to harmful content, follows Mandated Reporting.

Classes with Minor Students

Many class sections include both minor students and adult students. Instructors are told before the term which students are minors and apply this policy with that knowledge. Adult students follow Comingled Minor and Adult Student Environment and all the conduct rules above.

Accessibility

Where an accommodation adjusts the camera, microphone, or recording rules, it is documented under Accommodations for Students with Disabilities and honored without disclosing the underlying condition to other students.

Technical Support

Email [email protected] or text 202.968.1005, ideally before class day.

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1.7 Photo, Video, and Recording

Applies to: everyone (students and everyone acting for NewU). Approved by: the President. Reviewed: October 2026.

This policy sets out when and how photos, video, and audio of students and faculty are captured, stored, and used, with particular care for minor students (students under 18). It covers all NewU-related capture and use of images and recordings, in any setting and on any device, including NewU class recordings.

Class Recordings

• NewU records every NewU class session (video, audio, and material presented on screen) through classroom cameras and microphones and Google Meet. Participants are notified when a session is being recorded.
• NewU Inc. creates and owns class recordings and is their custodian. Recordings are not faculty work products.
• Recordings are stored in NewU's Google Workspace for Education environment with restricted sharing. NewU sets the access list: the instructor, the students enrolled in the section, and designated academic administrators of NewU and of the partner school for college in high school classes.
• NewU uses recordings for instruction and student review, academic administration, quality assurance, accreditation, and investigations.
• Recordings are kept for one academic year and then deleted, unless preserved for an investigation or as required by law.
• Recordings are never used for marketing and are never used to train artificial intelligence or machine learning models.
• Sharing a recording outside the enrolled class section requires the prior written approval of the Chief Academic Officer (CAO).
• Faculty and staff do not download recordings to personal devices and do not make their own recordings of class sessions or of students.
• Students, family members, and other participants do not record, capture, or redistribute any class session or its materials. The full rule is in Acceptable Use of University Systems. Violations are handled under Student Discipline and the responsible institution's policies.

Minor Students

No one acting for NewU photographs or records a minor student except through NewU's standard class recording, and no one acting for NewU posts an image of an identifiable minor student on personal social media (see Adult-Student Boundaries and Code of Interactions).

Marketing and Public Use

• A photo, video, or audio recording of an identifiable minor student is used in marketing, on the website, in social media, in press releases, in published materials, or in any other external context only with the prior written consent of a parent or legal guardian. For an adult student, consent comes from the student.
• Consent forms state the intended uses, how long the consent lasts, the right to withdraw consent for future uses, and how to request removal where feasible.
• Marketing use of a faculty member's likeness requires that faculty member's separate written consent.
• Crowd or context photos in which no minor student is individually identifiable do not require individual consent.

Routine Operations

Photos and recordings that are part of routine operations, such as class recordings, identification photos in NewU systems, and examination proctoring, are not marketing or public uses and do not need marketing consent. NewU handles proctored examination data as an education record (see Privacy and Education Records).

Events and Campus

• Photography and recording at NewU events are done only by NewU-designated personnel or approved photographers who follow this policy.
• Photos and recordings of an identifiable student taken at events are used only for purposes covered by an active consent on file.

Personal Devices and Social Media

• Everyone acting for NewU follows the minor student rule above on personal devices and personal social media.
• Students respect the privacy of other students and do not post images of other students who have not consented.

Storage and Removal

Photos and recordings are stored on NewU-managed systems. Marketing assets showing identifiable people are removed from active use when consent is withdrawn or on a written removal request, subject to prior good-faith use.

Investigations

Recording in connection with harassment proceedings, child protection investigations, or law enforcement is governed by Anti-Harassment and Discriminatory Conduct and Mandated Reporting, and may be lawful without consent where appropriate.

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1.8 Acceptable Use of University Systems

Applies to: everyone (students and everyone acting for NewU). Approved by: the President. Reviewed: October 2026.

This policy sets out how students, employees, faculty and other contractors, and volunteers use NewU's systems, accounts, and equipment.

Scope

All NewU-issued accounts and systems: NewU Google Workspace for Education accounts (newu.edu email, Google Meet, and file storage), Populi, Salesforce EDA, NewU networks, and NewU-owned equipment, including classroom computers, cameras, and microphones. The policy applies wherever these are used, including on personal devices, and to use of other networks through NewU resources.

Authorized Use

• NewU systems are for NewU work: teaching, learning, scholarship, administration, and approved communications. Resources are limited; users use them wisely and with consideration for others.
• Limited incidental personal use that does not interfere with work, consume meaningful resources, or violate policy is acceptable for employees and faculty.
• NewU systems are not used for private commercial activity, partisan political activity, or activity that creates a conflict of interest.
• NewU email is for NewU business. Emails are NewU records and may be subject to recordkeeping requirements and to discovery in litigation.
• Anything published through NewU systems represents NewU, not only the individual, even with a disclaimer. Appropriate language and conduct are expected.

Account Security

• Users use only their own accounts, keep credentials confidential, and do not share accounts, even for convenience. Another user's carelessness in revealing a password does not authorize its use.
• Users are responsible for all use of their accounts.
• Multi-factor authentication is enabled on every NewU account where available.
• Users lock their devices when away.
• A suspected account compromise is reported immediately to [email protected].

Prohibited Activity

• Attempting to circumvent security controls, scan networks, or access systems, data, or accounts without authorization, including by supplying false information or obtaining another person's password.
• Modifying or attempting to crash NewU systems, tampering with software protections or restrictions, or removing, reconfiguring, or moving cables, equipment, software, or services on NewU-owned equipment.
• Encroaching on others' use: tying up resources with games or other trivial uses, sending frivolous or excessive messages (including chain letters, junk mail, and unauthorized broadcast messages), using excessive storage, running needlessly inefficient programs, or physically damaging systems.
• Distributing malware or illegal content, or content that violates Anti-Discrimination and Equal Opportunity, Anti-Harassment and Discriminatory Conduct, or Photo, Video, and Recording.
• Storing or sharing pornography, hate content, or other content that violates the law or NewU policy.
• Using NewU systems to harass, threaten, or stalk.
• Using NewU systems to communicate with a student in a way that violates Adult-Student Boundaries and Code of Interactions.
• Violating copyright or license terms, or inspecting, modifying, distributing, or copying proprietary data, programs, or files without authorization.
• Using generative AI tools to produce work submitted as one's own, except as the syllabus permits (see Artificial Intelligence and Generative Tools and Academic Integrity).

Student Information

• NewU email and systems may be used on a personal device. Student information stays in NewU accounts and systems; it is not downloaded or saved to personal devices or personal accounts.
• Any actual or suspected unauthorized access to, disclosure of, or loss of student information is reported immediately to [email protected] and [email protected]. Faculty and other contractors also give NewU written notice within 72 hours, as their agreements require.

Recording, Capture, and Redistribution of Class Content

Class recordings belong to NewU. Class materials belong to NewU or to the faculty member who created them, as Use of University Name, Trademark, and Intellectual Property provides. Enrollment gives a student a personal, non-transferable right to use them for the student's own study while enrolled, and nothing more. Students, family members, and other members of the community:

• do not record, screen-record, screenshot, photograph, or otherwise capture any class session, in whole or in part, by any means, including a second device;
• do not download, copy, mirror, or re-upload NewU recordings, slides, assessments, or class materials to any other location or service;
• do not share, forward, publish, post, stream, sell, or otherwise make that content available to anyone not enrolled in the class, including by passing on a link or an access code;
• do not circumvent, or attempt to circumvent, any access, download, or sharing restriction NewU applies to that content; and
• do not submit that content to any artificial intelligence or machine learning tool for training, indexing, or reproduction.

Because NewU records every class session and makes the recording available to the class, no student needs to capture a class independently. A student who needs class content in a different form, including under an accommodation, asks the Chief Student Journey Officer (CSJO) at [email protected]. This section applies on personal devices and accounts as well as on NewU systems, whether the student attends live or watches a recording. Violations are handled under Student Discipline and, where they involve intellectual property, under Use of University Name, Trademark, and Intellectual Property.

Social Media

These rules apply to everyone acting for NewU who uses social media, including blogs, forums, and social networking and messaging platforms such as LinkedIn, Instagram, Facebook, X, YouTube, TikTok, and Snapchat:

• Show respect for NewU, its Board, its students, and its faculty. Do not harass, discriminate, or make defamatory comments. Anonymous posts can often be traced to the sender.
• Do not post NewU confidential information, including any student information.
• Do not identify or reference NewU students, vendors, or partners without express permission.
• A person who identifies themselves as acting for NewU, or discusses NewU matters, on a personal site includes a disclaimer that the views are their own and not NewU's. A disclaimer does not shield a post that violates NewU policy or the law.
• Employees do not use social media to criticize NewU's competitors or to compete with NewU.
• Do not use NewU's marks or reproduce NewU materials without permission (see Use of University Name, Trademark, and Intellectual Property). Ownership of work product follows the person's employment or contractor agreement.
• Follow the law, including Federal Trade Commission guidelines and copyright, trademark, and harassment laws.
• Do not friend, follow, connect with, or message an enrolled minor student from a personal account, and do not post an image that identifies a minor student (see Adult-Student Boundaries and Code of Interactions).

Monitoring and Inspection

Consistent with applicable law, and while respecting confidentiality and privacy, NewU may access, monitor, review, and inspect NewU-owned devices, systems, accounts, communications, recordings, logs, and storage used for NewU purposes. It does so to enforce its policies, including those on harassment and the safety of individuals and minor students; to prevent copyright and license violations; to protect the integrity of computers, networks, and data; and to protect NewU from seriously damaging consequences. Routine monitoring is automated and aimed at security and reliability. Targeted review of an individual account takes place only on specific cause approved by the President. Users have no expectation of privacy in their use of NewU systems. NewU complies with valid legal process, including subpoenas. NewU may restrict use of its systems, limit access to its networks, and remove or limit access to material posted on NewU systems. This policy does not chill protected speech, including good-faith reports of misconduct, lawful concerted activity, and whistleblower communications (see Whistleblower and Non-Retaliation).

Personal Devices and Departure

• Personal devices used to access NewU data run a current operating system with encryption, a screen lock, and anti-malware protection.
• When a person leaves NewU or an engagement ends, NewU disables the person's NewU accounts. NewU data on personal devices is returned or deleted as the head of IT directs, and NewU may require remote removal of NewU data from a personal device. Contractors return or delete student information at the end of their engagement.

Enforcement

Misuse may lead to loss of access and to discipline under Student Discipline for students and the Code of Ethics and Conduct for employees and contractors. System administrators may restrict access temporarily while a matter is reviewed. Misuse of other networks or computers through NewU resources is treated as misuse of NewU systems. Everyone remains bound by federal and District of Columbia law on civil rights, harassment, copyright, security, and electronic media.

Labor Rights

Nothing in this policy limits employees' rights under the National Labor Relations Act, including the right to discuss wages, hours, and other terms and conditions of employment.

Acknowledgment

Every user acknowledges this policy when NewU issues an account.

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1.9 Privacy and Education Records

Applies to: students, and everyone acting for NewU who handles education records. Approved by: the President. Reviewed: October 2026.

This policy describes the rights of students, and the duties of NewU, its faculty, and its staff, regarding education records under the Family Educational Rights and Privacy Act (FERPA). NewU's website Privacy Policy covers other personal information. Questions go to the Chief Student Journey Officer (CSJO) at [email protected].

Records Covered

Education records are records directly related to a student and kept by NewU or a party acting for NewU, including records in Populi, Salesforce EDA, and Google Workspace for Education, and proctored examination data. Personally identifiable information includes the name of the student or a family member, an address, an identification number, a biometric record, an indirect identifier such as date of birth, and other information that, alone or combined, would let a reasonable person identify the student with reasonable certainty. This policy does not cover:

• records kept in the sole possession of the maker as a personal memory aid;
• grades on peer-graded work before an instructor collects and records them;
• records of a law enforcement unit kept for law enforcement purposes;
• employment records, except records of a person employed because of their status as a student;
• treatment records made by a health care professional and shared only with those providing treatment; and
• other records FERPA excludes.

The policy applies to students who are or have been in attendance at NewU, including students in college in high school classes. It does not apply to applicants, although the admission records of applicants who enroll become education records. Records made after a student leaves are covered only where they relate back to the student's attendance.

Annual Notice

Each year NewU informs students of their FERPA rights: to consent to disclosure of their records, to opt out of directory information, to inspect and seek correction of their records, and to file a complaint with the U.S. Department of Education.

Consent to Disclosure

NewU does not disclose personally identifiable information from education records without the student's prior written or electronic consent. The consent is signed and dated and states the records to be disclosed, the purpose, and the recipients.

Disclosure Without Consent

NewU may, and in some cases must, disclose information without consent, limited to what the purpose requires:

• To school officials with a legitimate educational interest. School officials are NewU's employees and contractors, including all faculty, and outside parties that perform services NewU would otherwise perform itself, are under NewU's direct control in using and keeping records, and are bound by FERPA's limits on redisclosure, such as Populi, Salesforce, and Google. An official has a legitimate educational interest when the information is needed for, or would help, the official's duties. NewU's role-based access controls limit each official to the records they need.
• To another school where the student seeks or intends to enroll, or is already enrolled, for purposes related to the student's enrollment or transfer.
• For financial aid the student has applied for or received, to determine eligibility, amount, or conditions, or to enforce its terms.
• Under a court order or lawful subpoena, after a reasonable effort to notify the student in advance unless notice is prohibited. Subpoenas and court orders go to the President at [email protected], who approves any disclosure.
• In a health or safety emergency, to appropriate people, if the information is needed to protect the health or safety of the student or others.
• To parents, as described below.
• As directory information, as described below.
• In other cases FERPA allows or the law requires.

Parents and Students in College in High School Classes

• NewU records are postsecondary records. The rights in them belong to the student from enrollment, at any age.
• NewU treats students as adults and generally shares information from education records with parents or guardians only with the student's consent.
• A parent or legal guardian of a minor student in college in high school classes may receive the student's NewU grades and attendance on either of two bases: (a) the student's written FERPA release, collected at enrollment, which the student may revoke; or (b) the parent's written statement that the student is the parent's tax dependent. A written statement from a parent or legal guardian that the student is their dependent within the meaning of section 152 of the Internal Revenue Code of 1986 permits disclosure for any student.
• NewU also shares grades and attendance with the partner school where a student in college in high school classes is enrolled.
• Where FERPA permits and NewU decides disclosure is appropriate, NewU may also disclose without the student's consent in a health or safety emergency, and to the parent or legal guardian of a student under 21 about the student's violation of a NewU policy on alcohol or drugs.
• In an emergency or an alcohol or drug matter, the CSJO decides whether to notify parents and makes the contact. When practicable, the student is told first and given the chance to contact their parents.
• Parent and guardian inquiries go to [email protected]. Faculty and staff forward any such inquiry there and do not respond to the parent directly. Where no consent, release, or dependency statement exists, NewU responds only where the law permits disclosure.

Directory Information

NewU designates as directory information a student's name, address (local, home, or email), telephone number, date and place of birth, NewU ID number, major, participation in officially recognized activities and sports, weight and height of members of athletic teams, dates of attendance, degrees and awards received, and previous institutions attended. NewU may disclose directory information without consent unless the student opts out after the annual notice, and uses informed discretion in responding to requests. Because the Protection of Minors Policy controls where a student is a minor, NewU does not release as directory information any item that would identify a student as a minor, such as date of birth, or a minor student's home address or telephone number.

Limits on Redisclosure

NewU tells each recipient that information is disclosed on the condition that the recipient does not disclose it further without the student's prior written consent. This condition does not apply to directory information, to disclosures to the student or to parents as permitted above, to victims in certain disciplinary matters, or to disclosures under court orders and subpoenas.

Verification and Record of Disclosures

Before disclosing, NewU personnel take reasonable steps to verify the requester's identity and authority. NewU keeps a record of requests for and disclosures of a student's information, naming the requesters and recipients and their legitimate interests, for as long as the records themselves are kept, and the student may inspect it. No record is required for requests from or disclosures to the student, a school official with a legitimate educational interest, a person with the student's written consent, a person seeking directory information, or a federal grand jury or law enforcement agency under an order or subpoena that requires nondisclosure.

Inspecting Records

A student who is or has been in attendance may inspect and review their education records on written request. Requests for academic records go to [email protected] and requests for financial records to the Finance Office at [email protected]. NewU fulfills requests within 3 business days, and always within the 45 days FERPA allows. The office that keeps the record may charge a reasonable fee for copies. A student may not inspect parents' financial records without the parents' written permission, records covered by a written waiver the student signed (NewU never requires a waiver), the parts of records that contain information about other students, or other records FERPA excludes.

Correcting Records

• A student who believes a record is inaccurate, misleading, or in violation of the student's privacy rights may ask NewU to amend it. NewU decides within a reasonable time and informs the student in writing.
• If NewU declines, the student may request a hearing. A hearing may not be used to contest the appropriateness of a grade.
• The hearing is conducted by a person with no direct interest in the outcome, and the student may present relevant evidence. NewU issues a written decision within a reasonable time, summarizing the evidence and the reasons.
• If the challenge fails, the student may place a statement in the record commenting on the information or explaining the disagreement. NewU keeps the statement with the record and discloses it whenever it discloses that part of the record.

Complaints

A student may complain to the CSJO at [email protected], or to the President at [email protected] if the complaint concerns the CSJO. A student may also file a complaint about an alleged failure to comply with FERPA with the Student Privacy Policy Office, U.S. Department of Education, 400 Maryland Avenue SW, Washington, DC 20202.

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1.10 Admission and Enrollment

Applies to: applicants and students. Approved by: the President. Reviewed: October 2026.

This policy sets out how NewU admits first-year students, transfer students, and students in college in high school classes, and how an admitted student enrolls. NewU keeps applying simple and fair: it asks only for what predicts academic success, and it decides without regard to financial need. The Admissions Office ([email protected]), headed by the President, runs admissions.

Admission Principles

• Test-blind. NewU makes admission decisions solely on the basis of the applicant's high school GPA, a reliable, nondiscriminatory, and unbiased predictor of academic success, except as this policy provides for direct admissions, transfer students, and admission after college in high school classes. NewU does not require or consider test scores, essays, letters of recommendation, portfolios, resumes, certifications, lists of activities, or interviews.
• No quotas or hidden criteria. NewU uses no admission quotas based on gender, race, age, national origin, or any other metric, and no preferential policies or hidden criteria. Admission decisions follow Anti-Discrimination and Equal Opportunity.
• Financial aid-blind. NewU decides without any review or consideration of financial need or of any aid an applicant requests. The Admissions Office does not share financial aid information with admission reviewers.
• Past violations-blind. NewU does not consider past academic or disciplinary infractions or criminal convictions in admission decisions. Applicants disclose them so that NewU can support each student.

How to Apply

Applicants submit an online application and an electronic copy of their most recent high school transcript, high school diploma, GED certificate, HiSET certificate, or other state-recognized equivalent of a high school diploma. An unofficial transcript, or a photo of one, is enough to apply; NewU requires the official transcript before enrollment. An applicant who completed a homeschool program may instead submit documentation that the program complied with state homeschool law and resulted in a recognized secondary school completion credential.

NewU accepts applications through the application form on its website and through the Common App. Common App applicants pay the same $0 fee, submit no essays or test scores, and send their transcript before they enroll. NewU sets an application fee of $150 and may waive it for one, many, or all applicants; it waives it for all applicants, so applying costs $0.

Rolling Admissions

NewU reviews applications on a rolling basis for fall and spring entry. Students may apply as soon as they complete grade 11. NewU stops admitting students for an academic year two weeks after that year begins. NewU may also stop admitting for a year once all budgeted seats are filled by students who have signed an Enrollment Agreement and paid the deposit, allowing a reasonable oversubscription for customary attrition.

Admission Decisions

NewU admits every domestic first-year applicant with a verified high school credential and an unweighted cumulative GPA of 2.0 or higher. An applicant below 2.0 receives a Conditional Letter of Admission. NewU does not use waitlists. NewU informs each applicant of its decision by email and text message within 7 calendar days of receiving a complete application and any required documents. Applicants may check their status at any time at [email protected].

Conditional admission. An applicant whose unweighted cumulative high school GPA is below 2.0 may receive a Conditional Letter of Admission. The only condition is reaching an unweighted cumulative high school GPA of 2.0. When the applicant reaches it, the applicant emails a high school transcript showing it to [email protected], and NewU confirms full admission without a new application. NewU confirms the 2.0 GPA from the transcript before the student enrolls.

High School Completion Verification

NewU verifies each applicant's high school completion. For a diploma or transcript, NewU confirms that the issuing school is recognized by the relevant state education agency or by an accrediting body recognized by the U.S. Department of Education. For a school outside the U.S., NewU confirms that the school is recognized by its national or regional education authority and converts the grades to a 4.0 scale. For a GED or HiSET certificate, NewU confirms that a state-authorized testing entity issued it. If NewU has reason to believe a credential is not valid (for example, the issuer is not recognized, the credential appears altered, or there are other signs of fraud), NewU requests more documentation and may decline to recognize the credential or rescind an admission offer. An applicant whose credential cannot be validated is not eligible for admission.

Direct Admissions

NewU identifies college-ready students and may offer admission without an application (also called reverse or flipped admissions). Members of, and students enrolled in, these organizations and programs are pre-approved for admission, subject to meeting the English proficiency requirement (see International Applicants):

• National Society of High School Scholars (NSHSS)
• Sage Scholars Tuition Rewards (SSTR)
• National Honor Society (NHS)

The President may change this list.

Transfer Students

A student who has earned credit at any college or university is pre-approved for admission as a transfer student. Transfer students do not apply for admission, pay no transfer fee, and do not receive a letter of admission. They email their college transcript to [email protected], or upload it on the Transfer page of the NewU website, and receive a free transfer credit analysis within 7 days, with no obligation to enroll. Transfer students may bring up to 90 credits; Transcripts, Credit Transfer, and Diploma Issuance sets out how credit transfers.

Admission After College in High School Classes

A high school student who passes one college in high school class through a partner institution, with any grade other than F or I, qualifies for admission to NewU. The offer stays open, subject to verification of high school completion and to the deposit and Enrollment Agreement terms in effect when the student accepts it. Consistent with the Master Agreement between NewU Inc. and Dual Academy Corp., Dual Academy graduates are admitted on application, and all of their college credits are accepted toward the NewU degree. See College in High School Classes.

International Applicants

NewU does not issue Form I-20. International students who live outside the United States may enroll online and attend from outside the United States. An international student who already lives in the United States in a status that allows study without a new Form I-20 or a change of status may enroll on campus, hybrid, or online from the United States. An admission letter does not complete enrollment for an applicant who needs a student visa to study in the United States. Before enrolling an international student who lives in the United States, NewU verifies documents showing a status that allows full-time study without a new Form I-20 or a change of status. NewU does not provide immigration advice. See About These Policies.

Classes are taught in English. An international applicant shows English proficiency with documentation that English is the language spoken in the applicant’s home (a letter from the applicant’s school or counselor), that the applicant’s school taught in English, or that the applicant has lived in an English-speaking country for 2 or more years in the past 5 years. An applicant who meets none of these sends one English test score from the last 5 years at or above: TOEFL iBT 4.0 (80 on tests taken before January 21, 2026), IELTS 6.0, PTE Academic 50, Duolingo English Test 100, or Cambridge English Scale 169. Pre-approval through Direct Admissions is subject to meeting this English proficiency requirement.

Enrollment Intent Deposit

To secure a place in the incoming class, every admitted first-year and transfer student pays a non-refundable $300 Enrollment Intent Deposit. The deposit is not an extra fee: NewU deducts it from the first semester bill. It reserves the student's seat and holds the financial aid offer at the amount quoted; the deadline that locks in a scholarship offer is in Financial Aid. An offer of admission becomes void if the deposit is not paid in full and on time, except that an offer of admission after college in high school classes stays open. If NewU approves a deferral to a future semester, the deposit applies to that semester's bill. If the student later chooses not to enroll, the deposit is forfeited and not refunded.

Enrollment

After receiving the deposit, NewU emails the student an Enrollment Agreement to review and sign. An admitted and deposited student becomes enrolled on signing the NewU Enrollment Agreement (when the student is a minor, both the student and a parent or legal guardian sign). Under the agreement, the student:

• provides the official final high school transcript or diploma, or an equivalent credential; and
• pays all amounts due for the first semester under Tuition, Fees, and Refunds.

A student may cancel the Enrollment Agreement within three business days of signing it (see Tuition, Fees, and Refunds). Orientation is mandatory for all first-year and new transfer students (see Student Support Services). Students choose to study on campus, online, or hybrid at enrollment (see Academic Calendar and Instructional Time).

Withdrawal or Amendment of Offers

NewU may withdraw or amend an offer of admission, a financial aid offer, or an Enrollment Agreement for any applicant or student who:

• materially misrepresented any part of the application for admission or financial aid, falsified documents, or otherwise misrepresented themselves in a way that significantly affects the application;
• does not respond to the offer by the stated deadline, does not complete enrollment steps in time, or does not provide required documents by the stated deadlines;
• lives in the United States and cannot show a status that allows full-time study without a new Form I-20 or a change of status;
• received an offer conditional on grades, a GPA, or other conditions and does not meet them; or
• was admitted as a first-year student, other than through admission after college in high school classes, and has a high school GPA below 2.0 on a 4.0 scale at high school graduation.

Records

Application materials, admission decisions, Enrollment Agreements, and related communications are confidential and kept under Records Retention and Destruction.

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1.11 College in High School Classes

Applies to: students in college in high school classes and their parents or legal guardians. Approved by: the President. Reviewed: October 2026.

High school students take NewU college classes, called college in high school classes, through partner institutions. Dual Academy (Dual Academy Corp., a Delaware public benefit corporation) is a NewU partner: a separate, Cognia-accredited private high school, with its own admission at dualacademy.org. NewU Inc. and Dual Academy Corp. work together under the Master Agreement, whose Schedule B covers college in high school classes.

Eligibility

NewU enrolls no student under the age of 15. A high school student enrolls in NewU college classes through a partner institution and is enrolled at NewU for those classes.

Same Classes, Same Standards

Students in college in high school classes sit in the same class sections as NewU degree students, with the same NewU faculty, the same college-level content, and the same academic standards. In their NewU classes they follow the NewU policies that apply to students, including Code of Conduct, Academic Integrity, and Artificial Intelligence and Generative Tools. NewU's grading scale (see Academic Program) applies in every NewU class; Dual Academy uses its own scale only for its high school-only classes.

Credit and Transcripts

Students in college in high school classes earn NewU college credit, recorded on an official NewU transcript. They may apply it toward a NewU bachelor's degree or transfer it to another institution at that institution's discretion. NewU holds the postsecondary record for these classes.

Attendance

Students in college in high school classes follow Attendance. Students enrolled through Dual Academy Flex follow the online and Flex track in that policy.

Tuition and Payment

The partner institution sets and collects the price a high school student pays for NewU college classes, under its agreement with NewU, and its terms govern payment and refunds for those enrollments. NewU's published tuition and fees apply to students who enroll with NewU directly.

Records and Parent Access

Rights in NewU education records belong to the student at any age. A parent or legal guardian of a minor student in college in high school classes may see the student's NewU grades and attendance on either of two bases: the student's FERPA release, collected at enrollment, which the student may revoke; or the parent's written statement that the student is the parent's tax dependent. NewU also shares grades and attendance with the partner school where the student is enrolled. See Privacy and Education Records.

Students Under 18

The Protection of Minors policies govern every NewU class, platform, and setting that includes a student under 18, including Comingled Minor and Adult Student Environment. Parents and legal guardians of minor students receive the Protection of Minors Policy at enrollment.

Accommodations

A student in college in high school classes who needs a disability accommodation in a NewU class requests it under Accommodations for Students with Disabilities. The accommodation takes effect in the NewU class when the Registrar's Office confirms it to the faculty member.

Admission to a NewU Degree

Passing one college in high school class through a partner institution qualifies the student for admission to NewU. See Admission After College in High School Classes.

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1.12 Tuition, Fees, and Refunds

Applies to: students and admitted applicants. Approved by: the President. Reviewed: October 2026.

NewU keeps tuition, fees, and other charges low so that students can minimize or avoid debt. This policy sets out what NewU charges, when payment is due, and how cancellation, withdrawal, and refunds work. Questions go to the Finance Office ([email protected]).

Tuition and Fees, 2026-2027

• Enrollment Intent Deposit: $300, for first-year and transfer students only, applied to the first semester bill. Non-refundable.
• Application fee: $0. NewU sets an application fee of $150 and waives it for all applicants.
• Tuition Freeze: a student's posted tuition does not go up for the three years of the degree.

For college in high school classes, the partner institution sets the price (see College in High School Classes).

Payment Deadlines and Payment Plans

All payments are due in full 30 calendar days before the start of each semester. Enrolled students may request a 0% interest monthly payment plan. NewU reviews each request and approves or denies it at its discretion, based on the circumstances of the request, NewU's financial position at the time, and other factors NewU considers.

Late Payments and Holds

Payments not received by the due date incur a late fee of 1.5% per calendar month, applied to the base (principal) amount only. NewU applies partial payments to late fee balances first. NewU may unenroll a student who is more than 30 days overdue.

A past-due account carries a financial hold that restricts future registration and NewU services until the account is settled. A hold never blocks a transcript or diploma: NewU never withholds a transcript or diploma for unpaid charges, for any student (see Transcripts, Credit Transfer, and Diploma Issuance).

Students Using VA Education Benefits

Consistent with 38 U.S.C. 3679(e), NewU does not charge a late fee, deny access to classes, libraries, or other NewU facilities, or require a student to borrow additional funds because a VA payment under Chapter 31 or Chapter 33 has not yet arrived. This protection runs from the date the student provides a Certificate of Eligibility (or, for Chapter 31, a VA authorization) until VA pays or 90 days after NewU certifies tuition and fees, whichever comes first. NewU may require the student to submit the Certificate of Eligibility, a written request to use the benefit, and any other information needed to certify enrollment, and may charge any difference between the amount the student owes and the amount VA pays.

Three-Day Cancellation

A student who cancels the NewU Enrollment Agreement in writing within three business days of signing it receives a full refund of all tuition and fees paid. The Enrollment Intent Deposit is non-refundable.

Withdrawal and Refunds

A student withdraws from NewU by written notice to the Registrar's Office; an email to [email protected] is enough. The withdrawal takes effect on the date NewU receives the notice. NewU requests an exit interview, but it is not required (see Withdrawal from NewU).

• Notice received at least 30 days before a semester starts: NewU refunds 100% of the tuition and fees the student paid for that semester.
• Notice received less than 30 days before a semester starts, or during a semester: the student owes the full tuition and fees for that semester, whether or not the student attends, and owes nothing for later semesters.

Deposits, late fees, payments for prior billing periods, and payments for services already rendered or goods already received are non-refundable, except as the Veterans Affairs refund rule below or the Return of Title IV Funds rules require. Refunds carry no interest.

Veterans Affairs Refunds

Under 38 CFR 21.4255, if a VA beneficiary withdraws from NewU, NewU issues a refund under this policy, except that the amount charged for tuition, fees, and other charges for a portion of the class does not vary more than 10% from the exact pro rata portion of those charges that the length of the completed portion of the class bears to its total length. The exact proration is the ratio of the number of days of instruction the student completed to the total number of instructional days in the class. An established registration fee of up to $10 is not prorated; where the registration fee is more than $10, the amount above $10 is prorated.

Return of Title IV Funds (R2T4)

Applies only to students who receive federal student aid under Title IV.

Title IV funds include the Federal Pell Grant, Federal Direct Loans (subsidized and unsubsidized), Federal PLUS Loans, and other Title IV programs. They are awarded on the assumption that the student attends for the entire semester (payment period). Under 34 CFR 668.22, when a Title IV recipient withdraws during a semester, NewU calculates how much of the aid the student earned; the unearned portion goes back to the U.S. Department of Education. NewU does not offer programs or classes in modules.

Payment deadline and other sources. For the part of the semester charges that Title IV aid covers, the payment deadline is the date the funds are scheduled to be disbursed, provided the student has completed all FAFSA, verification, and loan origination steps in time for normal disbursement. The R2T4 calculation applies only to the federal aid portion of the account; the refund rules above apply to any part paid from other sources, including out-of-pocket payments, scholarships, and private loans.

Withdrawal date.

• Official withdrawal: the date the student begins NewU's withdrawal process or otherwise notifies the Registrar's Office ([email protected]) of the intent to withdraw, whichever is earlier. If there are several such dates, NewU uses the earliest, unless a later date of attendance at an academically related activity is documented.
• Unofficial withdrawal: for a student who stops attending without notice, the midpoint of the payment period, unless NewU can document the student's last date of attendance at an academically related activity, in which case NewU uses that date.
• Date of determination: for an official withdrawal, the withdrawal date or the date of notification, whichever is later; for an unofficial withdrawal, the date NewU becomes aware that the student stopped attending. The 45-day return deadline runs from the date of determination, not the withdrawal date.

Earned aid. The percentage earned is the number of calendar days completed in the payment period divided by the total number of calendar days in the payment period. Scheduled breaks of five or more consecutive days, and days on an approved leave of absence, are excluded from both numbers. A student who completes more than 60% of the semester has earned 100% of the aid; at 60% or less, the unearned portion is returned.

Approved leave of absence. A leave of absence is not a withdrawal if it meets 34 CFR 668.22(d): the student followed NewU's published leave request process; the leave does not exceed 180 days in any 12-month period; there is a reasonable expectation that the student will return; and NewU assesses no additional charges during the leave. A student who does not return from an approved leave is treated as withdrawn as of the date the leave began.

Order of return. Unearned funds are returned in this order:

1. Federal Direct Unsubsidized Loan
2. Federal Direct Subsidized Loan
3. Federal Direct PLUS Loan
4. Federal Pell Grant
5. Federal Supplemental Educational Opportunity Grant (FSEOG)
6. Other Title IV funds, if any

Responsibilities. NewU calculates the R2T4 amount, returns unearned funds to the U.S. Department of Education within 45 days of the date of determination, and notifies the student of any resulting balance owed to NewU. The student repays any Title IV funds the student must return and pays any balance owed to NewU because of the return.

Post-withdrawal disbursements. A student who earned more aid than was disbursed before withdrawal may be eligible for a post-withdrawal disbursement. Grant funds are disbursed within 45 days of the date of determination. For loan funds, NewU notifies the student (or the parent, for a parent PLUS loan) in writing within 30 days of the date of determination, offering the disbursement and explaining the right to accept all or part of it. The student or parent must respond within 14 days of the notice; if NewU receives an affirmative response in that window, it disburses the loan funds within 180 days of the date of determination. Without a response, NewU is not required to make the disbursement.

Notice. A Title IV recipient who withdraws receives written notice, usually by email, of the R2T4 result, the amount of Title IV aid returned, and any balance owed to NewU or to the U.S. Department of Education.

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1.13 Financial Aid

Applies to: applicants and students. Approved by: the President. Reviewed: October 2026.

NewU's tuition and fees are priced to be affordable, and its three-year degree lowers the total cost further. Some students still need help to enroll or to finish. This policy sets out the aid NewU offers, how to apply, and how NewU decides. The Finance Office ([email protected]) administers financial aid.

Federal Student Aid and the Pell Match

NewU is accredited by MSCHE. NewU does not participate in federal student aid (Title IV) programs and is not listed on the FAFSA. NewU matches the Pell Grant a student qualifies for with a NewU scholarship, and matches or exceeds other federal grants or assistance through NewU institutional scholarships. A student who would qualify for federal loans can use NewU's 0% interest monthly payment plan instead. Students who receive Title IV aid must also meet Satisfactory Academic Progress (SAP) for Federal Financial Aid.

Forms of Aid

• Pell match grant. A NewU grant equal to the Pell Grant the student qualifies for, as described above.
• NewU Institutional Scholarships. Need-based scholarships set by family income, as NewU determines at its sole discretion. They apply only to tuition and never exceed the posted tuition for the period.
• Sponsored Scholarships. Awarded when gifts or grants to NewU fund them. NewU follows any legally valid donor restrictions. They apply to tuition only and may carry the name the donor chooses.
• Sponsored Stipends. Awarded when gifts or grants to NewU fund them, under any legally valid donor restrictions. They may pay NewU fees, living expenses, books and educational supplies, or other eligible educational expenses, but not NewU tuition, and may carry the name the donor chooses.
• 0% interest monthly payment plans. Available on request, as described in Tuition, Fees, and Refunds.
• VA education benefits. For eligible students in on-campus programs (see below).
• Outside scholarships. NewU lists free outside scholarship searches on its Outside Scholarships page. NewU does not award these scholarships and is not affiliated with their donors.

NewU may offer other aid to admitted and enrolled students at its discretion.

How to Apply

Students apply through the form on the NewU Financial Aid page by sending one of the following:

• a FAFSA Submission Summary;
• the family's IRS Form 1040 for the prior year; or
• for students without either document, the College Board CSS Profile (NewU school code 1491), which offers a document-free option.

NewU accepts applications from admitted applicants until 30 calendar days before the start of their studies. A student admitted less than 30 calendar days before classes start may apply within 7 calendar days of admission. Enrolled students may submit an amended application until 30 calendar days before the start of each academic year.

How NewU Decides

NewU sets need-based scholarships by family income for the prior calendar year, using these tiers, which follow the U.S. Department of Education's family income tiers: $0 to $30,000; $30,000 to $48,000; $48,000 to $75,000; $75,000 to $110,000; and $110,000 and above. NewU aims for a net price for tuition, fees, and books as close as possible to what the Department of Education's methods would produce. When a FAFSA Submission Summary is available, NewU may use its more detailed information, including the Student Aid Index (SAI), to set the net price or to offer a payment plan.

NewU issues a financial aid offer letter within a week of receiving a complete application. The offer is itemized so that students and families can review it in full and line by line. Aid decisions never rest on any characteristic protected under Anti-Discrimination and Equal Opportunity.

Priority Deadlines

NewU awards scholarships on a rolling basis and observes three priority deadlines each year: December 1, March 1, and June 1. After these dates, NewU awards remaining aid on a first-come, first-served basis as seats fill. Once NewU issues a financial aid offer letter, the student pays the Enrollment Intent Deposit by the applicable priority deadline to secure the seat and lock in the scholarship offer. The Student Catalog lists the deposit and scholarship deadlines for each entry term. NewU may extend any financial aid or enrollment deadline at its discretion.

Order in Which Aid Applies

1. Federal aid the student receives, such as VA education benefits and, for students who receive it, Title IV aid.
2. State aid, such as grants and scholarships from the District of Columbia, Maryland, Virginia, or other states. Students report state aid to the Finance Office as soon as they learn they qualify for or will receive it.
3. External scholarships and grants from private organizations, foundations, or community groups. Students report them to the Finance Office as soon as they learn they qualify for or will receive them.
4. NewU institutional aid, applied last.

Total aid never exceeds the student's cost of attendance. When a student receives aid from several sources, NewU may adjust awards to comply with federal and state rules and NewU policy.

Appeals and Exceptions

A student who believes the aid offer does not reflect the family's financial situation may appeal in writing to the Finance Office ([email protected]), with any supporting documents. The Finance Office answers in writing. A student who disagrees with the answer may use Student Grievance and Appeals. The EVP and Chief Financial Officer (CFO) or the President may approve exceptions to this policy. The President approves changes to it.

Confidentiality

Financial documents, NewU's evaluation, and award decisions are confidential and available only to personnel with a legitimate administrative need. NewU does not disclose to faculty or classmates that a student receives aid, and aid status does not appear on academic records or transcripts. Aid records are kept under Records Retention and Destruction.

VA Education Benefits

NewU is approved by the U.S. Department of Veterans Affairs (VA) to accept VA education benefits for all programs offered on campus (VA facility code 3-1-0003-09). VA education benefits apply to on-campus enrollment. Eligible veterans, service members, spouses, and dependents can use:

• Post-9/11 GI Bill® (Chapter 33), including transferred benefits
• Fry Scholarship (Chapter 33)
• Montgomery GI Bill (Chapter 30)
• Selected Reserve GI Bill (Chapter 1606)
• Veteran Readiness and Employment, VR&E (Chapter 31)
• Survivors' and Dependents' Educational Assistance, DEA (Chapter 35)

Depending on eligibility, VA benefits may cover tuition and fees and provide a monthly housing allowance and a books-and-supplies stipend. NewU's School Certifying Official helps each student request a Certificate of Eligibility from VA and certifies enrollment. NewU's need-based scholarships apply toward any balance VA benefits do not cover. Students using VA benefits have the protections in Students Using VA Education Benefits and the Veterans Affairs refund rule in Tuition, Fees, and Refunds. More information about VA education benefits is available on the official U.S. government website, va.gov.

GI Bill® is a registered trademark of the U.S. Department of Veterans Affairs (VA).

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1.14 Academic Program

Applies to: students. Approved by: the President. Reviewed: October 2026.

NewU is a teaching institution. Its bachelor's degree takes three years instead of four: students earn the traditional 120 credits in six 18-week semesters, taking 5 classes and 20 credits each semester, with no summer or weekend classes. Full-time enrollment is 12 to 20 credits a semester, at the same tuition and fees; the three-year plan is 20 credits a semester. This policy sets out the degree structure, graduation requirements, grading, the credit hour, and internship credit.

Degrees and Majors

NewU offers five majors, each leading to a Bachelor of Arts (BA) or a Bachelor of Science (BS):

• Bachelor of Arts in Psychology and Human Behavior
• Bachelor of Arts in Entrepreneurship
• Bachelor of Arts in Creativity and Innovation Leadership
• Bachelor of Science in Sustainability (STEM)
• Bachelor of Science in Computer and Data Science (STEM)

Every major is offered on campus, online, or hybrid, with the same faculty, syllabus, learning outcomes, and graduation requirements (see Academic Calendar and Instructional Time). Students do not need to declare a major until the end of the first year. The Student Catalog lists the classes and learning outcomes for each major.

Curriculum

Every NewU degree requires:

• the NewU General Education (core) curriculum, 40 credits, scheduled in the first year; NewU enrolls each first-year student in these classes automatically;
• all required classes for the major, 40 credits;
• at least 16 credits of major-specific electives; and
• at least 24 credits of cross-major electives.

Graduation Requirements

To graduate, a student:

• earns at least 120 credits, each by completing a class with a passing grade;
• earns at least 25% of the credits required for the degree in residence at NewU;
• completes the requirements of the registered major; and
• has a cumulative GPA of 2.0 or higher.

Only credits and grades received before the graduation date count toward graduation eligibility and the cumulative GPA. Students return all NewU property before their graduation date. NewU holds Commencement once a year, at the end of the spring semester. NewU never withholds a diploma or transcript for unpaid charges (see Transcripts, Credit Transfer, and Diploma Issuance).

Grading Scale

Every NewU class uses this scale (Populi, 2026-2027), including college in high school classes. NewU reports GPA on a 4.0 scale.

There is no D-. A class designated Pass/Fail is graded P (60 and above) or F (below 60). Any grade other than F or I is a passing grade. Populi calculates GPA from the grade points above; an I counts as 0.0 until the final grade replaces it. When a student repeats a class, only the highest grade counts toward GPA, and both attempts stay on the transcript.

Incomplete Grades

A faculty member may give an I (Incomplete) when a student has not submitted all required work for the class, or is facing extenuating circumstances such as a family emergency or a personal medical or mental health event, or for another reason the faculty member, using sound judgment and acting in good faith, finds warrants a chance to earn a passing grade or improve the grade. A student who receives an I has between 1 and 4 calendar weeks to complete the work the class reasonably requires. The faculty member enters the final grade promptly after the student submits the work, or when the extension ends, whichever comes first.

Grade Reporting

Students receive grades in Populi within a reasonable time after submitting tests, assignments, and other work, as the faculty member sets. Each student receives a mid-semester progress report once per class each semester, and semester grades no later than two weeks after the end of each semester. Transcripts show letter grades and GPA. A student who disputes a grade raises it first with the faculty member, then under Student Grievance and Appeals.

Credit Hour

Consistent with the Federal Student Aid Handbook, NewU defines one credit hour as 50 minutes of direct faculty instruction per week (a contact hour) plus 120 minutes of student work outside class per week, such as homework, research, and reading (a homework hour), over 15 weeks. The definition applies to every NewU class in every modality.

The length of each class session depends on the class's credit hours, its meeting schedule (for example, Monday and Wednesday, or Tuesday and Thursday), and any holidays that fall on class days. NewU counts the class sessions and distributes the required contact and homework hours across them so that each class meets the minimum for its credits.

The Chief Academic Officer (CAO) is responsible for ensuring that every credit hour NewU awards meets this definition. The CAO or a designee reviews and approves every syllabus before the semester, and faculty correct any issue before the semester starts. For students on the online and Flex track, who may attend by recording, the CAO documents how the class meets this definition (see Attendance).

Internship Credit

A student who finds an internship can earn academic credit for it by enrolling in the major's Internship / Practicum / Capstone Project class for 4 credits. To earn the credit:

• the student submits an evaluation from the internship supervisor that is at least satisfactory, the equivalent of a passing grade;
• the internship is in the area of the student's program and uses the skills and knowledge the student is gaining; and
• the internship lasts at least two months.

How NewU Evaluates Its Programs

NewU assesses student learning in every class and program with the same learning outcomes, rubrics, and assessment instruments in every modality. Each term, NewU reviews class completion, retention, satisfactory academic progress, grade distributions, and learning outcome attainment, compares results across modalities, and uses the findings to improve class design, faculty training, and student support.

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1.15 Academic Calendar and Instructional Time

Applies to: students and faculty. Approved by: the President. Reviewed: October 2026.

This policy explains how NewU's academic year is organized, when and how classes meet, and how instructional time supports the credit NewU awards.

Academic Calendar

NewU publishes the Academic Calendar for each academic year. It lists orientation, the first and last day of each semester, breaks, the holidays with no classes, Commencement. All dates are in Eastern Time. NewU announces any material change to the published calendar in writing.

Semesters

The academic year has two semesters, fall and spring, and each semester runs 18 weeks. There are no summer or weekend classes. New students complete a required orientation before their first semester: four days before a fall semester, one day (Saturday) before a spring semester. Commencement takes place once a year, at the end of the spring semester.

Class Schedule

NewU classes meet only Monday through Thursday, mostly from 10 am to 3 pm Eastern Time. A typical class carries 4 credits and meets twice a week for 90 minutes. Full-time students take 12 to 20 credits a semester; the three-year plan is 5 classes, 20 credits, each semester. NewU's administrative offices are open Monday through Thursday, 10 am to 5 pm, and campus facilities are available to students, faculty, and staff 24 hours a day throughout the year, including holidays.

Instructional Time

Every class provides at least the instruction and outside work its credits require under the Credit Hour definition. NewU's longer semesters and class sessions keep the same total amount of instruction and homework time as a standard semester while reducing the number of semesters. When a holiday falls on a class day, the class's required hours are distributed across its remaining sessions.

On Campus, Online, or Hybrid

• On campus. All classes in person at NewU's campus, 1400 16th Street NW, Washington, DC 20036.
• Online. All classes over the internet, in the same class meetings and on the same schedule as on-campus students. Online students attend each session live or watch the class recording (see Attendance).
• Hybrid. At least 20% of classes on campus and up to 80% online. Each class is either fully in person or fully online.

All three share the same Monday through Thursday schedule, the same faculty, the same syllabus for each class, the same graduation requirements, and the same learning outcomes. Students choose a modality at enrollment and may change it for a future semester by request to the Registrar's Office ([email protected]). VA education benefits apply to on-campus enrollment (see Financial Aid). Virtual Learning Environment Safety sets out the rules for online classes.

Closures and Makeup

When NewU closes the campus for weather, public health, a utility failure, or another emergency, on-campus classes meet online for the period of the closure where feasible. If online instruction is also disrupted, the Chief Academic Officer (CAO) schedules makeup sessions that preserve the instructional time required for the credit awarded. NewU announces closures by email and through its text line, 202.968.1005, which is also its emergency broadcast number.

Partners for College in High School Classes

Students in college in high school classes follow the NewU Academic Calendar in those classes. Partner institutions coordinate their calendars with NewU's under their agreements with NewU, including the Master Agreement with Dual Academy Corp.

Records

The published calendar, its amendments, and records of closures and makeup sessions are kept under Records Retention and Destruction.

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1.16 Adding Classes

Applies to: students. Approved by: the President. Reviewed: October 2026.

This policy explains how a student enrolls in classes for a semester.

Registration

NewU enrolls every first-year student in the required core classes automatically. After the first year, students register for classes each semester in Populi, with help from academic advising and their success coach. A financial hold on a past-due account blocks registration until the account is settled (see Tuition, Fees, and Refunds).

Adding a Class

A student may add a class within 7 calendar days of the class start date, in Populi or by request to the Registrar's Office ([email protected]). This is the only change a student can make to class enrollment during a semester. A student enrolled in a class receives the grade earned in it, including a failing grade under Attendance.

Charges

Tuition and fees are charged by the semester. Adding a class does not change them, and refunds follow Tuition, Fees, and Refunds. For college in high school classes, the partner institution's terms govern charges and refunds.

Records

The Registrar's Office records every change in Populi. For a student using VA education benefits, NewU's School Certifying Official reports the change to VA.

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1.17 Attendance

Applies to: students. Approved by: the President. Reviewed: October 2026.

Students take part in every class, seminar, workshop, and other session they registered for, whether or not they are attempting to earn credit for it. This policy sets the on-campus track, which applies to full-time on-campus students and to the in-person classes of hybrid students, and the online and Flex track, which applies to online students, to the online classes of hybrid students, and to students enrolled through Dual Academy Flex.

On-Campus Track

• Full-time on-campus students attend in person. Hybrid students attend their in-person classes in person.
• A student on this track must attend at least 80% of the sessions of each class to complete it, provided the student meets all other requirements for passing. A student who attends less than 80% receives an automatic failing grade and no full or partial credit for the class.
• Watching a class recording does not count as attendance on this track.

Online and Flex Track

• Online students, and Flex students (high school students taking college classes through Dual Academy Flex), may attend each class session live or watch the class recording, and may mix the two during a semester.
• No attendance minimum applies, and the automatic failing grade for missed sessions does not apply. Credit rests on completing the graded work of the class by its deadlines.
• Every online class keeps regular and substantive interaction with the professor: each class session is taught live and recorded, and the professor gives feedback on graded work and answers students' questions.
• For withdrawal, refund, and financial aid purposes, NewU tracks an online student's attendance by academic engagement: attending a live class session, submitting graded work, taking an examination, or taking part in a team project or class discussion.
• The Chief Academic Officer documents the credit-hour equivalency for this track (see Credit Hour).

Absences and Make-Up Work

NewU does not distinguish between types of absences. Each professor marks a student present or absent, using judgment about the type of absence and the time of arrival or departure. There are no tardy or other categories. Professors consider in good faith, case by case, whether a student may make up work missed because of absences, and on what terms. A change to attendance requirements as a disability accommodation is decided under Accommodations for Students with Disabilities.

Attendance Records

Faculty take attendance at every class session in Populi, NewU's student information system. Only authorized administrators and the student's professors can enter, change, or view attendance records. A student may request a report of attendance records for any current or past class from the Registrar's Office ([email protected]). For a student in college in high school classes, NewU shares attendance with the partner school where the student is enrolled, and with a parent or legal guardian as Privacy and Education Records allows.

Unenrollment for Non-Attendance

NewU may unenroll a student who does not attend any session of the classes the student is enrolled in, or, in online classes, shows no academic engagement in them, for 30 consecutive calendar days. This does not apply to a student on an approved leave of absence, to a student with an exemption from the Chief Student Journey Officer, the President, or a person the President designates, or to Flex students.

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1.18 Academic Integrity

Applies to: students and faculty. Approved by: the President. Reviewed: October 2026.

NewU is an academic community whose purpose is the pursuit of knowledge, and that purpose depends on honest work. Every member of the community is responsible for honesty in academic work at all times. Every student follows this policy in every class and examination, on campus and online, including students in college in high school classes.

Violations

Any activity that has the effect or intention of interfering with education, the pursuit of knowledge, or the fair evaluation of a student's performance is prohibited. Violations include:

• Plagiarism: presenting another person's work, ideas, data, structure, or words as one's own without proper attribution, from any source (printed, online, AI-generated, or another student's), including submitting purchased or ghostwritten work, paraphrasing without attribution, and leaving out quotation marks where they belong.
• Cheating: using or attempting to use unauthorized materials, information, technologies, or help in an examination, quiz, assignment, or other assessment; communicating with another person during an assessment in a way the faculty member has not permitted; submitting work another person prepared; or preventing another student from using authorized help. Examples: using a cheat sheet in an examination, or altering a graded examination and resubmitting it for a better grade.
• Fabrication: inventing, falsifying, or altering data, sources, citations, or results; citing nonexistent articles; misrepresenting attendance, participation, or completion of academic activities; or forging signatures or documents.
• Unauthorized collaboration: working with others on an assignment, examination, or other assessment beyond what the faculty member has expressly permitted.
• Multiple submission: submitting, without prior permission, work already submitted to meet another academic requirement.
• Misrepresentation of academic records: misrepresenting, tampering with, or attempting to tamper with any part of a transcript or academic record, before or after coming to NewU, such as forging a grade change, tampering with computer records, or falsifying academic information on a resume.
• Facilitation: knowingly helping or attempting to help another student commit a violation, such as working together on a take-home examination.
• Unfair advantage: attempting to gain an unauthorized advantage over other students, such as gaining or giving unauthorized access to examination materials, obstructing another student's work, or lying about a need for an extension.

Using AI tools in a way a class does not permit is a violation; Artificial Intelligence and Generative Tools sets out the rules.

Responsibilities

Students understand the integrity standards of each class, including its rules on AI tools, citation, and collaboration. A student who is unsure whether an action is permitted asks the faculty member before submitting the work.

Faculty state clear integrity standards in each syllabus, including the class rules for student use of AI tools and whether the class uses remote proctoring; design assessments that reflect those standards; remind students of them before significant assessments; and report suspected violations under the procedure below. Online examinations run in Populi, with Populi’s built-in proctoring where the syllabus calls for it, at no additional charge.

Procedure

1. Faculty review. The faculty member who suspects a violation reviews the work and the evidence, documents the concern in writing, and notifies the student in writing. The student may respond in writing or in a meeting with the faculty member.
2. Faculty determination. After hearing from the student, the faculty member decides: no violation, a minor violation, or a material violation. The faculty member handles a minor violation with an academic consequence on the affected assessment (such as a zero, or a redo at a reduced grade) and sends a written record to the Chief Academic Officer (CAO) for the student's file. The faculty member refers a material violation to the CAO.
3. CAO review. For a material violation, the CAO reviews the record, may interview the student, the faculty member, and other witnesses, and issues a written decision. Outcomes include failure on the assessment, failure of the class, academic probation, dismissal, and referral to Student Discipline where conduct beyond academic integrity is also at issue.
4. Appeal. The student may appeal the CAO's decision under Student Grievance and Appeals.

Consequences and Repeat Violations

• A proven and documented instance of plagiarism may lead to academic probation for the following semester and to mandatory academic advising (see Academic Standing).
• Plagiarism in a senior thesis or capstone project results in cancellation of that work, no recognition of the credits attempted for it, and/or academic probation.
• A repeat violation is treated more seriously than a first one, and the CAO considers prior documented violations. Repeated proven and documented instances of plagiarism may lead to unenrollment.

Records

Academic integrity files are education records kept under Records Retention and Destruction. Records of minor violations stay in the student's academic file; records of material violations decided by the CAO or on appeal stay in the student's disciplinary file.

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1.19 Artificial Intelligence and Generative Tools

Applies to: everyone (students and everyone acting for NewU). Approved by: the President. Reviewed: October 2026.

This policy sets expectations for the use of artificial intelligence (AI) and generative tools, including large language models, image, video, and audio generators, code assistants, and AI-assisted research tools, in NewU's academic and administrative work. It applies in every NewU class, including college in high school classes; a partner institution's own AI policy applies to its students in addition.

Students

• Each faculty member states in the syllabus the class rules for student use of AI tools, and students follow them. An assignment may set different rules for that assessment; where the syllabus and an assignment differ, the assignment controls. Where neither addresses AI, no AI use is permitted in submitted work.
• Where AI use is permitted, the student discloses the tool, the prompts or inputs that produced material parts of the work, and the student's own contribution, in the way the faculty member specifies.
• Submitting AI-generated content as one's own work where AI use is not permitted, or without the required disclosure, is plagiarism. Using AI to produce misleading citations, fabricated sources, or false data is fabrication. Using AI to bypass the purpose of an assessment, such as having AI write a response meant to show the student's own reasoning, is cheating. These are handled under Academic Integrity.
• Students do not submit class recordings, transcripts, slides, assessments, or other class materials to any AI tool for training, indexing, or reproduction (see Acceptable Use of University Systems).

Faculty

• Faculty may use AI tools to prepare teaching content such as lesson plans, sample problems, scaffolding materials, slides, and examples. They are responsible for the integrity, accuracy, and appropriateness of any AI-generated content they use, and disclose in the syllabus or class materials where instructional content was substantially generated by AI.
• Faculty do not use AI tools to assign grades or to decide the credit any student work earns. Grading judgment stays with the faculty member.
• Faculty state the class rules for student AI use in each syllabus (see Faculty Responsibilities).

Staff and Others Acting for NewU

Employees, contractors, and volunteers may use AI tools to support administrative work and remain responsible for the compliance, quality, accuracy, and fidelity of everything they deliver. They do not delegate to an AI tool any decision that requires human judgment, including admission, financial aid, disciplinary, employment, and grading decisions.

Data Protection

No one enters a student's education records, or personally identifying information of any minor student, into an AI tool that does not operate under a data processing agreement with NewU. The IT office ([email protected]) keeps the list of approved AI tools and the kinds of information allowed in each. NewU never uses class recordings to train AI or machine learning models.

Records

Records of approved AI tools, data processing agreements, and AI-related incidents are kept under Records Retention and Destruction.

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1.20 Accommodations for Students with Disabilities

Applies to: students and applicants. Approved by: the President. Reviewed: October 2026.

NewU provides access and equal educational opportunity to all students, including students with disabilities, and does not discriminate on the basis of disability. NewU provides reasonable accommodation for a student's known disability so that the student has an equal opportunity to take part in NewU academic and extracurricular programs, activities, and services, as Section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act of 1990, as amended, and the District of Columbia Human Rights Act require. Admission decisions do not consider disability.

Definitions

• Disability: a physical or mental impairment that substantially limits one or more major life activities, a record of such an impairment, or being regarded as having such an impairment.
• Reasonable accommodation: a modification or adjustment that gives a qualified student with a disability full access to NewU programs without fundamentally altering the purpose or requirements of a class or program. NewU decides accommodations individually, based on the functional limitations of the impairment, and they may vary from class to class with its content and format. Accommodations are meant to be effective and reasonable; they may not be exactly what the student requests.
• Appropriate documentation: a current and comprehensive written evaluation or report from a clinician qualified to make the diagnosis. It includes a diagnosis, identifies the student's specific functional limitations in the academic setting, and shows substantial limitation compared to most people. It may include clinical and social histories from parents, counselors, and specialists, and follows well-established practice in the relevant field.

Requesting an Accommodation

A student who seeks an accommodation self-identifies in writing to the Registrar's Office ([email protected]), which assesses requests and determines accommodations. A student may do so at admission or at any time during studies. The student provides appropriate documentation at the student's own expense; the office may ask for more information if the documentation does not support the disability or the accommodations requested.

Decision

The Chief Student Journey Officer (CSJO) reviews the documentation and determines accommodations through an interactive process with the student, consulting the Chief Academic Officer and faculty where that helps decide how best to accommodate the student in a particular class. The CSJO issues a written decision within a reasonable time after receiving complete documentation. An approved accommodation plan states the accommodations, the classes they apply to, the period they cover, and any conditions.

Examples of Accommodations

Accommodations depend on the disability and the student. Examples include:

• extended time on examinations and timed assignments;
• a reduced-distraction testing environment, including for online and proctored assessments;
• note-taking support, captions, or transcripts of live sessions;
• adaptive technology, including screen readers, speech-to-text, and approved AI assistive tools;
• a modified assignment format that does not alter the academic standard of the assessment; and
• authorized absences for disability-related medical appointments.

Putting Accommodations in Place

A student approved for accommodations authorizes the Registrar's Office to inform the appropriate faculty. Faculty provide accommodations only after receiving an email from the Registrar's Office listing the approved accommodations; this applies to college in high school classes as well. Each semester, the student requests individual examination accommodations from the Registrar's Office. Students are encouraged to introduce themselves to their professors to discuss their needs. A plan may be changed at any time at the student's request or when the student's needs change, and material changes are confirmed in writing.

Responsibilities of Faculty and Staff

Faculty and staff ensure equity and access in their programs and classes. Approved accommodations do not fundamentally alter the academic requirements essential to a class or program of study, or licensing prerequisites. Students with disabilities meet the same performance standards for the degree as other students: accommodations provide equal access, not an unfair advantage.

Confidentiality

Disability documentation is confidential. It stays with the Registrar's Office and is used only to determine reasonable accommodations. Faculty share accommodation information only as needed to provide the accommodations, and do not discuss a student's disability or accommodations in front of the class, in the presence of other students, or with faculty or staff not directly involved.

Disagreements

A student who believes NewU mishandled a request, denied a reasonable accommodation, or discriminated on the basis of disability may file a grievance under Student Grievance and Appeals or report discrimination under Anti-Discrimination and Equal Opportunity.

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1.21 Student Support Services

Applies to: students. Approved by: the President. Reviewed: October 2026.

NewU supports each student's academic, personal, and professional success throughout their studies, in every modality. For a question about a class, students go to their professor first, then to the relevant office (see Where to Send What).

Orientation

Every new student, including every new transfer student, completes NewU's required orientation before the first semester: four days before a fall semester, one day (Saturday) before a spring semester. Orientation covers access to Google Workspace and Populi, expectations, academic integrity, support contacts, study skills, and team building. Online and hybrid students attend separate first-day sessions on online logistics. On-campus and hybrid students learn to use Library of Congress resources during in-person orientation at the Library of Congress; online students receive the same instruction virtually.

Coaching for Success

Every student meets one-on-one at least once a month with a success coach, a professor who knows the student by name; online students meet by video. The meetings are required. They cover academic goals, study habits, time management, career development, and resilience, and help the student make steady progress toward graduation. Coaches document each session (date, topics, and action items) as part of the student's education record.

Coaches are not licensed mental health providers. When a student's needs go beyond coaching, the coach connects the student with appropriate resources. Coaches do not promise confidentiality they cannot keep: a coach who learns of suspected abuse or neglect of a minor reports it under Mandated Reporting of Child Abuse, Neglect, and Boundary Violations; a coach who learns that someone is in immediate danger calls 911; and a coach who learns of an academic integrity concern reports it under Academic Integrity.

Office Hours and Academic Advising

Each faculty member holds weekly office hours at published times, responds to student email within one business day, and gives academic advising to students in the class. Faculty may also meet students individually outside class time and office hours. Academic advising helps students with class selection, degree planning, and NewU's academic policies, and NewU regularly monitors each student's progress toward degree completion and career development.

Learning Teams and Tutoring

First-year students work in learning teams with classmates on projects, assignments, and some examinations, building communication, conflict resolution, time management, and learning skills. Teams meet after classes at times they set. NewU organizes tutoring to support learning, including faculty-led sessions and peer support that faculty assign where appropriate. Tutoring may be offered in some or all classes and for skills the curriculum develops, such as academic and creative writing and emotional intelligence. Tutoring may be optional or required in a class, but it earns no academic credit beyond the credits in the official class description.

Special Academic Advising

A student whose academic performance shows a need for it, or who has a proven and documented instance of plagiarism, takes part in mandatory academic advising, which may include individual progress checks and workshops. Mandatory advising continues for students on academic warning or probation (see Academic Standing).

Career Development

Career development workshops cover resume writing, interview preparation, and networking. Success coaches cover career development in the monthly meetings, and NewU offers career development resources and placement support to all students.

Well-Being

Resilience building workshops and individual support help students manage stress, develop coping skills, and build confidence. On-demand physical and mental health support is available 24 hours a day, 7 days a week, for non-emergency needs. In an emergency, call 911 first.

Other Services

• Financial aid and financial literacy: on demand through the Finance Office ([email protected]) and through workshops.
• Disability accommodations: see Accommodations for Students with Disabilities.
• Technical support: live help for Google Workspace and Populi during class hours, at [email protected] or by text to 202.968.1005, ideally before class day. Questions about how to use class tools go first to the professor.
• Library: see Library and Information Resources.

Student Organizations

NewU encourages students to take part in student organizations that build leadership, collaboration, and community. They include the Student Government Association (SGA), which represents student interests and helps shape NewU policies; interest clubs; and the NewU Innovation Center for Entrepreneurs (NICE), which offers resources and mentorship for students launching new ventures. NewU and Student Government engage online students and host events for all students.

Records

Coaching notes and advising records are confidential education records kept under Records Retention and Destruction.

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1.22 Academic Standing: Probation, Dismissal, and Readmission

Applies to: students. Approved by: the President. Reviewed: October 2026.

NewU identifies and supports students who need help early, places students on warning and probation when progress falls short, may dismiss students whose progress does not recover, and considers requests to return. Academic or disciplinary action is appropriate when academic performance or student behavior falls below an acceptable level before, during, or after enrollment. This policy also covers withdrawal from NewU and leave of absence.

Good Standing

A student is in good academic standing with a cumulative GPA of 2.0 or higher.

Academic Warning

A student in good standing whose cumulative GPA falls below 2.0 at the end of a semester receives a written academic warning. The warning names the concern, what the student is expected to do, and the support available. A warning is an early notice, not a sanction.

Academic Probation

A student on academic warning whose cumulative GPA is still below 2.0 at the end of the next semester is placed on academic probation. A proven and documented instance of plagiarism may also lead to probation for the following semester (see Academic Integrity). The probation notice sets out the conditions for returning to good standing, the academic plan, and the timeline, usually the next semester, and the student acknowledges it. Probation does not by itself deny enrollment for the next semester. A student returns to good standing when the cumulative GPA reaches 2.0.

Mandatory Advising

Students on academic warning or probation take part in mandatory academic advising, which may include individual progress checks and workshops. NewU may continue special advising for one more semester after a student returns to good standing.

Academic Dismissal

A student is subject to academic dismissal after:

• a second consecutive semester on probation without returning to good standing; or
• a semester GPA below 1.0.

The Chief Student Journey Officer (CSJO) issues academic warnings, probation notices, and dismissals in writing; a dismissal requires the President's concurrence. The notice states the basis, the effective date, and the right to appeal.

Other Grounds for Unenrollment

NewU may also unenroll a student who:

• has repeated proven and documented instances of plagiarism;
• is in material or repeated breach of the Code of Conduct or other NewU policies, through Student Discipline;
• is in material or repeated breach of financial obligations to NewU (see Tuition, Fees, and Refunds, including the protections for students using VA education benefits); or
• does not attend for 30 consecutive calendar days, as set out in Attendance.

Appeals

A student may appeal a warning, probation, dismissal, or unenrollment decision under Student Grievance and Appeals.

Withdrawal from NewU

A student who wishes to leave NewU without intending to return at a future time gives written notice to the Registrar's Office; an email to [email protected] is enough. The withdrawal takes effect on the date NewU receives the notice. NewU requests an exit interview, but it is not required. Until that date the student remains enrolled and responsible for academic and financial obligations. The financial effect of withdrawal is set out in Tuition, Fees, and Refunds, and the Return of Title IV Funds rules apply to Title IV recipients. A student who withdraws may return by written readmission request, as set out below.

Leave of Absence

A leave of absence lets a student interrupt studies for a compelling reason, such as a sustained medical or mental health condition that prevents attendance, or a personal matter requiring absence. The student submits a written letter with supporting documentation to the Registrar's Office, explaining why the student needs to interrupt studies at that time.

• A leave lasts one whole semester.
• The CSJO approves leave requests in advance of the requested semester; decisions do not apply retroactively.
• During an approved leave, the student is not expected to complete academic or other work or to be on campus, and does not have the benefits of student status.
• Until the student is told by email that the leave has been processed, the student remains registered and responsible for academic and financial obligations, including class work.
• A student who does not resume attendance when the leave ends is subject to unenrollment for non-attendance.

Readmission

NewU may, but is not obligated to, readmit at any time:

• a student who withdrew;
• a student who has fully paid all amounts owed to NewU, including tuition, fees, late fees, and other charges; or
• a student who shows, to NewU's satisfaction, that the original cause of dismissal or unenrollment no longer applies.

Readmission takes effect when the student submits a written readmission request to the Registrar's Office, NewU issues a written decision to readmit, and the student signs or renews all documents required of new and returning students, such as waivers, acknowledgments, and the Enrollment Agreement. Readmission may come with an academic plan for the first semester back.

Satisfactory Academic Progress (SAP) for Federal Financial Aid

Applies only to students who receive federal student aid under Title IV.

To remain eligible for federal Title IV aid (such as Pell Grants and Direct Loans), a student meets the SAP standards below, under 34 CFR 668.34. These standards are separate from academic standing above.

Evaluation. NewU evaluates SAP at the end of each payment period, that is, at the end of the fall semester and at the end of the spring semester.

Standards. A student meets all three:

• Cumulative GPA: no minimum at the end of the first semester (pace and maximum timeframe still apply); at least 1.5 at the end of the first academic year (two semesters); and at least 2.0 at the end of the third semester, when students are expected to have completed 60 credits, and at every later evaluation, consistent with NewU's graduation requirements.
• Pace: successful completion of at least 66.67% of cumulative credits attempted. For example, a student who attempts 30 credits passes at least 20.
• Maximum timeframe: completion of the degree within 150% of the published program length. For the 120-credit degree, a student may attempt up to 180 credits.

How credits count. Attempted credits include every class enrolled, including incompletes and failing grades. Completed credits are those with a passing grade. Transfer credits accepted toward the degree count as both attempted and completed. A repeated class counts as attempted each time, and only the highest grade counts toward GPA. An incomplete counts as attempted but not completed until a final passing grade is recorded; NewU then updates GPA and pace at the next evaluation.

Financial Aid Warning. A student who fails SAP for the first time is placed on Financial Aid Warning for one payment period (one semester). Aid continues during the warning period, and no appeal is needed.

Financial Aid Suspension. A student who does not meet SAP at the end of the warning semester has aid suspended and may appeal.

Appeals. A student appeals a suspension in writing to the Finance Office ([email protected]) with an explanation of extenuating circumstances (such as illness, a death in the family, or housing insecurity), any supporting documentation, and a plan for returning to good standing. If the appeal is approved, the student is placed on Financial Aid Probation for one payment period. If, when the appeal is granted, NewU determines that the student cannot reasonably meet SAP by the end of that payment period, NewU and the student develop an academic plan that, if followed, ensures the student meets SAP by a specific point in time.

Academic plan. The plan is created with an academic advisor, followed semester by semester until SAP is regained, and reviewed each semester to decide continued aid eligibility.

Reinstatement. Aid may be reinstated when the student meets SAP again or successfully follows the academic plan.

Notice. NewU notifies students in writing of their SAP status after each evaluation. Students on Financial Aid Warning, Financial Aid Probation, or an academic plan also receive written notice of their status, the terms of any plan, and the conditions for continued Title IV eligibility at the end of each payment period.

Records

Academic standing records are confidential and kept under Records Retention and Destruction.

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1.23 Transcripts, Credit Transfer, and Diploma Issuance

Applies to: students, former students, and transfer applicants. Approved by: the President. Reviewed: October 2026.

This policy sets out how NewU issues transcripts and diplomas and how credit transfers into and out of NewU.

Transcripts

NewU issues official transcripts for all NewU classes, including college in high school classes. The transcript shows each class with its letter grade or mark, the credits earned, and the cumulative GPA. Students request transcripts from the Registrar's Office ([email protected]). NewU fulfills requests for academic records within 3 business days.

NewU releases a transcript only at the student's written request or with the student's written consent, at any age, except where the law allows disclosure without consent (see Privacy and Education Records).

No Transcript or Diploma Holds

NewU never withholds a transcript or a diploma for unpaid charges, for any student, whatever the amount or age of the balance. NewU may still place a registration hold on a past-due account and pursue the balance under Tuition, Fees, and Refunds.

Credit Transfer into NewU

• Transfer students are pre-approved for admission and receive a free transfer credit analysis within 7 days of sending their college transcript, with no obligation to enroll (see Transfer Students).
• A transfer student may bring up to 90 credits toward the 120-credit degree.
• Any passing grade, meaning any grade other than F or I, qualifies a class for transfer. NewU evaluates the official transcript and, where needed, the class syllabus to decide how each class applies to the degree, and may award partial credit for a class that partly overlaps a NewU class.
• NewU may evaluate AP or IB high school classes a student submits for transfer credit, and decides at its discretion whether to award credit.
• NewU does not award academic credit for prior non-academic learning, life or work experience, or the results of competency-based assessments.
• At least 25% of the credits required for the degree must be earned in residence at NewU.

Credits from college in high school classes are NewU credits and appear on the NewU transcript (see College in High School Classes).

Credit Transfer from NewU

Other institutions accept NewU credits at their sole discretion. NewU supports students who wish to transfer by giving advice; standard documents such as transcripts, class syllabi, and enrollment verification; and communication with the receiving institution. If this support goes beyond what is reasonable and customary, NewU may charge a non-refundable time-and-materials transfer support fee set by the EVP and Chief Financial Officer (CFO).

Diplomas

NewU issues a diploma to every student who meets the graduation requirements in Academic Program, regardless of the status of any past-due account. NewU holds Commencement once a year, at the end of the spring semester.

Records

Transcripts, credit evaluations, and diploma records are kept under Records Retention and Destruction.

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1.24 Student Grievance and Appeals

Applies to: students. Approved by: the President. Reviewed: October 2026.

This policy gives students a fair and orderly way to raise concerns and to appeal NewU decisions. It covers:

• appeals of a decision applying an academic or other NewU policy to the student, including decisions under Academic Integrity, Accommodations for Students with Disabilities, Academic Standing, Financial Aid, and Student Discipline; and
• grievances alleging that an employee, faculty member, office, or other member of the NewU community, acting in an official capacity, violated a written NewU policy that directly affects the student. A grievance may be filed only where no other NewU procedure covers the matter.

Reports of discrimination, harassment, retaliation, and safeguarding concerns go to the Chief Student Journey Officer (CSJO) at [email protected] and follow Anti-Discrimination and Equal Opportunity, Anti-Harassment and Discriminatory Conduct, and Protection of Minors, which have their own procedures and appeals. Ethics and whistleblower reports go to [email protected] under Whistleblower and Non-Retaliation.

Step 1: Informal Resolution

Many concerns are best resolved by talking with the person closest to the issue: the professor for a class concern, the success coach for an advising concern, or the relevant office for anything else. A student with a grievance first contacts the person responsible for the matter within 20 working days of the event, or of when the student could reasonably have learned of it, and tries to resolve it informally. A student who is unsure how to proceed may ask the Registrar's Office ([email protected]) to identify the right person.

Step 2: Written Appeal or Grievance to the CSJO

The CSJO receives every written appeal and formal grievance at [email protected]. The student may send it from the student's NewU email address (or from the registered personal email address if the NewU account is suspended), send it by regular mail or courier, or deliver it in person.

• Appeal of a decision: the CSJO must receive it within 10 calendar days after the decision or incident. The CSJO answers in writing within 10 calendar days, and may extend that by up to 30 additional calendar days with written reasons to the student when the appeal is complex.
• Formal grievance: if the matter is not resolved informally within 15 working days of the first direct contact, the student may submit a written grievance within 20 working days of that contact. It states the policy allegedly violated, the facts and evidence, the remedy sought, and a short history of the attempts to resolve it informally. The CSJO meets with the student and with others as needed to establish the facts and try to resolve the matter, and issues a written decision to the student and the respondent.

The CSJO may make inquiries or meet the people involved to resolve an appeal. If force majeure delays a response, the CSJO tells the student in writing and estimates the delay; if force majeure prevents the CSJO from acting, the deadline extends for the duration of the force majeure or its immediate effects, or until another NewU official formally takes over the CSJO's duties. When the CSJO is absent for more than 10 calendar days, the CSJO authorizes another senior NewU representative to handle appeals for the period of the absence. An appeal or grievance concerning the CSJO goes directly to the President.

Step 3: Appeal to the President

A student who is not satisfied with the CSJO's decision may appeal to the President at [email protected] within 10 working days of receiving it, by submitting the decision and the original appeal or grievance. In a grievance, the respondent may appeal the same way. The President:

• may dismiss a grievance without further proceedings if there would be no policy violation even if the facts alleged were true;
• considers only matters included in the written appeal or grievance;
• gives the student and the respondent access to all documents the President considers;
• may hold a hearing, in person or by video, with the student and the respondent, at which the student may bring an adviser of choice and question the witnesses; the adviser may not speak, address the President, or question witnesses, and must not disrupt the hearing, and the President sets the format; and
• issues a final written decision within 30 calendar days of receiving the appeal, with findings of fact, the policy at issue, a conclusion on the merits, and any remedy, copied to the respondent where there is one.

The President's decision is final within NewU. The President may extend any time limit in this policy by up to 10 working days.

No Retaliation

No student is subject to unfair action or treatment by any NewU official for raising a grievance or appeal. Retaliation is prohibited under Whistleblower and Non-Retaliation.

Records

The Registrar's Office keeps a copy of each appeal or grievance, any amended version, each decision, and the final outcome, under Records Retention and Destruction.

Complaints to Outside Agencies

Students exhaust NewU's complaint procedures before using other avenues of redress, and may then seek redress from any relevant external agency. This does not limit a student's right to complain to NewU's accreditor or to its licensing agency:

• Middle States Commission on Higher Education (MSCHE), 1007 North Orange Street, 4th Floor, MB #166, Wilmington, DE 19801. www.msche.org.
• Higher Education Licensure Commission (HELC), the agency of last resort for student complaints: Higher Education Licensure Commission, 1050 First Street NE, Fifth Floor, Washington, DC 20002. Phone (202) 727-6436. TTY 711. Email [email protected].

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1.25 Substance Use and Smoke-Free Environment

Applies to: everyone (students and everyone acting for NewU). Approved by: the President. Reviewed: October 2026.

NewU is an alcohol-free, drug-free, and smoke-free environment that protects the health, safety, and welfare of its community. Each member of the community is responsible for their own actions. This policy applies to students, directors, officers, employees, contractors (including all faculty), and volunteers, and to guests and visitors, in every NewU setting: NewU's space at 1400 16th Street NW, online classes and other virtual NewU settings, and every NewU event or meeting, on or off campus.

Alcohol

• No one may manufacture, possess, distribute, dispense, sell, consume, or use any alcoholic beverage on property NewU owns, leases, or controls, or as part of any NewU event or meeting organized by a NewU representative, organization, or group, on or off campus.
• No one reports to work or performs services for NewU under the influence of alcohol, or consumes alcohol while on duty or during work hours.
• Consistent with District of Columbia law, advertisements of social events do not promote or describe the availability of alcoholic beverages, and do not promote the consumption of alcohol by minors.

Drugs and Cannabis

• No one may manufacture, distribute, dispense, sell, possess, consume, or use any illegal drug or substance on property NewU owns, leases, or controls, or as part of any NewU event or meeting, on or off campus.
• The unlawful use, possession, purchase, sale, or distribution of any illegal drug, being under its influence, and the misuse of legal drugs are prohibited on NewU premises and while performing services for NewU.
• These rules apply regardless of a person's age or the legal status of a substance under District of Columbia or state law. Cannabis use, including under any state recreational or medical authorization, is prohibited in every NewU setting.
• A prescription does not authorize impairment in class, at work, or at a NewU activity.

Smoke-Free and Vape-Free

Smoking and vaping are prohibited at all times in NewU's space, at NewU events, and on camera in online classes. This covers cigarettes, cigars, pipe tobacco, hookah, and electronic smoking devices such as e-cigarettes, e-cigars, and e-pipes, whatever substance is used. NewU posts signs in its space. Building rules and local law also apply, and NewU's standard is at least as strict.

Health and Safety First

In any case of intoxication, alcohol poisoning, or substance misuse, the first concern is the health and safety of the people involved. Anyone who needs medical help, or sees someone dangerously intoxicated, calls 911 first.

Reasonable Suspicion

A faculty or staff member who reasonably suspects that a student is under the influence in a NewU setting notifies the Chief Student Journey Officer (CSJO) at [email protected] and the President. NewU's response puts safety first and may include removing the student from the activity, seeking medical attention, notifying the parent or legal guardian of a minor student where the law allows, and a documented follow-up with the student.

Students

A student who violates this policy is subject to Student Discipline, which may lead to suspension or expulsion. NewU may refer illegal activity to law enforcement, and offers treatment and counseling resources where appropriate to support recovery and continued education. Student concerns about compliance with this policy go to the Registrar's Office ([email protected]).

Employees, Contractors, and Volunteers

To ensure compliance, NewU may conduct substance abuse screening:

• Pre-employment: as NewU requires for prospective employees who receive a conditional offer of employment; and
• For cause: on reasonable suspicion that an employee is under the influence of alcohol or drugs that could affect, or has adversely affected, the employee's job performance.

An employee who violates this policy, or who is convicted under a criminal drug statute for a violation occurring in the workplace, is subject to discipline up to and including termination, for a first offense, and may be required to take part satisfactorily in a drug abuse assistance or rehabilitation program. A contractor or volunteer who violates this policy is subject to the progressive response in Code of Ethics and Conduct, and a contractor's agreement governs how the engagement ends. Personnel concerns about compliance with this policy go to the HR office ([email protected]).

Compliance with Law

Every member of the NewU community and every NewU organization complies with local, state, and federal law on the possession, use, or sale of alcohol and controlled substances, on or off campus. Adult students never provide alcohol, cannabis, or tobacco to a minor student (see Comingled Minor and Adult Student Environment).

Records

Substance-related incident records are confidential and kept under Records Retention and Destruction.

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1.26 Open Expression

Applies to: everyone (students and everyone acting for NewU). Approved by: the President. Reviewed: October 2026.

As an institution of higher education, NewU is committed to free and open inquiry, deliberation, and debate in all matters. NewU gives all members of its community, including students, faculty, and staff, wide latitude to speak, write, listen, challenge, and learn.

The ideas of different members of the community will often and naturally conflict. It is for individual members, not for NewU as an institution, to judge the value of ideas, and to act on those judgments not by seeking to suppress speech but by openly and vigorously contesting the ideas they oppose. Helping members of the community engage with each other effectively and responsibly is part of NewU's educational mission.

Limits

Freedom to debate does not mean that anyone may say anything, anywhere. NewU prohibits expression that:

• violates the law;
• falsely defames a specific individual;
• is a genuine threat;
• violates Anti-Harassment and Discriminatory Conduct; or
• unjustifiably invades substantial privacy or confidentiality interests.

NewU may also reasonably regulate the time, place, and manner of expression so that it does not disrupt NewU's ordinary activities. Contracts (including faculty agreements), confidentiality agreements and policies, and professional conduct and personnel policies that regulate conduct, including speech, are not superseded by this policy. These are narrow exceptions to the general principle of free expression, and NewU does not apply them in a way that is inconsistent with its commitment to the free and open discussion of ideas.

Protecting the Expression of Others

Members of the community may criticize and contest the views of other members and of invited speakers, but may not obstruct or otherwise interfere with the freedom of others to express views they reject or even loathe. NewU promotes a lively and fearless freedom of debate and protects that freedom when others try to restrict it. Because it is essential to free inquiry, every member of the community shares responsibility for civil and respectful discourse.

Related Policies

Student rights and responsibilities are in Code of Conduct; faculty freedom in teaching and discussion is in Academic Freedom; limits on political campaign activity are in Political Activity; and classes that include minor students also follow Comingled Minor and Adult Student Environment.

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1.27 Use of University Name, Trademark, and Intellectual Property

Applies to: everyone (students and everyone acting for NewU), and anyone seeking to use NewU's names or marks. Approved by: the President. Reviewed: October 2026.

NewU regulates the use of its names, the names of its programs, and its trademarks and logos so that each use relates to NewU's educational mission and serves its goals. This policy also sets out how NewU respects the intellectual property of others and who owns work created at NewU. The President, or the President's designee, oversees the use of NewU's names and marks.

Names

• NewU Inc. is the legal name of the nonprofit corporation, used in contracts, tax filings, and other legal and formal documents.
• NewU University is the name under which NewU Inc. operates, used in public materials.
• NewU is the short form, used in ordinary communication.

Official Use

Anyone representing NewU in an official capacity uses NewU's names and marks as this policy sets out, and uses approved NewU stationery for official correspondence. NewU's names and marks may be used for any approved NewU academic program. Any other use, in connection with a non-academic program, activity, service, or product, needs the prior approval of the President. Requests go to [email protected]; student organizations submit requests first to the Chief Student Journey Officer for review. The President decides whether a proposed use relates to NewU's mission and whether its benefits outweigh its risks, and may approve it, with or without conditions, or decline it.

Use by Outside Entities

Outside entities may use NewU's names or marks on products or services only under a written license from NewU Inc.; requests go to the Office of the President. NewU may recognize a sponsor's contribution to a NewU program or activity, but no use may suggest that NewU endorses the sponsor's goods or services, and NewU's names or marks may not appear with an outside entity's name or logo without the President's prior approval.

Dual Academy Corp. uses the NEWU marks, including in the name NewU Dual Academy, under license from NewU Inc. under Schedule A (Trademark License) of the Master Agreement. Any use of NewU's marks outside that license requires the written consent of NewU Inc.

Personal Use

NewU's names and marks may not be used in connection with personal activities. They may not appear in any announcement, advertisement, publication, correspondence, or report about personal or non-NewU activities in a way that could suggest that NewU endorses or is responsible for any project, product, or service. Faculty and staff who keep personal websites, social media accounts, or outside publications identify personal statements as their own. Political activity follows Political Activity.

Domains, Accounts, and Handles

No one registers a domain name, social media handle, app store account, or email address that refers to NewU or a NewU program without the President's written approval. NewU accounts and credentials belong to NewU and are returned at the end of employment or engagement.

Copyright Compliance

Students, faculty, and staff download, possess, or store only lawfully acquired copyrighted materials, and use, adapt, distribute, or perform them only in ways consistent with United States copyright law, related case law, fair use, the rights of copyright holders, accepted academic standards and practice, and the terms of any applicable license, such as a software license. NewU does not tolerate unauthorized copying of copyrighted media, software, or class content, meets its own contractual obligations, and complies with copyright law. Copyright infringement notices go to [email protected].

Who Owns What

• NewU owns its names and marks, the curriculum and materials NewU creates, and all class recordings. Class recordings are created and owned by NewU Inc. and are not faculty work products.
• Faculty own the class materials they create, and grant NewU a perpetual, irrevocable, worldwide, royalty-free license to use, reproduce, distribute, display, perform, and create derivative works from them.
• Students own the original work they create in their classes. By enrolling, students grant NewU a non-exclusive, royalty-free license to use, reproduce, and display their work for accreditation, assessment of learning, instructional improvement, and internal training. Any other use, including any external or promotional use, needs the written consent of the student and, for a minor student, of a parent or legal guardian (see Photo, Video, and Recording).

NewU never uses class recordings for marketing or to train AI or machine learning models. Class sessions, recordings, transcripts, slides, assessments, and class materials are for the personal study of the students enrolled in the class; Acceptable Use of University Systems and Virtual Learning Environment Safety set out the rules on recording and sharing them. NewU seeks to put the intellectual property it owns to work for the good of society and shares the rights that result from licensing it equitably.

Enforcement

Anyone who suspects unauthorized use of NewU's names or marks reports it to [email protected], and NewU may act on the advice of counsel. A person who violates this policy may face discipline under NewU policy. A person who copies or uses copyrighted material without authorization may also face civil suit, criminal charges, penalties, and fines, and, depending on the facts, is responsible for their own defense and any resulting liability.

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1.28 Library and Information Resources

Applies to: students, faculty, and staff. Approved by: the President. Reviewed: October 2026.

NewU's operating model keeps a quality education affordable for students and families. In line with it, NewU relies on the resources of the Library of Congress and the DC Public Library for its students, faculty, and staff, and does not keep a physical library collection on campus. DC Public Library's central Martin Luther King Jr. Memorial Library is a few blocks from campus. Access to both libraries is free.

Access

NewU helps its students, faculty, and staff gain and keep access to the physical and electronic resources these libraries offer their members. During orientation, on-campus and hybrid students learn to use Library of Congress resources in person at the Library of Congress; online students receive the same instruction virtually. Whether they attend on campus or online, students can use library resources remotely over the internet, along with registration and advising.

Class Materials

NewU is digital-first. Faculty select the required readings and resources for each class, curate class materials, and give students access to them directly, so students do not buy textbooks. Faculty request teaching materials, software, e-books, articles, and case studies through the Registrar's Office ([email protected]).

Research Skills

Faculty teach research practice suited to college-level work, including evaluating sources, citation, and the ethical use of information, including AI-assisted research under Artificial Intelligence and Generative Tools.

Copyright and Accessibility

Use of library and licensed materials follows the terms of the applicable license and Use of University Name, Trademark, and Intellectual Property. A student who needs materials in another format requests it under Accommodations for Students with Disabilities.

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2.1 Faculty Engagement and Classification

Applies to: faculty. Approved by: the President. Reviewed: October 2026.

Classification

NewU engages all faculty as independent contractors. NewU has a 100% adjunct faculty model in support of its commitment to affordability for students. Each faculty member holds the title of Professor. There are no faculty ranks at NewU.

The engagement

• NewU engages each faculty member per class section, per semester, under a one-semester ICA. The ICA ends automatically on the last day of the semester shown in the Academic Calendar.
• No faculty member has an expectation of a future contract, and a regular, ongoing relationship of indefinite term is not contemplated. The President decides each semester whether to offer a new contract (see 2.6 Faculty Evaluation and Re-engagement).
• A faculty member is not an employee of NewU and receives no fringe benefits, health insurance, paid vacation, or other employee benefit. Employee-only policies, such as those on paid time off, leave, and work schedules, do not apply to faculty.
• The engagement is non-exclusive, provided no conflict of interest arises (see 2.4 Faculty Professional Ethics).
• NewU's concern is the result. NewU does not control how a faculty member performs the services. Faculty keep discretion over their methods, schedule, and place of work, except as needed to meet deliverables and instructional deadlines, such as teaching each class session at its scheduled time. NewU sets no work hours.

Pay

• NewU pays each faculty member at the rate stated in the ICA for each class section. The faculty member invoices at the end of each calendar month to [email protected], and NewU pays within 10 days of a properly submitted invoice.
• NewU may adjust payment for partially delivered or deficient services, as the ICA provides.
• NewU reimburses no expense unless the EVP and Chief Financial Officer (CFO) approves it in advance and in writing.
• Each faculty member is responsible for all taxes on the compensation.
• A faculty member who receives an overpayment notifies the CFO immediately at [email protected] and repays NewU the full amount without delay.

Other terms of the ICA

The ICA also sets terms on substitutes (see 2.5 Faculty Responsibilities), background checks (see 2.2 Faculty Recruitment and Engagement), confidentiality of NewU and student information, ownership of work products and class recordings (see 1.27 Use of University Name, Trademark, and Intellectual Property), non-solicitation, and non-disparagement, which protects academic discourse. Each faculty member follows the NewU policies on this page.

Concerns and disputes

• A faculty member raises a dispute about the engagement first with the Chief Academic Officer (CAO). As the ICA provides, a dispute goes to the CAO (30 calendar days), then to the President (an additional 10 calendar days), and then to binding arbitration in Washington, DC under the CPR Institute Rules for Non-Administered Arbitration. District of Columbia law governs.
• Conduct concerns about a faculty member follow the progressive response for employees and contractors in 4.1 Code of Ethics and Conduct. How a contract ends follows the ICA.
• Student complaints, including grade appeals, follow 1.24 Student Grievance and Appeals.

This policy summarizes key terms of the ICA. The signed ICA states them in full.

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2.2 Faculty Recruitment and Engagement

Applies to: faculty and candidates for faculty positions. Approved by: the President. Reviewed: October 2026.

Framework

• All faculty recruitment and contracting comply with applicable labor laws and regulations.
• Only the Chief Academic Officer (CAO), with the knowledge and approval of the President, may start, pause, or stop recruitment for any faculty position.
• The President, who heads the HR office ([email protected]), manages the faculty recruitment process with input from the CAO.

Recruitment

1. When the CAO decides to recruit, with the President's knowledge and permission, NewU advertises the position on Indeed.com or other recruitment platforms. The final decision to advertise and to offer a position is at the President's sole discretion.
2. Before a vacancy is announced, all responsible parties agree on each major element of the position (the one-semester independent contractor engagement, the class, the section or sections, and compensation), how the position relates to NewU's likely needs, the expectations for the faculty member's work, and the resources NewU provides to help meet them.
3. The CAO works with the President and, at the CAO's discretion, other faculty to review applications, shortlist candidates, and recommend finalists to the President.
4. Each announcement states the teaching modality (on campus, online, or hybrid), the type of engagement (independent contractor, one semester), compensation, required qualifications and skills, whether the position depends on funding or other conditions, teaching expectations, and the experience and credentials required. NewU requires at least a master's degree or relevant professional experience in the subject or field. NewU may give interested candidates more information at its sole discretion.
5. Candidates have reasonable time to apply after a position is announced.
6. NewU ordinarily seeks several qualified candidates. Offers go to candidates only with the President's approval, or with the CAO's approval when the President has authorized it.

Confidentiality, interviews, and offers

• NewU protects the confidentiality of the information it receives about candidates and expects candidates to respect the confidentiality of the process. Candidates do not seek confidential information from anyone involved in the review, during or after the process. Questions about the process, its timing, or its outcome go to the CAO.
• Interviewers do not treat any candidate in a discriminatory way (see 1.3 Anti-Discrimination and Equal Opportunity). Communications with candidates are consistent with the announcement.
• Candidates disclose promptly any condition that may bear materially on an offer, such as a request for a later start, a known conflict during the term of the engagement, a conflict of interest, or other information that affects NewU or the candidate's ability and fit to serve.
• Candidates who ask about the progress of the search and the status of their candidacy receive that information to the extent possible.
• The President makes the final decision to offer a contract and is responsible for recruitment that follows applicable law.
• NewU may tell the successful candidate informally that it intends to make an offer, but the formal offer is in writing. Oral offers and oral acceptances are not binding, and communications with the candidate are frank and accurate. NewU sends the written offer within 10 days of telling the candidate it intends to make one, and tells the candidate promptly if the offer will not come within 10 days.
• The terms of an offer are consistent with the announcement or with terms later agreed, and other relevant information is given to the candidate in writing.

Conditions of the engagement

• The faculty member signs the ICA.
• The faculty member clears a background check under 4.16 Background Screening, as a condition of the ICA. NewU runs the check in-house. It covers educational credentials, professional qualifications, criminal records, and references.
• Before first instructional contact with a class section that includes a minor student, and each year after that, the faculty member completes NewU's safeguarding compliance orientation under 1.5 Protection of Minors. NewU also directs faculty to the District of Columbia's mandated reporter training, which District law requires of mandatory reporters (D.C. Code § 4-1321.08), and documents completion.
• The faculty member takes part in onboarding and other activities the CAO or the President requires, and prepares for the role before the engagement starts.

Safer recruitment

Every engagement that involves interaction with minor students follows 4.16 Background Screening. Background screening, reference checks, and probationary monitoring are required (see 1.5.1 Child Protection and Safeguarding).

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2.3 Academic Freedom

Applies to: faculty. Approved by: the President. Reviewed: October 2026.

Institutions of higher education are conducted for the common good and not to further the interest of either the individual teacher or the institution as a whole. The common good depends upon the free search for truth and its free exposition.

Academic freedom in its teaching aspect is fundamental for the protection of the rights of the teacher in teaching and of the student to freedom in learning. It carries with it duties correlative with rights. Academic freedom and academic responsibility apply to everyone who teaches for NewU.

Freedoms and responsibilities

• Faculty are entitled to full freedom in research and in the publication of the results, subject to the adequate performance of their other academic duties.
• Faculty are entitled to freedom in the classroom in discussing their subject, but they take care not to introduce into their teaching controversial matter that has no relation to their subject.
• Faculty are citizens, members of a learned profession, and members of an educational institution. When they speak or write as citizens, they are free from institutional censorship or discipline, but their special position in the community imposes special obligations. As scholars and educators, they remember that the public may judge their profession and NewU by their words. They are accurate at all times, exercise appropriate restraint, show respect for the opinions of others, and make every effort to indicate that they are not speaking for NewU.

NewU's central functions of teaching and learning depend upon an atmosphere in which freedom of inquiry, thought, expression, publication, and peaceable assembly are given the fullest protection. NewU encourages expression of the widest range of viewpoints, free from institutional orthodoxy and from internal or external coercion. Holding an engagement at NewU in no way affects a faculty member's rights under the Constitution of the United States.

In furtherance of these principles, decisions on (a) the recruitment and engagement of faculty, (b) the assignment of teaching and other primarily academic responsibilities, and (c) any other granting or withholding of benefits or imposition of burdens are made without regard to a person's political, social, or other views not directly related to academic values or to the assumption of academic responsibilities, and without regard to any characteristic protected under 1.3 Anti-Discrimination and Equal Opportunity.

Class design and the freedom to teach

NewU, through the Chief Academic Officer (CAO), sets each class's learning outcomes, credit-hour workload, required core materials, modules, and common assessments, and approves every syllabus before the semester begins. Every section of a class, on campus, online, or hybrid, uses the same approved syllabus.

Within that design, faculty choose their teaching methods and supplementary materials, assess individual student work, and keep full freedom of discussion in class. A faculty member may assign supplementary materials on subjects the faculty member believes the required materials treat inadequately.

The CAO reviews class design periodically, with substantial reflection and discussion among the faculty who teach each class.

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2.4 Faculty Professional Ethics

Applies to: faculty. Approved by: the President. Reviewed: October 2026.

Professors, guided by a deep conviction of the worth and dignity of the advancement of knowledge, recognize the special responsibilities placed upon them. Their primary responsibility to their subject is to seek and to state the truth as they see it. To this end they develop and improve their scholarly competence, exercise critical self-discipline and judgment in using, extending, and transmitting knowledge, and practice intellectual honesty. Subsidiary interests never seriously hamper or compromise their freedom of inquiry.

As teachers, professors encourage the free pursuit of learning in their students and hold before them the best scholarly and ethical standards of their discipline. They respect students as individuals and keep to their proper roles as intellectual guides and counselors. They make every reasonable effort to foster honest academic conduct and to ensure that their evaluations of students reflect each student's true merit. They respect the confidential nature of the relationship between professor and student, avoid any exploitation, harassment, or discriminatory treatment of students, and acknowledge significant academic or scholarly assistance from them.

As colleagues, professors do not discriminate against or harass colleagues, and they respect and defend the free inquiry of associates, even when it leads to conclusions that differ from their own. As members of an academic institution, they seek above all to be effective teachers and scholars. When they speak or act as private persons, they avoid creating the impression of speaking or acting for NewU. As citizens in a profession that depends upon freedom for its health and integrity, they promote conditions of free inquiry and further public understanding of academic freedom.

Principles

Faculty are bound by this statement and by 4.1 Code of Ethics and Conduct. The principles below explain which actions may lead to action under 4.1 and the faculty member's ICA.

1. Students and personal services. Faculty exercise caution when engaging students for personal services. Where a supervisory or evaluative relationship exists between a faculty member and a student, extensive use of the student for personal services unrelated to the faculty member's professional obligations to NewU, paid or unpaid, is normally avoided. Faculty have no commercial transactions or paid private tutoring with a minor student (see 2.7 Working with Minor Students).
2. Relationships with students. Faculty have no romantic, sexual, or dating relationship with any enrolled or admitted student of any age. The full rule, including written disclosure of a relationship that already exists and the rule for former students who were minors while enrolled, is in 1.5.3 Adult-Student Boundaries and Code of Interactions.
3. Colleagues' freedom of speech and harassment. Faculty respect their colleagues' freedom of speech and academic freedom. The right to hold divergent opinions and to speak freely on controversial matters is fundamental to academic discourse. Some speech goes beyond what freedom of speech and academic freedom protect: conduct that meets the definition of harassment in 1.4 Anti-Harassment and Discriminatory Conduct is not protected. Harassment may take the form of direct ethnic or racial slurs or abusive language toward a specific individual. Libel against a colleague, or repeated attacks on the personal or academic reputation of a colleague or a student, is also harassment, specifically when statements are made with malicious intent and with the knowledge that they are untrue. A faculty member who makes a statement that could damage a colleague's or a student's reputation, and that is later proven false, issues both a retraction and an apology.
4. Working environment. Not every behavior that might violate this policy can be listed, but a general standard applies. When arguments and conflicts with colleagues create an atmosphere permeated with overt hostility, abusive behavior, or intimidation that prevents faculty or staff from fulfilling their professional obligations, the matter is no longer one of collegiality. When the general behavior of a faculty member, including comments of a purely verbal nature, creates a demonstrably hostile, intimidating, or abusive environment for other faculty, that behavior violates this policy.
5. What is not actionable. A faculty member's opinions, beliefs, attitudes, or public statements on controversial issues are not evidence against the faculty member under this policy. Divergent or unpopular opinions do not violate this policy. NewU applies this policy consistently with 2.3 Academic Freedom and 1.26 Open Expression.
6. Students' academic freedom. Faculty respect the academic freedom of their students by evaluating students only on the quality of each student's academic performance, and they recognize the right of students to hold views that differ from their own.
7. Evaluating colleagues. Faculty excuse themselves from any duty that involves a conflict of interest when they are in a position to evaluate a colleague or to recommend a colleague for engagement.
8. Service in grievance and conduct processes. Faculty who serve at NewU's request in a grievance, conduct, academic integrity, or investigation process do not undertake it lightly: their recommendations may affect a student's studies or a colleague's ability to work in the profession. They do not exert undue bias on the process or allow personal bias to affect their judgment. A conflict of interest exists when a person serving in such a role fails to disclose relevant information or prior knowledge of the case, or has an ongoing business relationship, a supervisory or evaluative relationship, or a close personal, sexual, or romantic relationship with any party.
9. Outside engagements. Faculty disclose to the Chief Academic Officer (CAO), in writing, any outside engagement that competes with NewU or creates a conflict of interest.

Raising and resolving concerns

Not every action that may conflict with these principles is serious enough to call for formal action; good judgment is the key to applying any NewU policy. Faculty first try to resolve disputes collegially and informally with the CAO. When this is neither possible nor appropriate, and evidence exists that a faculty member has violated this policy or another NewU policy, the CAO or another officer NewU designates tells the faculty member in writing the nature of the violation and the changes in behavior expected.

Further steps follow the progressive response for employees and contractors in 4.1 Code of Ethics and Conduct and the terms of the ICA. When a violation is so severe that it threatens the ethical integrity of NewU or of the teaching profession, NewU may end the faculty member's contract under its terms for a first offense. Under most circumstances, formal proceedings are a last resort.

Faculty report harassment, discrimination, retaliation, and safeguarding concerns to the Chief Student Journey Officer ([email protected]), and ethics, whistleblower, and financial-irregularity reports to the President ([email protected]), as 1.4 Anti-Harassment and Discriminatory Conduct and 4.3 Whistleblower and Non-Retaliation set out.

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2.5 Faculty Responsibilities

Applies to: faculty. Approved by: the President. Reviewed: October 2026.

Each faculty member delivers the services in the ICA's statement of work and meets the standards below. NewU's concern is the result; the faculty member chooses the methods (see 2.1 and 2.3).

Teaching

• Remain current in the subjects and classes taught.
• Prepare for each class, deliver and manage each class session, and follow up after class.
• Teach each assigned class as scheduled, beginning and ending each session promptly, on the assigned subject, at the assigned level, and with the rigor and standards appropriate to that level. Plan appropriate activities for every scheduled class meeting.
• Foster free discussion, inquiry, and expression in class while maintaining the class's academic standards and objectives.
• Select the readings and resources the class needs beyond NewU's required core materials, and make sure required books and other class materials are accessible to students when needed.
• Ensure that students meet the learning outcomes the Chief Academic Officer (CAO) sets.
• Complete in a professional, timely, and responsible manner all other teaching and academic assignments accepted or assigned, such as submitting grades, mentoring or reading theses, writing letters of recommendation, and conducting tutorials.
• Never use the status of a faculty member to coerce, intimidate, or manipulate students.

Syllabus

Each faculty member builds and updates the class syllabus within the class design NewU sets (see 2.3), including learning objectives, weekly topics, assignments, assessment criteria, whether the class uses remote proctoring, and the class rules for student use of AI tools. The CAO reviews and approves each syllabus before the semester starts, and the faculty member corrects any issue before the semester starts. The faculty member distributes the approved syllabus to all students in Populi by the end of the first week of class.

Meeting classes, absences, and substitutes

Faculty meet every class for which they are scheduled. A faculty member who must miss a class reports the absence in advance to the CAO, before the class is cancelled where possible, and arranges to make up the class or have it covered. A substitute teaches only with the CAO's prior written approval, and under the ICA the faculty member pays the substitute. A substitute for a section that includes a minor student must also have cleared a background check and completed the safeguarding orientation (see 1.5 Protection of Minors).

Attendance

Faculty take attendance for every class session in Populi. Online students who attend live keep the camera on for the full session, unless an approved accommodation provides otherwise (see 1.20 Accommodations for Students with Disabilities). Online students and Flex students may attend live or watch the recording, as 1.17 Attendance sets out.

Online and hybrid classes

• Class sessions are recorded only through NewU's Google Workspace for Education, using Google Meet and the classroom camera and microphone. Faculty make no separate recordings of class sessions or of students.
• Faculty never download class recordings to personal devices, and share a recording outside the enrolled class section only with the CAO's prior written approval (see 1.7 Photo, Video, and Recording).
• If an uninvited participant joins, or a session is disrupted by inappropriate content or behavior, the faculty member removes the participant immediately; locks the session, or ends it and reconvenes with a new link; preserves the recording, chat log, and participant list; reassures students and resumes instruction if appropriate; and reports the incident the same business day to [email protected] and to the Chief Student Journey Officer (CSJO) at [email protected]. Where minor students were exposed to harmful content, the faculty member also follows 1.5.2 Mandated Reporting of Child Abuse, Neglect, and Boundary Violations.
• Proctored exams run in Populi with Populi’s built-in proctoring.

Artificial intelligence

• The syllabus states the class rules for student use of AI tools (see 1.19 Artificial Intelligence and Generative Tools).
• Faculty do not use AI tools to assign grades or to determine the level of credit awarded for any student work. Grading judgment remains with the faculty member.
• Faculty disclose in the syllabus or in class materials where instructional content has been substantially generated by AI tools.

Grading

• Academic freedom includes the faculty member's right freely to evaluate student academic performance. Faculty grade accurately and on time, with honesty and fairness and without bias, using appropriate criteria and following stated procedures, and give students feedback on their work.
• Faculty design assignments and exams aligned with the class objectives, use the grading scale in 1.14 Academic Program, and state academic integrity standards in each syllabus. Suspected violations follow 1.18 Academic Integrity.
• Grades reflect the degree to which students have met the learning outcomes for the class, and the distribution of grades is consistent with NewU averages. Repeated and significant variations from NewU averages are justified by sound pedagogy and supported by the CAO.
• Faculty enter grades in Populi within the deadlines the registrar office sets, and enter semester grades no later than two calendar weeks after the end of the semester.
• A final grade submitted by a faculty member may be overruled only through the student appeal process in 1.24 Student Grievance and Appeals (the CSJO, then the President). Faculty cooperate fully with grade appeals.

Office hours, advising, and coaching

• Hold weekly office hours at published times during the contracted semester, listed on the class calendar and held on NewU platforms, such as Google Meet, or in an observable space on campus (see 1.5.3 Adult-Student Boundaries and Code of Interactions).
• Respond to student email within one business day.
• Advise students in the class. At NewU, every student is advised by a member of the faculty. Faculty advisors give accurate information and appropriate guidance and know NewU's degree requirements; understand students' developmental levels and help them set and reach goals; know how and when to guide students to other NewU resources; and show courtesy, respect, interest in the student's program, approachability, and good listening.
• Schedule and conduct one-on-one Coaching for Success meetings with assigned students, at least once a month for each student.

Students, records, and communications

• Faculty are school officials with a legitimate educational interest under FERPA (see 1.9 Privacy and Education Records). They use only NewU-provided accounts and systems, such as newu.edu email, Populi, and Google Meet, to communicate with students and handle student information; keep no student information on personal devices or accounts; and return or delete student information at the end of the engagement.
• Faculty notify NewU in writing at [email protected] within 72 hours of any actual or suspected unauthorized access to, disclosure of, or loss of student information.
• Students bring academic questions to their professor first. Faculty answer questions about the class, including how to use Populi and the other class tools, and send anything that remains unresolved to the relevant office, such as [email protected], never to a named administrator.
• Faculty attend administrative meetings when the CAO or the President asks, communicate and collaborate through NewU channels, and provide additional services NewU reasonably requests.
• Requests for teaching materials, software, e-books, articles, and case studies go to [email protected]; IT access and outages to [email protected]; invoices to [email protected]; and personnel matters to [email protected]. Response times and escalation follow 4.21 Institutional Communications.

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2.6 Faculty Evaluation and Re-engagement

Applies to: faculty. Approved by: the President. Reviewed: October 2026.

Because faculty are evaluated with respect to NewU's mission, faculty evaluation is both an individual and an institutional matter. It has two basic aims: to assist faculty development and to meet institutional needs. Making clear the expectations NewU places upon the teacher, and providing the conditions and support necessary for excellent teaching, are primary institutional obligations.

NewU expects every faculty member to perform the duties in 2.5 Faculty Responsibilities satisfactorily. Satisfactory performance does not by itself entitle a faculty member to another contract. A faculty member is expected to have a thorough knowledge of the subjects taught, a demonstrated ability to communicate that knowledge to students, and the skill to stimulate students to reach their potential.

Criteria

• Teaching. The effective teacher is committed to the subject, to students, and to constant improvement in teaching; shows enthusiasm for and thorough knowledge of the field; is available to students in and out of class; encourages questions, welcomes diversity of opinion, and is considerate and fair in all dealings with students; sets rigorous academic standards and gives timely and substantial feedback on all assignments and exams; welcomes and profits from constructive criticism; and keeps class content and methods current within the approved class design.
• Class development. New classes proposed or taught; significant revisions; newly developed teaching materials; new technologies and techniques; innovation in class.
• Pedagogy. Quality of prepared materials; effective use of teaching techniques in class; attention to students' suggestions; exams and grading criteria that allow fair evaluation of students; effective response to guidance from previous evaluations.
• Additional work with students. Supervising senior projects or theses; independent study classes; other work supporting learning; academic advising and Coaching for Success.

Sources of information

A fair evaluation includes an accurate description of what the faculty member does as a teacher (the number, level, and kinds of classes taught, the number of students, and out-of-class work related to teaching), measures of the effectiveness of that work, and fair consideration of how it relates to NewU's expectations and support. The emphasis is on firsthand evidence of teaching competence, which is most likely to be found among faculty colleagues and the students who receive instruction. Sources include:

• student evaluations;
• Populi grade reports;
• peer reviews;
• syllabi, exams, and class materials;
• the faculty member's self-evaluation;
• other input the CAO gathers.

Care is taken that this review does not inhibit the teacher, limit the variety of effective teaching styles, or discourage purposeful innovation.

Review and re-engagement

The Chief Academic Officer (CAO) evaluates each faculty member's teaching on a regular schedule. For each faculty member under evaluation, the CAO reviews the information above and makes a written recommendation to the President on whether to offer the faculty member another contract. The faculty member may respond in writing to the CAO's evaluation, and the response goes to the President with the recommendation. The President has sole and final authority to offer a contract.

NewU has no faculty ranks, so there is no promotion review and no evaluation dossier.

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2.7 Working with Minor Students

Applies to: faculty. Approved by: the President. Reviewed: October 2026.

High school students age 15 and older take college in high school classes through partner institutions, including Dual Academy, in the same sections as adult students. 1.5 Protection of Minors and its four parts govern every setting that includes a minor student and bind faculty in full, together with 1.6 Virtual Learning Environment Safety and 1.7 Photo, Video, and Recording. This policy collects the rules faculty apply most often and adds two rules for faculty.

In every class

• NewU tells faculty which students in their sections are minors. Faculty treat that information as confidential.
• Faculty communicate with minor students only through NewU-provided accounts and systems, never through personal email, personal phone, personal messaging apps, or personal social media.
• One-on-one academic contact with a minor student, including office hours and Coaching for Success, takes place on NewU platforms, is scheduled through the NewU calendar, and is observable and interruptible. Faculty hold no unscheduled private video session or private chat with a minor student.
• Faculty do not connect with an enrolled minor student from a personal account on any platform, including professional networks such as LinkedIn. A faculty member who receives a request declines it or leaves it pending, tells the student why, and invites the student to connect once the student is 18; a letter of recommendation through NewU channels is the substitute in the meantime.
• Faculty do not photograph or record a minor student except through NewU's standard class recording, do not arrange to meet a minor student off platform, and do not transport a minor student except with the written consent of the student's parent or legal guardian.
• Faculty do not give a minor student gifts of meaningful value, money, or loans, and do not single out a minor student for excessive personal attention.
• When a minor student is present at a NewU facility or activity, faculty avoid being alone with the student in a closed or unobservable space.
• Faculty, or another adult acting for NewU, moderate group channels that include minor students.

Two further rules for faculty

• Faculty have no commercial transactions or paid private tutoring with a minor student.
• A faculty member who has an existing personal, family, or close relationship with a minor student, or with the student's parent or legal guardian, discloses the relationship in writing to the Chief Student Journey Officer (CSJO) at [email protected] at engagement or when the relationship becomes relevant. The CSJO documents reasonable accommodations, such as reassignment, to avoid conflicts.

Relationships

The relationship rule in 1.5.3 Adult-Student Boundaries and Code of Interactions applies to every faculty member. No exception ever applies to a minor.

Reporting

D.C. Code § 4-1321.02 makes teachers and school officials in the District mandated reporters. A faculty member who has reasonable cause to suspect abuse or neglect of a minor reports it immediately to the appropriate authority (911 in immediate danger; in the District of Columbia, the Child and Family Services Agency at 202-671-SAFE (7233) or the Metropolitan Police Department) and, in parallel, notifies the CSJO at [email protected]. Internal notice does not delay or substitute for the external report, and the reporter does not investigate. The full procedure, including reports for minors who live in other states, is in 1.5.2 Mandated Reporting of Child Abuse, Neglect, and Boundary Violations.

Interim measures

NewU may immediately restrict a faculty member's access to classes, systems, and students while a report or suspected violation is reviewed. Violations are addressed under the ICA and 4.1 Code of Ethics and Conduct, up to ending the contract and referral to law enforcement.

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3.1 Worker Classification

Applies to: employees. Approved by: the President. Reviewed: October 2026.

To determine eligibility for benefits and overtime status, and to comply with federal and District of Columbia law, NewU classifies its employees as set out below. NewU may review or change a classification at any time. Contractors, including all faculty and the part-time administrative staff, serve under their written agreements. Before a role is posted, the President decides whether it is filled by an employee or engaged as a contractor.

Exempt status

NewU classifies its employees as exempt. Exempt employees are paid on a salaried basis and are not eligible to receive overtime pay. NewU tells each employee of the exempt classification at hire or on a change of position (see 3.3 Pay and Deductions).

Classification of positions

The President, who heads the HR office ([email protected]), is responsible for the classification of positions. Before a position is posted, the President reviews the job requisition for every position that is new to NewU, being replaced, or undergoing a significant change in scope and responsibility, and determines the appropriate job and grade profile.

NewU is subject to the federal Fair Labor Standards Act (FLSA), which regulates hours of work, the payment of wages, minimum rates of pay, overtime pay, and recordkeeping. The President reviews each position before posting to confirm that it is classified correctly and that its written job description and actual duties are consistent. Positions are evaluated on the duties in the job requisition; the level of problem solving, accountability, decision-making, and responsibility; the scope and complexity of the position; and its impact on NewU's operations. The evaluation establishes the position's job family, job profile, grade profile, and exemption status.

Salary offers

Salary offers are based on the candidate's qualifications, experience, skills, and education as they relate directly to the requirements of the position, and on internal equity, external market benchmarks, and the grade profile. No offer is below the minimum or above the maximum of the grade profile. No formal salary offer, or promise of an offer, is made without the President's prior approval.

Reclassification and compensation changes

• A reclassification assigns a new job profile or grade profile, and in some cases a new job family, to an existing position, based on an evaluation of its duties, responsibilities, scope, impact, and minimum qualifications.
• A filled position is eligible for reclassification review when an authorized and necessary significant increase in its scope, impact, complexity, responsibilities, and accountability requires the employee to exercise greater judgment and discretion and to rely on a larger and more specific skill set than before.
• The employee must have at least six months of continuous service in the current position, and must have performed the new duties successfully for at least six months, before a reclassification request is submitted. Years of service, outstanding work performance, and an increase in the volume of work are not grounds for reclassification.
• The employee's supervisor identifies significant changes in job responsibility and starts a reclassification review. An employee who disagrees with the supervisor about the need for a review may raise it with the President at [email protected].
• Off-cycle salary adjustments address pay compression, equity, market factors, or an increase in duties, and may be requested at any time in the fiscal year. The employee must have at least six months of continuous service. An employee on a performance improvement plan is not eligible, and length of service alone is not a valid reason. A review may result in an internal equity adjustment, an external market adjustment, or no change.
• The President reviews and approves every reclassification and compensation change and sets its effective date. No reclassification or compensation change takes effect before the beginning of the current fiscal year.

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3.2 Employment at Will

Applies to: employees. Approved by: the President. Reviewed: October 2026.

Employment at NewU is at will unless a written individual employment agreement signed by the President states otherwise. Either the employee or NewU may end the employment relationship at any time, with or without cause or advance notice.

Nothing in the Staff Handbook or any other NewU handbook or policy is intended to create, or creates, an employment agreement, express or implied. Nothing in this or any other document given to an employee is a contract that employment or any benefit will continue for any period of time. No NewU representative may change this policy for any employee or enter into any agreement, oral or written, that changes the at-will relationship. Salary figures stated in annual or monthly terms are for convenience or to make comparisons easier, and do not create an employment contract for any specific period.

The progressive response in 4.1 Code of Ethics and Conduct does not change the at-will status of employees or limit NewU's right to skip its steps.

Nothing in this policy interferes with, restrains, or prevents concerted activity protected by the National Labor Relations Act, including employee communications about wages, hours, or other terms or conditions of employment. Employees have the right to engage in or refrain from such activities.

Contractors, including all faculty and the part-time administrative staff, work under their written agreements, which govern how their engagements end.

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3.3 Pay and Deductions

Applies to: employees. Approved by: the President. Reviewed: October 2026.

Pay

NewU pays employees monthly by direct deposit to the employee's checking or savings account, or both. If a payday falls on a federal holiday, employees are paid on the preceding workday. Pay questions go to the HR office at [email protected]. Contractors are paid on invoices under their agreements (see 2.1 and 4.11 Paying Suppliers and Contractors).

Salary basis for exempt employees

NewU's pay practices follow the federal Fair Labor Standards Act (FLSA), its amendments, and its regulations. Under the FLSA, positions are classified as non-exempt or exempt. Exempt employees are exempt from the FLSA's overtime provisions but are covered by its other provisions. NewU complies with the FLSA's salary basis requirements and does not make improper deductions from the salaries of exempt employees. NewU tells each employee classified as exempt of that classification at hire or on a change of position.

Permitted deductions

The FLSA limits the deductions that may be made from an exempt employee's pay. Permitted deductions include:

• deductions required by law, such as income taxes;
• deductions for employee benefits the employee authorizes;
• absence from work for one or more full days for personal reasons other than sickness or disability;
• absence from work for one or more full days due to sickness or disability, if the deduction follows a bona fide plan, policy, or practice of providing compensation for salary lost due to illness;
• offsets for amounts received as witness or jury fees, or as military pay.

In the week an exempt employee begins work at NewU, and in the last week of employment, the employee is paid only for actual hours worked.

Improper deductions

An exempt employee who believes an improper deduction has been taken from the employee's pay reports it immediately to [email protected]. NewU investigates the report promptly. If the deduction was improper, NewU reimburses the employee and takes good-faith measures to prevent improper deductions in the future. NewU resolves any other type of pay error promptly.

Overpayments

• Employees review each pay stub or direct deposit notice when they receive it. An employee who finds an overpayment of salary or other compensation notifies the EVP and Chief Financial Officer (CFO) immediately at [email protected], so the amount can be confirmed. When the CFO finds an overpayment, the CFO tells the employee that an overpayment was made and its amount.
• On being told of an overpayment, the employee repays NewU the full amount immediately. If immediate repayment would cause extreme hardship, the employee may ask in writing for a payback period of up to sixty (60) days, which the CFO approves. A payback period beyond sixty (60) days requires approval under the thresholds in 4.9 Financial Management and Approval Authority.
• An employee may repay by payroll deduction on written authorization to the CFO.
• A violation of this section may lead to discipline under 4.1 Code of Ethics and Conduct, up to and including termination. NewU may take further steps to recover an overpayment and related collection fees, as the law permits.

Overpayments to contractors, including faculty, are settled under their agreements (see 2.1).

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3.4 Work Schedule

Applies to: employees. Approved by: the President. Reviewed: October 2026.

All of NewU's full-time employees are Executive Staff and work a flexible schedule.

Flexible schedule

Executive Staff may work on their own schedule and from any location, and may take time off at any time and for any reason, provided this does not in any way negatively affect the quality of their work or the work of other NewU team members, and does not delay any work or deliverable of importance to NewU.

• At times, and with reasonable notice, the President may ask any Executive Staff member to pause or end time off.
• If the President requires it, Executive Staff return to their workstation or perform tasks on a timeline the President sets.
• Executive Staff notify the President in writing at [email protected], with reasonable notice, of any time off or change of location expected to last more than 3 (three) days.
• Because they work on a flexible schedule, Executive Staff are not eligible for paid time off (PTO) or personal days.
• The President may suspend or cancel a flexible schedule arrangement at any time.

Time records

Exempt monthly-paid employees follow exemption pay reporting: they record only time away from work, such as sick time, holidays, bereavement, and jury duty. For time reporting only, full-time exempt employees are treated as working 40 hours a week (8 hours a day, 5 days a week). This does not reflect actual hours worked.

Schedules for contractors and volunteers follow their agreements. Faculty have no set work hours (see 2.1).

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3.5 Holidays

Applies to: employees. Approved by: the President. Reviewed: October 2026.

NewU observes and allows time off with pay on these holidays:

• New Year's Day
• Presidents' Day
• Memorial Day
• Independence Day
• Labor Day
• Thanksgiving Day
• Day after Thanksgiving
• Workday directly before or after Christmas (depending on the day of the week of Christmas)
• Christmas
• New Year's Eve Day

NewU designates any additional holidays at the start of each calendar year. When a listed holiday falls on a weekend, NewU may schedule another day. Class holidays and breaks are set in the Academic Calendar.

Working on a holiday

When NewU operates on a holiday, the President schedules coverage. Exempt employees who work on a scheduled holiday are not entitled to additional pay, but receive time off, when the workload permits, for the hours worked, up to 8 hours.

Religious observances

Employees may request time off for religious observances that are not on the holiday schedule, with adequate notice to the President. An employee may take the time off under the flexible schedule in 3.4 Work Schedule, or may work outside the employee's usual hours to make up the time. A request may be denied when the employee's absence on the requested day would create an undue hardship.

Other time off

Employees take vacation, personal, and other time off under the flexible schedule in 3.4 Work Schedule.

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3.6 Performance Reviews

Applies to: employees. Approved by: the President. Reviewed: October 2026.

NewU appraises each employee's performance periodically. The appraisal encourages constructive dialogue between employees and their supervisors, clarifies job responsibilities and performance goals, supports the employee's professional development, records job performance and accomplishments in the employee's NewU employment history, and provides a basis for decisions on compensation.

The annual appraisal

• The formal Performance Appraisal takes place once a year, usually by the employee's immediate supervisor. After it is completed, it is discussed with the employee and signed by the reviewer and the employee. The employee's signature shows that the appraisal has been reviewed with the employee, not necessarily that the employee agrees with it.
• Performance Appraisals become part of the employee's personnel file and are kept confidential under 4.17 Personnel and Contractor Files.
• An objective appraisal rests on a clear understanding of the job. At the start of the employee's duties, the supervisor states the duties the employee is expected to perform and the expectations for performing them. At the beginning of each appraisal period, the supervisor and the employee review their understanding of the duties, goals, and performance expectations of the job, including future performance planning and professional development goals.
• An employee who supervises others is appraised in part on how effectively the employee manages them, including completing appraisals for direct reports.

Administrative review of an "Unacceptable" appraisal

An employee whose overall performance is described as "Unacceptable" may ask for administrative review. Review is not available for individual assessments in specific sections of the appraisal.

1. After signing the appraisal, with or without comment, the employee may meet with the immediate supervisor to discuss it. The employee contacts the supervisor within 10 work days of receiving the appraisal to schedule the meeting, and gives the supervisor the specific reasons for the request in writing at least 2 work days before the meeting. Within 10 work days after the meeting, the supervisor gives the employee a written response to the issues raised.
2. If the employee is not satisfied with the supervisor's response, or no response is given, the employee may ask the President for review through [email protected], stating the specific concerns in writing within 10 work days of receiving the supervisor's response. Within 10 work days after meeting with the employee, the President gives a written response, which normally concludes the review.
3. At any stage, an employee who believes the procedures used were inconsistent with this policy may ask the President to review them. That review is limited to whether this policy was followed, and the President may direct corrective action.
4. At all stages, the employee is responsible for showing that the appraisal is inaccurate or that this policy was not followed.
5. Only the employee and the supervisor attend appraisal meetings. If both agree, the President may help facilitate the meetings.

Contractors are reviewed under their agreements. Faculty are reviewed under 2.6 Faculty Evaluation and Re-engagement.

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3.7 Outside Employment

Applies to: employees. Approved by: the President. Reviewed: October 2026.

NewU recognizes that some employees may need or want to hold additional jobs outside their employment with NewU. Employees may engage in outside work or hold other jobs, subject to restrictions based on reasonable business concerns. NewU applies this policy consistently and without discrimination to all employees, in compliance with applicable employment and labor laws.

An employee notifies the President at [email protected] before taking outside employment. These rules apply:

1. Work-related activities and conduct away from NewU do not compete with, conflict with, or compromise NewU's interests, or adversely affect job performance and the ability to fulfill all responsibilities to NewU. Employees do not perform for NewU's students, applicants, or other customers any services that NewU normally performs. Employees do not use NewU tools or equipment, or use or apply confidential information, without authorization, and do not solicit or conduct outside business while working for NewU.
2. No employee has commercial transactions or paid private tutoring with a minor student (see 1.5.3 Adult-Student Boundaries and Code of Interactions).
3. Employees consider carefully the demands that additional work will create before accepting outside employment. Outside employment is not an excuse for poor job performance, absenteeism, refusal to travel, or refusal to work different hours. If outside work causes or contributes to job-related problems at NewU, the employee is asked to discontinue it and may be subject to the progressive response in 4.1 Code of Ethics and Conduct.
4. If an employee's outside employment presents a conflict of interest with NewU (see 4.2 Conflict of Interest), or has any potential for negative impact on NewU, the employee is asked to end the outside employment.
5. An employee's refusal to comply with NewU's reasonable request to end outside employment may result in immediate termination of employment.

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3.8 Separation from Employment

Applies to: employees. Approved by: the President. Reviewed: October 2026.

Resignation

An employee who resigns is asked to give written notice to the President at [email protected] at least two (2) weeks before the last day of work. Employees who give the requested notice are considered to have resigned in good standing and are generally eligible for rehire. The President acknowledges the resignation in writing.

Departure

The President coordinates each employee's departure. The process includes the return of all NewU property, a review of the employee's post-employment benefits status, and an exit interview. NewU accounts are closed under 1.8 Acceptable Use of University Systems.

Other separations

Employment is at will (see 3.2 Employment at Will). Separation for conduct or performance follows 4.1 Code of Ethics and Conduct.

The end of a contractor's engagement, including any faculty contract, follows the contractor's agreement and 1.8 Acceptable Use of University Systems.

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4.1 Code of Ethics and Conduct

Applies to: everyone acting for NewU (directors, officers, employees, contractors including all faculty, and volunteers). Approved by: the President. Reviewed: October 2026.

Everyone who acts for NewU is responsible for sustaining the ethical standards of this institution and of the broader community in which it works. NewU values integrity, excellence, creativity, social responsibility, and freedom of inquiry and expression, and builds these values into its education and business practices. This Code turns those values into specific expectations for directors, officers, employees, faculty, contractors, and volunteers, and sets out how NewU responds to violations. The President adopts this Code and may amend it.

Scope

This Code applies in every NewU setting: the campus, online classrooms, NewU systems and accounts, NewU events, and NewU communications, including email, messaging, and social media. It applies to consultants and contractors when they perform services for NewU, interact with members of the NewU community, act on NewU's behalf, or are required by contract to comply with it. Students follow the Code of Conduct; when a student acts for NewU, for example as a volunteer or as the Student Representative to the Board, this Code also applies. Specific NewU policies may supplement this Code; it does not replace them.

Ethical Standards

NewU earns and keeps a reputation for integrity, which includes compliance with laws, regulations, and its contracts. Even the appearance of misconduct or impropriety can damage NewU. Where no specific law or regulation governs, fairness, honesty, and respect for the rights of others govern our conduct.

Everyone acting for NewU carries out their responsibilities in line with applicable legal and ethical principles and conducts NewU business with honesty, accuracy, and fairness. No unethical practice is tolerated, even if it is "customary" outside NewU or serves a worthy goal. Expediency never compromises integrity. Each of us is accountable for our own actions and, together, for upholding these standards and complying with all applicable laws, regulations, and policies.

This Code is a general guide. When a situation is ethically unclear, seek advice before acting. When in doubt, ask.

Expectations for Directors, Officers, Employees, and Contractors

• Act in the best interest of NewU and its students at all times.
• Comply with these policies, with NewU procedures, and with the law.
• Treat students, families, and colleagues with respect, fairness, and professionalism.
• Maintain appropriate professional boundaries with students under Adult-Student Boundaries and Code of Interactions.
• Protect confidential information and use it only for authorized NewU purposes.
• Disclose conflicts of interest under the Conflict of Interest policy and recuse from affected decisions.
• Report suspected child abuse or neglect immediately under Mandated Reporting.
• Report any suspected violation of NewU policy or law under Whistleblower and Non-Retaliation.
• Do not harass, bully, discriminate, or retaliate (Anti-Discrimination and Equal Opportunity; Anti-Harassment and Discriminatory Conduct).
• Do not use, possess, sell, or distribute illegal drugs, and do not use alcohol at any NewU event or while performing services for NewU (Substance Use and Smoke-Free Environment).
• Bring no firearm or other weapon into, and make no threat of violence in, any NewU setting (Safety and Security).
• Dress in a casual yet professional way, consistent with good hygiene, safety, and good taste, on campus and on camera. The President decides questions about attire.

Conflicts of Interest and Corporate Opportunities

The fiduciary relationship of directors, officers, and employees to NewU is honored in both fact and appearance. They act in good faith in all transactions involved in their duties and do not use their positions with NewU, or knowledge gained from them, for personal benefit. NewU's interest comes first in all decisions and actions. A conflict of interest exists when a NewU representative's direct or indirect personal interests are inconsistent with or interfere with NewU's best interests.

Directors, officers, and anyone who makes or influences purchasing or contracting decisions follow the Conflict of Interest policy adopted by the Board of Directors on April 25, 2019. Every related-party contract needs prior approval of the Board of Directors.

Everyone acting for NewU advances NewU's legitimate interests whenever possible. No one takes for themselves an opportunity discovered through NewU property, information, or position without NewU's prior written consent, and no one uses NewU property, information, or position for improper personal gain.

Fair Dealing

NewU treats each member of its community fairly and with respect, and embraces diversity and inclusion. NewU prohibits discrimination and harassment as set out in Anti-Discrimination and Equal Opportunity and Anti-Harassment and Discriminatory Conduct. Where a violation is found, NewU acts promptly to stop the conduct, prevent its recurrence, and discipline those responsible.

Confidentiality

Everyone acting for NewU keeps confidential the information entrusted to them, except when an appropriate NewU officer authorizes disclosure or the law requires it. Confidential information includes all non-public information that might be of use to competitors or other third parties, or harmful to NewU or its constituencies if disclosed, and information that third parties have entrusted to NewU. Student education records are also governed by Privacy and Education Records.

Everyone who receives or creates confidential, regulated, proprietary, or private information for NewU follows the laws, contractual obligations, and NewU policies on its use, protection, and disclosure. Anyone who improperly uses or discloses confidential information is subject to discipline, up to and including termination of employment or of the contract, and to legal action, even if they gain nothing from the disclosure. On leaving NewU, everyone returns all sensitive NewU data unless an exception has been granted. Nothing in this section prohibits employees from discussing wages and other terms and conditions of employment.

Protection and Proper Use of NewU Assets

Everyone acting for NewU is a responsible steward of NewU's resources, protecting its assets and using them properly and efficiently in ways that preserve trust and add value. Theft, carelessness, and waste directly harm NewU's operations. Report any suspected fraud or theft at once under Whistleblower and Non-Retaliation.

NewU facilities, equipment, and other physical assets are for NewU purposes. Incidental personal use is permitted as long as it does not affect performance or disrupt work (see Acceptable Use of University Systems).

Protecting NewU's assets includes its proprietary information: intellectual property such as patents, trademarks, and copyrights, as well as business plans, databases, records, employment information, and unpublished financial data and reports. Unauthorized use or distribution of this information violates NewU policy and may also be illegal (see Use of University Name, Trademark, and Intellectual Property).

Compliance with Laws, Rules, and Regulations

Obeying the law, in letter and in spirit, is the foundation of NewU's ethical standards. Everyone acting for NewU complies with applicable laws, rules, and regulations at every level of government in the United States and in any other jurisdiction where NewU does business, understands the policies, laws, and rules that apply to their role, works to prevent violations, and speaks up about possible violations. If you are unsure whether an action is permitted by law or NewU policy, ask your supervisor or the office that handles the subject (Where to Send What) before acting.

Timely and Truthful Public Disclosures

Everyone who prepares, drafts, reviews, signs, or certifies financial and other reports and documents that NewU files with or submits to federal, state, or local authorities makes disclosures that are full, fair, accurate, timely, and understandable. No one knowingly conceals or falsifies information, misrepresents material facts, or omits material facts needed to avoid misleading the authorities or NewU's independent auditors. The same standards apply to NewU's other public communications.

Anyone who learns that information in a filing or public communication was untrue or misleading when made, or that later information would affect a similar future filing or communication, tells the President at [email protected].

Significant Accounting Deficiencies

The President and the EVP and Chief Financial Officer (CFO) inform the Board of Directors of (a) any material deficiency in the design or operation of internal controls over financial reporting that could affect NewU's ability to record, process, summarize, and report financial data, and (b) any fraud that involves executives or other employees responsible for NewU's financial reporting, disclosures, or internal control over financial reporting.

Progressive Response for Employees and Contractors

NewU responds to a violation of this Code or of any NewU policy in proportion to its seriousness, the circumstances, any prior problems, and the person's role and record. Reasons for a response include poor attendance, poor performance, and inappropriate conduct. The response usually follows these steps:

1. Coaching or written counseling for minor first-time issues. Coaching may include training, mentoring, a review of syllabi or teaching, and monitoring of progress.
2. A formal written warning with a corrective action plan.
3. Suspension, with or without pay, pending investigation or for a stated period. For a contractor, this is a suspension of the engagement; for faculty, it may include removal from a class section.
4. Termination of employment or of the contract, or a decision not to offer a further contract.

NewU also refers matters to law enforcement, licensing bodies, or accreditors where required.

The President may skip earlier steps for serious misconduct, including any conduct that endangers a student, suspected child abuse, sexual misconduct, physical assault, theft, fraud or other dishonesty, falsification of NewU records, a weapon in a NewU setting, secret recording of others, a violation of Substance Use and Smoke-Free Environment, and any conduct that creates legal or reputational risk.

Employment at NewU is at will (Employment at Will); these steps do not change that status. Contract terms govern how a contractor's engagement ends and how a contractor disputes a decision. For faculty, the Independent Contractor Agreement governs, including its dispute steps (Faculty Engagement and Classification).

Faculty Matters and Academic Freedom

Academic Freedom applies to every faculty matter under this Code, and no faculty member is disciplined for the exercise of academic freedom as that policy defines it. Faculty misconduct includes dishonest or unethical conduct in the faculty member's own teaching, preventing or obstructing teaching or any other lawful NewU function, harassment, and neglect of NewU-related duties and responsibilities.

Investigations and Due Process

All credible reports are investigated promptly, fairly, and confidentially by a person without a conflict of interest, appointed by the President. The person concerned is told the substance of the allegation and given an opportunity to respond, except where doing so would compromise an investigation involving suspected abuse or an imminent safety risk. The President decides in writing. Findings, decisions, and outcomes are documented and kept under Records Retention and Destruction.

Reports of harassment, discrimination, and safeguarding concerns go to the Chief Student Journey Officer (CSJO) at [email protected] and follow Anti-Harassment and Discriminatory Conduct and Protection of Minors.

The person concerned may submit one written request for reconsideration to the President within 10 business days of receiving the decision. The President's decision on reconsideration is final, except where a contractor's agreement provides otherwise.

Administration and Accountability

The President administers this Code. Report a suspected violation, including one that involves the President, a director, or the CFO, to the President at [email protected] under Whistleblower and Non-Retaliation. Failing to report a violation, and withholding information about a violation, are themselves violations. Everyone acting for NewU cooperates in internal investigations of possible misconduct. A violation may lead to removal from office, termination of employment, or the end of a contract or volunteer role. A violation may also break the law and lead to criminal or civil liability for the person and for NewU.

Questions about this Code go to the President at [email protected].

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4.2 Conflict of Interest

Applies to: directors, officers, and employees who can influence the actions of NewU. Approved by: the Board of Directors (adopted April 25, 2019). Reviewed: October 2026.

NewU Inc. Conflicts of Interest Policy¹, adopted by the Board of Directors on April 25, 2019. The text below is published as adopted.

Article I. Purpose

The purpose of this conflicts of interest policy (the “Policy”) is to protect the interests of NewU Inc. (the “Organization”), a tax-exempt organization, when it is contemplating entering into a transaction or arrangement that might benefit the private interest of an officer or director of the Organization or might result in a possible excesses benefit transaction. This Policy is intended to supplement but not replace any applicable state and federal laws governing conflicts of interest applicable to nonprofit and charitable organizations.

Tax-exempt status is important both for its continued financial stability and for public support. Consequently, there exists between the Organization and its board, officers and employees, and the public a fiduciary duty, which carries with it a broad and unbending duty of loyalty and fidelity. The board, officers and employees have the responsibly of administering the affairs of the Organization honesty and prudently, and of exercising their best care, skill and judgment for the sole benefit of the Organization. Those persons shall exercise the utmost good faith in all transactions involved in their duties, and shall not use their positions with the Organization or knowledge gained therefrom for their personal benefit. The interest of the Organization must be the first priority in all decisions and actions.

Article II. Scope

This statement is directed not only to directors and officers, but to all employees who can influence the actions of the Organization. For example, this would include all who make purchasing decisions, all persons who might be described as “management personnel,” and anyone who has priority information concerning the Organization. Each such officer, director, or management personnel employee will execute a Certificate in the form attached hereto acknowledging that he or she understands and intends to fully comply with this Policy.

Article III. Definitions

1. Interested Person. Any director, principal officer, or member of a committee with governing board delegated powers, who has a direct or indirect financial interest, as defined below, or any person who makes purchasing decisions, or who might be described as “management personnel”, or anyone who has priority information concerning the Organization, with respect to transactions in which they are in a position to influence the Organization’s decision, is an interested person.
2. Financial Interest. A person has a financial interest if the person has, directly or indirectly, through business, investment, or family:
   1. An ownership or investment interest in any entity with which the Organization has a transaction or arrangement.
   2. A compensation arrangement with the Organization or with any entity or individual with which the Organization has a transaction or arrangement, or
   3. A potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which the Organization is negotiating a transaction or arrangement.

   Compensation includes direct and indirect remuneration as well as gifts or favors that are not insubstantial.

   A person will not be deemed to have a financial interest under paragraphs (a), (b), or (c) above if the only transaction, arrangement or relationship between the entity referred to therein and the Organization is that of donor and donee, respectively. A financial interest is not necessarily a conflict of interest. Under Article IV, Section 2 of this Policy, a person who has a financial interest may have a conflict of interest only if the appropriate governing board or committee decided that a conflict of interest exits.

Article IV. Areas in which Conflicts May Arise

This article provides some illustrations of circumstances when a conflict of interest might arise. The lists are instructive only and not exhaustive. As described above, in accordance with Article IV, Section 2 of this Policy, a person who has a financial interest may have a conflict of interest only if the appropriate governing board or committee of the Organization decided, upon full disclosure, that a conflict of interest exits.

Conflicts of interest may arise in personal dealings of directors, officers or management employees of the Organization with any of the following third parties:

• Persons and firms supplying goods and services to the Organization;
• Persons and firms from whom the Organization leases property and equipment;
• Persons and firms with whom the Organization is dealing or planning to deal in connection with the gift, purchase or sale of real estate, securities, or other property;
• Competing or affinity organizations;
• Donors and others supporting the Organization;
• Agencies, organizations and associations which affect the operations of the Organization;
• Family members, friends, and other employees.

A conflict of interest may arise through but is not limited to:

• Owning stock or holding debt or other proprietary interests in any third party dealing with the Organization.
• Holding office, serving on the board, participating in management, or being otherwise employed (or formerly employed) with any third party dealing with the Organization.
• Receiving remuneration for services with respect to individual transactions involving the Organization.
• Using the Organization’s time, personnel, equipment, supplies, or goodwill for other than the Organization-approved activities, programs, and purposes.
• Receiving personal gifts or loans, from third parties dealing or competing with the Organization.

Article V. Disclosure Policy and Procedure

1. Duty to Disclose. In connection with any actual or potential conflict of interest, an Interested Person must disclose the existence of the Financial Interest and be given the opportunity to disclose all material facts to the directors and members of committees with governing board delegated powers considering the proposed transaction or arrangement.
2. Determining Whether a Conflict of Interest Exists. After disclosure of the Financial Interest and all material facts, and after any discussion with the Interested Person, he or she shall leave the governing board or committee meeting while the determination of a conflict of interest is discussed and voted upon. The remaining board or committee members shall decide if a conflict of interest exists.
3. Procedures for Addressing the Conflict of Interest.
   1. An Interested Person may make a presentation at the governing board or committee meeting, but after the presentation, he or she shall leave the meeting during the discussion of, and the vote on, the transaction or arrangement involving the potential conflict of interest.
   2. The chairperson of the governing board or committee may, if appropriate, appoint a disinterested person or committee to investigate alternatives to the proposed transaction or arrangement.
   3. If a conflict of interest exists, then after exercising due diligence, the governing board or committee shall determine whether the Organization can obtain with reasonable efforts a more advantageous transaction or arrangement from a person or entity that would not give rise to a conflict of interest.
   4. In a case described in paragraph c above, if a more advantageous transaction or arrangement is not reasonably possible under circumstances not producing a conflict of interest, the governing board or committee shall determine by a majority vote of the disinterested directors whether the transaction or arrangement is in the Organization’s best interest, for its own benefit, and whether it is fair and reasonable. In conformity with the above determination it shall make its decision as to whether to enter into the transaction or arrangement.
4. Violations of the Conflicts of Interest Policy.
   1. If the governing board or committee has reasonable cause to believe a member has failed to disclose actual or potential conflicts of interest, it shall inform the member of the basis for such belief and afford the member an opportunity to explain the alleged failure to disclose.
   2. If, after hearing the member's response and after making further investigation as warranted by the circumstances, the governing board or committee determines the member has failed to disclose an actual or potential conflict of interest, it shall take appropriate disciplinary and corrective action.

Article VI. Records and Proceedings

The minutes of the governing board and all committees with board delegated powers shall contain:

1. The names of the persons who disclosed or otherwise were found to have a Financial Interest in connection with an actual or possible conflict of interest, the nature of the Financial Interest, any action taken to determine whether a conflict of interest was present, and the governing board’s or committee’s decision as to whether a conflict of interest in fact existed.
2. The names of the persons who were present for discussions and votes relating to the transaction or arrangement, the content of the discussion, including any alternatives to the proposed transaction or arrangement, and a record of any votes taken in connection with the proceedings.

Article VII. Compensation

1. A voting member of the governing board who receives compensation, directly or indirectly, from the Organization for services is precluded from voting on matters pertaining to that member's compensation.
2. A voting member of any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from the Foundation for services is precluded from voting on matters pertaining to that member's compensation.
3. No voting member of the governing board or any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from the Foundation, either individually or collectively, is prohibited from providing information to any committee regarding compensation.

Article VIII. Annual Statements

All persons defined as Interested Persons shall annually sign a statement which affirms such person:

1. Has received a copy of this Policy,
2. Has read and understands this Policy,
3. Has agreed to comply with this Policy, and
4. Understands that the Organization is a charitable organization, and in order to maintain its federal tax exemption it must be operated exclusively for charitable purposes.

Article IX. Periodic Reviews

To ensure the Organization operates in a manner consistent with charitable purposes and does not engage in activities that could jeopardize its tax-exempt status, periodic reviews shall be conducted. The periodic reviews shall, at a minimum, include the following subjects:

1. Whether compensation arrangements and benefits are reasonable, based on competent survey information, and the result of arm's length bargaining.
2. Whether partnerships, joint ventures, and arrangements with management organizations conform to the Organization’s written policies, are properly recorded, reflect reasonable investment or payments for goods and services, further charitable purposes and do not result in inurement, impermissible private benefit or in an excess benefit transaction.

Article X. Use of Outside Experts

When conducting the period reviews as provided for in Article VIII of this Policy, the Organization may, but need not, use outside advisors. If outside experts are used, their use shall not relieve the governing board of its responsibility for ensuring periodic reviews are conducted.

Certification

I hereby certify as follows:

I have received a copy of the foregoing Conflict of Interest Policy of NewU Inc. I have read it carefully, I understand it, and I agree to comply with the Policy. I understand that NewU Inc., is designated as a 501(c)(3) charitable organization, and that in order to maintain its federal tax exemption, NewU Inc., must be operated exclusively for its tax-exempt purposes.

To the best of my knowledge, except as hereinafter stated, (1) I do not have any financial interest as described in Article III, Section 2 of the Policy (excepting, in the case of an employee of NewU Inc., a compensation arrangement with NewU Inc. that has been approved by the Board of Directors); and (2) I have no interest that conflicts with the interests of NewU Inc., nor do I have any relationship or interest that may appear to present a conflict.

The exceptions are:

If any situation should arise in the future which I believe may cause me to have a conflict of interest with NewU Inc., I will promptly and fully disclose the circumstances to the President or the Chairman of the Board.

(Name and Title)

(Signature)

(Date)

¹ Note: This Policy is modeled on a template developed by the Internal Revenue Service (“IRS”) for nonprofit organizations. The IRS template is available at http://www.irs.gov/instructions/i1023/ar03.html.

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4.3 Whistleblower and Non-Retaliation

Applies to: everyone (students and everyone acting for NewU: directors, officers, employees, contractors including all faculty, and volunteers). Approved by: the President. Reviewed: October 2026.

NewU keeps a culture of openness in which people feel encouraged and confident to raise concerns about suspected misconduct at an early stage. Misconduct, malfeasance, or wrongdoing (together, "misconduct") can harm NewU, so NewU encourages everyone to raise genuine concerns or concrete suspicions of misconduct. This policy gives everyone a safe internal way to raise concerns and protects those who do.

Definitions

• Whistleblower: a person who makes a report under this policy and is protected by it.
• Report: a concern raised under this policy, by the procedure below.
• Concerned Person: a person or organization named in a report as the one to whom the misconduct is attributed or with whom it is associated.

What to Report

Report any suspected violation of NewU policy or law, including misleading financial reporting, use of NewU resources for personal gain, falsifying records, serious ethical misconduct, failure to comply with legal obligations, and financial irregularities (see below).

Where to Report

• Ethics, whistleblower, retaliation, and financial-irregularity reports, including reports about the President, a director, or the EVP and Chief Financial Officer (CFO): the President, at [email protected].
• Harassment, discrimination, and safeguarding reports, and retaliation for making one: the Chief Student Journey Officer (CSJO), at [email protected], under Anti-Harassment and Discriminatory Conduct and Protection of Minors.
• Suspected child abuse or neglect: report immediately to the authorities under Mandated Reporting.
• Emergencies: call 911 first.

A report may be made anonymously.

How to Report

Make the report in writing, by email, at the earliest opportunity. Include as much detail as possible, including, where applicable, the names of individuals, events, locations, and dates. The person who receives the report acknowledges it within 5 working days, unless it was made anonymously.

Review and Investigation

The President reviews each report and is the decision-maker for it.

1. The decision-maker considers the report and the information available and decides whether it falls within this policy or belongs under another NewU policy.
2. If the report does not meet the criteria of this policy, or is otherwise without substance, no further action is taken.
3. If the report falls within another NewU policy, it is referred for action under that policy.
4. If the report falls within this policy, the decision-maker (1) appoints someone inside NewU without a conflict of interest to lead an investigation, (2) appoints someone outside NewU to lead an independent inquiry, or (3) refers the matter directly to the competent authorities for investigation.
5. Reports are investigated as sensitively and quickly as possible, and every concern is treated fairly and properly.
6. When the investigation ends, a written report goes to the decision-maker, who decides what action, if any, to take and gives the person who made the report feedback on the follow-up.
7. The decision is final. The person who made the report may not seek review of it. A Concerned Person who faces discipline has the rights set out in Code of Ethics and Conduct.

Confidentiality and Rights of the Concerned Person

NewU keeps the whistleblower's identity confidential as far as possible. The identity may have to be disclosed to conduct a thorough investigation, to comply with the law, or to give accused individuals their legal rights of defense.

The identity of the Concerned Person is kept confidential. The Concerned Person has rights of defense, including the right to be heard and the right to seek an effective remedy against a decision, and is presumed innocent during the investigation.

Reports are handled confidentially and sensitively. Related material is stored securely, and access to information produced in handling a report is limited to those relevant to the investigation.

Non-Retaliation

NewU prohibits retaliation against anyone who makes a report in good faith or takes part in an investigation, under this or any other NewU policy. Retaliation includes termination of employment, cuts in pay, poor assignments, fewer classes, ending or not renewing a contract or volunteer role, adverse academic action against a student, threats, and intimidation. Retaliation is itself a violation of NewU policy and leads to discipline. Report retaliation to the President at [email protected], or to the CSJO at [email protected] when it follows a report of harassment, discrimination, or a safeguarding concern. Protection from retaliation does not give immunity for any personal wrongdoing that is alleged and investigated.

Good Faith and False Reports

Use sound judgment to avoid baseless allegations. Anyone who knowingly makes a false report is subject to discipline, up to and including dismissal, termination of employment, or the end of a contract.

Financial Irregularities

NewU safeguards its financial assets from theft and misappropriation. A financial irregularity is an intentional misstatement or omission of information related to financial transactions, including embezzlement, fraud, misuse of NewU assets, misappropriation of assets, falsification of records, and noncompliance with laws or regulations.

Everyone reports known or suspected financial irregularities at once to the President at [email protected], including irregularities that involve the President, a director, or the CFO. This single collection point lets NewU review, evaluate, and change its financial and system controls so that similar irregularities do not recur.

NewU investigates every allegation; how it investigates depends on the nature and subject of the allegation. Reports and investigations of financial irregularities are confidential until NewU decides what action to take. NewU may then make disclosures as necessary. Financial irregularities and misappropriation of funds may lead to criminal charges against those responsible. If outside funds are involved, NewU may have to repay them and pay related fines and penalties.

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4.4 Political Activity

Applies to: everyone acting for NewU (directors, officers, employees, contractors including all faculty, and volunteers), and anyone using NewU's name or resources. Approved by: the President. Reviewed: October 2026.

NewU complies with the Internal Revenue Service rules that prohibit the use of NewU resources in political campaign activity for or against candidates. As a 501(c)(3) tax-exempt organization, NewU may not participate or intervene, directly or indirectly, in any political campaign on behalf of or in opposition to any candidate for public office. A violation can lead to excise taxes, penalties, and the loss of NewU's tax-exempt status.

Rules

1. NewU's name, marks, and logo may not be used on letters or other written materials, including social media, intended to support or oppose a political campaign for or against any candidate for public office, political party, or political action committee, including soliciting funds for these purposes. This includes NewU letterhead, envelopes, email accounts, phone lines, and voicemail.
2. No one acting for NewU states, orally or in writing, including on social media, that they speak for NewU when expressing support for or opposition to a candidate for public office. Where silence could be read as NewU's support or opposition, they state explicitly that they speak as individuals, not for NewU. NewU titles are used for identification only.
3. No NewU office, and no office of anyone acting for NewU, may be used as a return mailing address to solicit funds for a political campaign for or against any candidate for public office, or to solicit an endorsement of any candidate, political party, or political action committee.
4. NewU funds, computers, phones, email, accounts, and other equipment or supplies may not be used on behalf of or against any candidate for public office, political party, or political action committee.
5. NewU facilities (classrooms, meeting rooms, and offices) may not be used on behalf of or against any candidate for public office, political party, or political action committee. If a NewU facility is regularly made available to non-NewU groups, it may be made available for political campaign activity only on the same terms that govern other uses and on an equal basis to other candidates.
6. NewU web pages and social media accounts may not be used on behalf of or against any candidate for public office, political party, or political action committee.
7. No one acting for NewU performs tasks related to a political campaign for public office, a political party, or a political action committee in their NewU capacity, and no one is coerced into any political activity, including monetary contributions.

Personal Political Activity

Nothing in this policy prohibits anyone from taking part in political activity in their individual capacity, separate from their relationship to NewU. Employees do so outside work hours or on approved leave. Contractors and volunteers do so outside the time they work for NewU.

See also Use of University Name, Trademark, and Intellectual Property and Acceptable Use of University Systems. Legal basis: Internal Revenue Code, 26 U.S.C. § 501(c)(3).

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4.5 Gifts and Grants

Applies to: NewU and anyone who seeks or accepts gifts or grants for NewU, including directors and the President. Approved by: the President. Reviewed: October 2026.

NewU accepts gifts that promote its goals and mission. The type and purpose of a gift may affect whether NewU can accept it, for example when it carries use restrictions that conflict with NewU policies or the law, involves an unusual type of asset, restricts how the asset may be disposed of, or requires future maintenance costs.

Gifts NewU Does Not Accept

NewU may refuse, or return to the donor, any gift whose functions or goals are inconsistent with NewU's. NewU refuses gifts with use restrictions that are inconsistent with its goals or objectives, and does not accept gifts that would restrict the educational process, conflict with NewU policies, or violate the law.

Approval

The President accepts unrestricted gifts of cash and publicly traded securities of any amount, and reports all gifts and grants to the Board of Directors each year. Prior approval of the Board of Directors is required only for:

• gifts with restrictions, naming, or maintenance costs, including tangible property donated on condition that it be permanently exhibited or maintained in a specific way;
• gifts of real estate, and gifts of other non-cash property that carries costs, such as transfer costs;
• grants whose terms commit NewU to spend or deliver more than $50,000.

Gift Agreements

NewU requires a signed gift agreement for every gift of $5,000 or more that requires a new fund, and for every gift that includes naming. NewU uses gift agreements with donors whenever possible. Send gift and grant documents to the Finance Office at [email protected].

Foreign Gifts and Contracts

Section 117 of the Higher Education Act of 1965, as amended (20 U.S.C. § 1011f), requires institutions that receive a gift from, or enter into a contract with, a foreign source worth $250,000 or more, alone or combined with all other gifts from or contracts with that source in a calendar year, to file a disclosure report with the U.S. Department of Education. Failure to file can lead to civil action and the assessment of costs against NewU.

NewU files the report no later than January 31 or July 31, whichever comes first, after receiving such a gift or signing such a contract. To meet this deadline, NewU aggregates all foreign income, including grants, contracts, and gifts of money and property, to determine whether the threshold has been met.

• Foreign source: a foreign government or any of its agencies; a legal entity, governmental or otherwise, created under the laws of a foreign state; an individual who is not a citizen or national of the United States or a trust territory or protectorate of the United States; or an agent acting for a foreign source.
• Contract: any agreement for the acquisition by purchase, lease, or barter of property or services by the foreign source, for the direct benefit or use of either party.
• Restricted or conditional gift or contract: any endowment, gift, grant, contract, award, present, or property of any kind that includes provisions on the employment, assignment, or termination of faculty; the establishment of departments, centers, research or lecture programs, or new faculty positions; the selection or admission of students; or the award of grants, loans, scholarships, fellowships, or other financial aid restricted to students of a specified country, religion, sex, ethnic origin, or political opinion.

Definitions

• Gift: an unconditional transfer of cash or other assets to NewU, or the cancellation of a NewU liability. Gifts may be unrestricted or restricted.
• Gift agreement: a formal document stating the intended use of a gift and such matters as the payment schedule, donor recognition, and fund naming.
• Real estate: land and anything growing on, attached to, or built on it, excluding anything that can be removed without injury to the land, including houses and commercial property.

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4.6 Policy on Policies

Applies to: everyone acting for NewU (directors, officers, employees, contractors including all faculty, and volunteers). Approved by: the President. Reviewed: October 2026.

I. Purpose

This policy sets the framework and standards for developing, approving, reviewing, revising, and withdrawing NewU policies, so that all policies are consistent, effective, and reflect NewU's mission, vision, objectives, and strategic priorities.

II. Scope

This policy applies to all formal, written NewU policies, including every policy on this page. It does not apply to procedures, guidelines, or other supporting documents unless specified. Procedures that carry out a policy, such as the internal finance manual kept by the EVP and Chief Financial Officer (CFO), are not published on this page.

III. Definitions

1. Policy: a formal, written statement that provides guidance or rules to direct decision-making or action in a particular area.
2. Procedure: a series of steps to be followed to carry out a policy.

IV. Policy Creation, Review, and Revision

1. Policy owner: the office that drafts or revises the policy.
2. Policy development: anyone proposing a new policy or a revision first drafts a proposal that states the need, scope, and implications of the policy. Drafts are evidence-based, aligned with NewU's mission and vision, and written clearly and concisely. Where feasible, the policy owner consults internal and external stakeholders to ensure broad input and support.
3. Policy revision: before submitting a revision for approval, the policy owner carefully considers its implications. A policy may be withdrawn if it becomes obsolete or irrelevant, or is superseded by a new policy. Withdrawing a policy requires the same level of approval as adopting it.

V. Policy Approval

The President approves every NewU policy, except the Conflict of Interest policy, which the Board of Directors adopts. Changes to NewU's mission and vision statements require approval of the Board of Directors (Mission and Vision Review).

VI. Policy Publication

1. All approved policies are published on this page, newu.university/policies/.
2. The policy owner communicates the policy to the people it affects.
3. Policies may be updated from time to time. The version on this page is the current version. NewU notifies students, faculty, and staff of material changes and provides a copy of any policy on request.

VII. Policy Maintenance

1. Every policy is reviewed at least every three years.
2. The policy owner starts the review and updates the policy.
3. Each policy on this page states whom it applies to, who approved it, and when it was last reviewed.

VIII. Record Keeping

1. The President's Office keeps a record of all approved policies, including each version, its policy name, effective date, previous version date, policy owner, approver, approval date, and related documents.
2. Obsolete policies are withdrawn and archived for historical reference.

IX. Exceptions

Any exception to this policy must be approved in writing by the President.

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4.7 Mission and Vision Review

Applies to: the President, the Executive Team, and the Board of Directors, with faculty, staff, students, and alumni taking part. Approved by: the President. Reviewed: October 2026.

Reviewing NewU's mission and vision keeps them aligned with the changing demands of society, advances in academic fields, and the needs of students, faculty, and other stakeholders. NewU's current Mission, Vision, and Values appear at the top of this page.

1. Regular review: the mission and vision statements are reviewed every five years.
2. Inclusion: the review involves faculty, staff, students, alumni, and the Board of Directors.
3. Research and environmental scan: the review includes surveys or focus groups on how NewU's mission and vision are perceived; analyzes trends in higher education, society, and workforce needs; and compares the mission and vision statements of peer institutions.
4. Strategic planning: any change or reaffirmation is aligned with NewU's strategic plan, or the revised mission and vision become the foundation for future strategic planning.
5. Flexibility and stability: the mission (the core purpose) may stay largely stable over time, while the vision (the desired future state) may need to adapt to changing circumstances.
6. Communication and transparency: the President, the Executive Team, and the Board explain the reasons for a review to all stakeholders, share the process, and gather feedback at several stages. Once revisions are final, they share the updated mission and vision widely and make sure stakeholders understand the changes and their implications.
7. Integration: the mission and vision are built into NewU's daily operations, decision-making, and culture.
8. Continuous monitoring: between formal reviews, NewU keeps track of how the mission and vision resonate and whether they remain relevant.
9. Documentation: the Executive Team documents the process, outcomes, and reasons for any changes, for institutional memory and future reviews.
10. Approval: changes to the mission and vision require approval of the Board of Directors.
11. Education and training: after a revision, the Executive Team makes sure the NewU community learns about it, through orientation sessions, workshops, and ongoing training.
12. Recognition: the Executive Team uses each revision or reaffirmation to celebrate NewU's identity and reinforce its commitment to its foundational values and aspirations.

The mission and vision statements are foundational, but they are not set in stone. As NewU evolves, so do its guiding documents, as long as they remain true to its core values and aspirations.

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4.8 Faculty and Student Representation to the Board

Applies to: faculty, students, and the Board of Directors. Approved by: the President. Reviewed: October 2026.

Faculty and students, as key stakeholders, have a voice in NewU's governance and strategic direction. This policy fosters open communication, transparency, and collaboration between the Board of Directors and the wider NewU community. It covers the nomination, selection, and participation of the faculty and student representatives to the Board of Directors.

Faculty Representative

One faculty member is elected each year to serve as Faculty Representative to the Board. Any faculty member is eligible. Any faculty member may nominate another faculty member or self-nominate. The faculty organize and hold the Faculty Representative election at the start of each academic year. Only NewU faculty members vote, each casting one vote per election, by secret ballot, and the candidate with the most votes is elected. If no faculty nominations come forward, the Chief Academic Officer serves as Faculty Representative to the Board. The Faculty Representative serves a term of one calendar year and may be re-elected, for up to three consecutive terms in total.

Student Representative

One student, elected by the student body, serves as Student Representative to the Board. The Student Government Bylaws govern who serves as the Student Representative to the Board.

Roles and Responsibilities

• The representatives take an active part in Board meetings, bringing forward the concerns, ideas, and perspectives of the faculty and students.
• They serve as a bridge between the Board and the wider faculty and student body, making sure that Board decisions are communicated back to the community.
• They keep Board matters confidential and respect the Board's decision-making processes.

Conduct

Although they are not members of the Board, the faculty and student representatives follow the Code of Ethics and Conduct that applies to directors, with professionalism, mutual respect, and commitment to NewU's mission and vision.

Orientation

The representatives complete an orientation on the Board's functions, governance structure, and responsibilities.

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4.9 Financial Management and Approval Authority

Applies to: everyone acting for NewU (directors, officers, employees, contractors including all faculty, and volunteers). Approved by: the President. Reviewed: October 2026.

Everyone who spends, receives, approves, or records money for NewU is accountable for doing it on time and correctly. This policy covers all of NewU's business activities. Tasks may be delegated, but accountability cannot: the person who delegates a task remains responsible for its proper performance. Supervisors make sure the people they supervise know this policy. The EVP and Chief Financial Officer (CFO) is the designated officer for this policy and its procedures, which are in the internal finance manual kept by the CFO.

Budget

The CFO prepares NewU's budget with the President and the executive team, in line with NewU's mission and strategy. NewU uses the incremental budget model.

Recording Transactions

• All revenues and expenditures are recorded in NewU's accounting system. Revenues are recorded when earned, generally when NewU has delivered the goods or services; expenses are recorded when NewU receives the goods or services. Holding an invoice or contract does not stop an expense from being incurred and reportable, so invoices go to [email protected] as soon as they arrive.
• Every transaction, whatever its amount, is recorded in the general ledger with an accurate description and complete supporting documents, so that financial statements can be prepared under generally accepted accounting principles in the United States (U.S. GAAP).
• Transactions are recorded on time and accurately, with their true business nature identified, following the monthly closing calendar and schedules the CFO issues.
• No transaction and no supporting document may be deliberately left incomplete or distorted. No payment is approved with the understanding that any part of it is for a purpose other than the one stated in its supporting documents.

Oversight and Internal Controls

The CFO is responsible for the accuracy, integrity, and overall management of NewU's financial system, is consulted on accounting policies and procedures, and oversees financial transactions. Working with others at NewU, the CFO makes sure that:

• transactions are reviewed and approved by someone with the appropriate knowledge and authority;
• NewU keeps its accounting records, supplier information, and contracts in its accounting and records systems, with backups;
• internal controls are in place, including segregation of duties, access to physical assets and data limited to each person's job responsibilities, and monitoring of financial results;
• periodic account reports are reviewed for accuracy and completeness, with budget-to-actual and year-over-year comparisons; significant variances are investigated, and the reasons and any corrective plan are documented;
• entries are properly allocated to NewU's chart of accounts and match the purpose of each account; new accounts need the CFO's prior approval;
• charges to restricted accounts follow the donor's restrictions and are allowable under the donor's terms;
• NewU property, cash, checks, and card receipts are secured and accounted for (see Receiving Payments and Card Security and Fixed Assets).

When NewU accepts federal funds, it follows the federal rules and terms that come with them. An independent certified public accountant audits NewU's finances each year.

Approval Authority

These thresholds apply to every purchase preauthorization, purchase, contract, lease, loan, and acquisition or disposal of fixed assets, and to expense reports and accounting corrections. Splitting a transaction to avoid a threshold is prohibited.

A related-party contract or transaction is one in which an Interested Person, as defined in the Conflict of Interest policy, has a financial interest. It includes any engagement or pay of a relative of a director or officer (Relatives and Domestic Partners). The President's own expenses and card charges are approved by the Board Treasurer, or by the Chair of the Board if the office is vacant (Expenses and Corporate Cards).

Contracts

Contract signing is governed by NewU's Bylaws; Board resolutions authorize the President to sign contracts that bind NewU. A contract with a financial commitment over $50,000, and any related-party contract, needs prior approval of the Board of Directors.

Emergencies

In an emergency, no one commits NewU to more than $50,000 before the Board of Directors approves. The Board can act by written consent if the Bylaws allow. Emergency rules waive bidding only (Purchasing); the approval thresholds still apply.

Corrections

NewU records each transaction to the proper account and funding source when it happens. When a correction is needed, including to payroll, payables, or cost transfers, it is identified as soon as possible, evaluated for materiality, and processed and recorded correctly and promptly. Report an improper charge to the CFO at [email protected] as soon as you discover it. Corrections follow the thresholds above and stop at the President. A correction to a transaction that crosses NewU's fiscal year end is also reported to and approved by the CFO.

Bank Accounts

The President opens and closes NewU bank accounts under the authority of the Board of Directors. No other officer, employee, or contractor may open a bank account with NewU funds or in NewU's name, or close a NewU bank account. The CFO keeps the record of all NewU accounts and their authorized signers.

Taxes

The CFO makes sure all applicable federal, District, and state taxes are paid on time to the right authorities (Tax and Unclaimed Property Compliance).

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4.10 Purchasing

Applies to: everyone acting for NewU who buys goods or services for NewU. Approved by: the President. Reviewed: October 2026.

NewU buys goods and services from outside sources on the basis of sound business practice, best value, accountability, and compliance with donor, grant, and regulatory requirements. Every purchase has enough supporting documents to justify the supplier selection, the competitive process, and the price NewU pays. The EVP and Chief Financial Officer (CFO) is NewU's authority for buying goods and services from outside sources and has general responsibility for NewU's purchasing. Everyone who buys for NewU acts as a steward of NewU funds. Purchasing procedures are in the internal finance manual kept by the CFO.

Best Value

NewU seeks goods and services that give the best value and meet or exceed the required specifications. Buyers consider price, quality, and reliability, as well as the capability, capacity, and past performance of the supplier. Each purchase has appropriate service and delivery terms, and NewU uses competitive processes whenever possible and practical. Purchases for grant-funded activities follow the donor's or grantor's requirements.

Supplier Standards

NewU buys in an ethical, legal, and socially responsible way and expects its suppliers to share this commitment. Suppliers comply with all applicable laws, codes, and regulations of the countries, states, and localities where they operate, including those on the environment, occupational health and safety, and labor practices, and require their own suppliers, including temporary labor agencies, to do the same. NewU keeps supplier records, contracts, and payment history in its accounting and records systems.

Related Parties

A purchase or contract with a related party needs prior approval of the Board of Directors, at any amount (Financial Management and Approval Authority; Conflict of Interest).

Competitive Bidding for Major Purchases

A major purchase is the purchase of goods and services from one supplier totaling $25,000 or more in a year. Every major purchase requires bidding and review before the supplier is engaged. Send the contract requirements, the bids received with their quotations, and other supporting documents to the CFO at [email protected]. The CFO considers:

• any prior work history with NewU (quality of work, budget overruns, delivery dates);
• price compared with other proposals;
• the supplier's financial ability to complete the contract;
• the quality of the products or services and the ability to deliver on time;
• estimated delivery dates;
• supplier references;
• the supplier's policy on complying with equal employment opportunity and other fair labor laws.

When a supplier is selected, a report goes to the President naming the supplier and the reasons for the selection. Approval follows the thresholds in Financial Management and Approval Authority. If a contract's value is over $50,000, the Board of Directors approves its terms before it binds NewU.

Bidding is not required for faculty and other individual contracts, for renewals of systems already in use, or for sole-source purchases with a written reason approved by the CFO.

Emergency Purchases

An emergency is an event, natural or human-caused, intentional or accidental, that threatens the health or safety of the NewU community, causes loss of or damage to NewU property or its environment, or disrupts normal NewU operations, and so calls for immediate action.

Everyone anticipates their needs for goods and services so that emergency purchases can be avoided, and follows the standard purchasing rules in an emergency when possible. When an emergency calls for immediate purchases, the CFO or a designee may waive competitive bidding and approve expedited purchases of goods and services essential to the response. The waiver is documented in writing or by email. Emergency rules waive bidding only: the approval thresholds still apply, and no one commits NewU to more than $50,000 before the Board of Directors approves. The CFO sets emergency purchasing procedures to keep NewU's operations running.

Before buying, the person in charge of an emergency purchase confirms that funds are available or requests them from the CFO; approval is given in writing or by email. That person tracks emergency spending and sends the CFO the financial documents and the reasons for the emergency purchase within 30 days after the incident ends, or sooner on request.

Receiving and Returns

The person who orders goods inspects them on arrival against the order and confirms receipt to [email protected]. NewU does not accept defective goods: they are refused or returned to the supplier, and card purchases are credited back to the card. During a warranty period, the person in charge of the goods contacts the supplier for service and tells the CFO if the service is not provided or the warranty needs to be extended.

Agreements Outside This Policy

A purchase agreement made in a way that is inconsistent with this policy is voidable by NewU.

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4.11 Paying Suppliers and Contractors

Applies to: everyone acting for NewU who orders goods or services or requests a payment, and every supplier and contractor (including all faculty) who invoices NewU. Approved by: the President. Reviewed: October 2026.

This policy covers every payment NewU makes, including payments to suppliers, payments for services, tax payments, awards, and stipends. Payment procedures, including supplier setup and lead times, are in the internal finance manual kept by the EVP and Chief Financial Officer (CFO).

Invoices

Suppliers and contractors, including faculty, send all invoices to [email protected]. NewU pays invoices on or before their due date under NewU's payment terms or the terms on the invoice, unless a discount offered for early payment makes earlier payment favorable. Before payment, the person who ordered the goods or services confirms that they were received as ordered. NewU prefers to avoid freight charges; any freight charge must be agreed when the order is placed.

Contractors, including faculty, are paid under their agreements against an approved invoice and are responsible for all taxes on their pay.

Payment Methods

NewU aims to be cashless, for cost, efficiency, transparency, and record keeping. In order of preference, NewU pays by:

1. electronic payment (Automated Clearing House (ACH) transfer, or debit or credit card);
2. wire transfer;
3. paper check;
4. cashier's check, only at the payee's request and with the CFO's prior approval;
5. cash, only with the CFO's prior approval, and never more than $10,000.

NewU chooses the method based on cost (the most cost-effective method that can be delivered securely and limits the risk of fraud or misuse), the currency required, and how time-sensitive the payment is. Only U.S. dollar payments are made by ACH, card, or paper check. Suppliers are paid by ACH to the account and financial institution they designate, under the agreed payment terms. Employees are reimbursed by ACH to the account used for their pay. Paper checks are mailed to the payee; holding a check for pickup requires the CFO's prior approval.

Wire Transfers and Payments in Other Currencies

NewU makes payments in U.S. dollars. In certain circumstances, NewU pays in a non-U.S. currency by wire transfer or by bank draft. Wire transfers cost more, so NewU uses them only when business needs require them. Send wire and foreign-currency payment requests, with supporting documents showing the amount and currency, the business purpose, the payee's name and address, and the date and nature of the transaction, to [email protected] well before the due date. Payments to a new supplier or to a non-U.S. payee need extra time to set up and verify the payee. NewU is prohibited by law from making payments in non-U.S. currencies to certain foreign countries or persons in them, for example under economic sanctions.

Tax Reporting

NewU collects a Form W-9 from every U.S. contractor before the first payment and files the required Forms 1099. Payments to non-U.S. persons are reviewed for tax withholding before payment.

Overpayments

A supplier or contractor who receives more than the amount due tells [email protected] and repays the overpayment promptly. Employee overpayments are covered by Pay and Deductions.

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4.12 Receiving Payments and Card Security

Applies to: everyone (students and everyone acting for NewU), and outside parties that take card payments at NewU events or for NewU. Approved by: the President. Reviewed: October 2026.

NewU prefers electronic payment and aims to be cashless. Tuition and fee payment terms for students are in Tuition, Fees, and Refunds. Procedures for handling deposits, checks, and card transactions are in the internal finance manual kept by the EVP and Chief Financial Officer (CFO).

Payments to NewU

• Checks are made payable to “NewU Inc.” or “NewU.” No payment to NewU may be made payable to an individual.
• Every payment to NewU is deposited in a NewU account.
• Cash, checks, and card receipts are deposited on the day they are received.
• Accepting cash of any amount requires the CFO's prior approval.
• Physical checks are kept secure for at least 90 days and then destroyed securely.

Card Payments and Data Security

Credit and debit cardholder information is regulated information that must be secured. NewU complies with the Payment Card Industry Data Security Standard (PCI DSS) and protects cardholder information against loss and fraud when it is processed, transmitted, and disposed of. Failure to comply can lead to fines, loss of the ability to accept cards, and harm to NewU's reputation. Cardholder information is also protected under Acceptable Use of University Systems.

• NewU takes card payments only through NewU-approved payment processing methods.
• Card data is never stored. Once a payment is authorized, no one acting for NewU writes down, keeps, scans, or emails a full card number, security code, PIN, or card track data.
• NewU keeps card transaction records (sales drafts, cardholder consents for preauthorized orders, and credit drafts) for three years from the transaction date, without full card numbers.
• The CFO issues all card merchant accounts, arranges NewU-approved card acceptance services, and approves card procedures. No NewU office collects, processes, stores, transmits, or displays card information without the CFO's advance approval, whether the transaction happens in person, by phone, fax, mail, or online, or through a NewU-approved third-party vendor.
• An office with a business need to accept cards contacts the CFO before accepting any payment, to obtain a merchant account, training, and an approved secure payment method.
• Anyone at NewU who manages or contracts with outside parties, such as caterers, partner organizations, or event organizers, that intend to take card payments at a NewU event or for NewU obtains the CFO's review and approval first.
• NewU's wired and wireless networks may not be used to accept payment cards.

Cardholder information means any information about a credit or debit card, including the card number, cardholder name, card verification code (CVC, CVV, or CID), expiration date, personal identification number (PIN), and password.

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4.13 Expenses and Corporate Cards

Applies to: employees; contractors (including all faculty), students, and other non-employees as stated below. Approved by: the President. Reviewed: October 2026.

Everyone who incurs a business expense for NewU exercises good stewardship and follows this policy, and every approver enforces it. This policy covers expenses for NewU travel and local expenses for NewU business, whatever the account or funding source. Expense and card procedures are in the internal finance manual kept by the EVP and Chief Financial Officer (CFO).

Permitted Expenses

NewU incurs or reimburses expenses that are:

• actual, necessary, and reasonable;
• for a NewU business purpose;
• documented, approved, and submitted properly; and
• consistent with NewU's business objectives.

If you have any doubt about whether an expense is proper, ask your supervisor or the CFO before you incur it. Any exception to this policy needs the CFO's written approval in advance, attached to the expense report. Unallowable or excess expenses, and travel advances, are the employee's responsibility and are repaid within 60 days if NewU funds paid them. Expenses charged to a grant are approved under this policy and the grant's terms.

Receipts and Submission

• Every expense is itemized and supported by a receipt showing the date, the vendor, the items and unit prices, and the total paid.
• Submit expense reports with receipts to [email protected] within 15 calendar days of the expense or of the end of the trip. Corporate card transactions may be reported monthly.
• Report expenses in the currency of the receipt; the Finance Office converts them to U.S. dollars.
• Keep original receipts until the report is fully processed and paid.
• A missing receipt should be rare. When an itemized receipt cannot be obtained, complete a missing receipt statement or attach the CFO's email approval.
• Corporate card expenses not reported within 60 days may be added to the employee's taxable income and reported on the employee's Form W-2, as Internal Revenue Service rules require.

Approval

Expense reports follow the thresholds in Financial Management and Approval Authority and stop at the President. No one approves their own expenses, or the expenses of someone they report to. The President's own expenses and corporate card charges are approved by the Board Treasurer, or by the Chair of the Board if the office of Treasurer is vacant.

Each approver:

1. requires everyone who incurs expenses for NewU to follow this policy;
2. verifies the purpose and reasonableness of each expense;
3. reviews the receipts and confirms that the expenses are actual business expenses, not personal ones;
4. verifies that any exception has the CFO's advance approval attached; and
5. rejects any expense that does not comply with this policy.

Contractors, Students, and Other Non-Employees

Contractors, including faculty, are reimbursed only for expenses the CFO approves in writing in advance, billed on their invoice under their agreement. Students and other non-employees, such as honorarium recipients, send reimbursement requests for NewU business expenses, with itemized receipts, to [email protected] for the CFO's approval.

Corporate Cards

NewU may issue corporate cards to employees for purchases that benefit NewU and for payment while traveling on NewU business. A corporate card is a corporate liability card with NewU as the cardholder. It is only a way to buy and pay: it does not change any NewU policy on preferred vendors, restricted purchases, competition, or documentation.

• Eligibility: a card is issued only with the CFO's approval, to an employee who has completed training, has never had a card suspended for late expense reporting or misuse, and has a supervisor who reviews and approves the card's charges (for the President, the Board Treasurer or the Chair of the Board, as above).
• Individual cards: cards are individual and cannot be transferred. Each employee who needs a card applies for one.
• Lost or stolen cards: report them at once to the issuing bank and to the CFO.
• Monitoring: the CFO or a designee monitors card activity. A card used for purchases that are not allowed is cancelled.
• Leaving NewU: the card is returned to NewU immediately when employment ends.

Personal purchases on a corporate card are prohibited. The following purchases are also prohibited:

• any order over the cardholder's single transaction limit, unless the CFO approves it in writing in advance; splitting an order into smaller transactions to stay under the limit is prohibited;
• services performed by an individual or a single-owner limited liability company;
• gasoline for personal vehicles;
• prizes, awards, gift cards, and other cash equivalents, unless the CFO approves them in writing in advance, with the approval attached to the expense report;
• special occasion items for specific individuals (such as flowers, fruit baskets, candy, or balloons), unless the CFO approves them in advance, with the approval attached to the expense report;
• any purchase prohibited by another NewU policy.

Misuse of a card leads to suspension or cancellation of the card and may lead to discipline, including termination of employment, criminal prosecution, and repayment of unauthorized purchases with any collection costs and attorneys' fees.

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4.14 Fixed Assets

Applies to: everyone acting for NewU (directors, officers, employees, contractors including all faculty, and volunteers). Approved by: the President. Reviewed: October 2026.

NewU safeguards its fixed assets, keeps effective internal controls over them, and keeps proper records of their use and disposal, so that it gets full benefit from them, meets NewU and donor requirements on their use and disposal, and accounts for them correctly. This policy applies to fixed assets acquired with NewU or outside funding, and by gift or loan. Asset tagging, inventory, and record procedures are in the internal finance manual kept by the EVP and Chief Financial Officer (CFO).

What Counts as a Fixed Asset

A fixed asset is any tangible property, furniture, equipment, or software used in NewU's day-to-day operations that has a useful life of more than one year and a unit cost or gift value of $500 or more. Bulk purchases of $500 or more of the same item (for example, laptops or office chairs), or of items used for the same purpose, are capitalized as one item. Fixed assets include office furniture and fixtures, computers and other technology equipment, and software.

Acquiring Fixed Assets

Fixed assets are bought through NewU's approved purchasing methods (Purchasing).

Records and Inventory

The CFO, or one or more designees each responsible for a set of assets, controls and maintains fixed assets and their records. This includes recording, on time, every purchase, gift, loan, transfer, sale, or other disposal; keeping the information needed to control, protect, and maintain each asset; reconciling the records with the general ledger; and accounting for acquisition, capitalization, depreciation, and disposal under U.S. GAAP. The CFO or a designee conducts an annual physical inventory to verify the existence and location of fixed assets and the accuracy of NewU's records.

Disposal

Disposal means the sale, transfer of ownership, or final disposal of a fixed asset. To dispose of a fixed asset, the person responsible for it seeks approval under the thresholds in Financial Management and Approval Authority, which stop at the President. NewU looks for ways to dispose of fully amortized assets, such as a charitable donation.

Loss or Theft

Report the loss or theft of any fixed asset, including electronic equipment, to the CFO at [email protected] as soon as you discover it.

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4.15 Tax and Unclaimed Property Compliance

Applies to: everyone acting for NewU (directors, officers, employees, contractors including all faculty, and volunteers). Approved by: the President. Reviewed: October 2026.

NewU files its tax returns and reports, and pays any tax due, on time and in compliance with federal, District, state, and local law. The EVP and Chief Financial Officer (CFO) is responsible for this policy. Filing forms and step-by-step procedures are in the internal finance manual kept by the CFO.

Unrelated Business Income

NewU is a 501(c)(3) tax-exempt organization. It is exempt from tax on income related to its exempt purpose, which is education (for example, tuition revenue). Income from a trade or business not related to that purpose is "unrelated business income" under Internal Revenue Service rules and is subject to annual reporting and income tax. NewU identifies and reports unrelated business income on its annual return and pays any tax due.

Income from an activity is subject to unrelated business income tax when all three of these are present:

1. the activity is not substantially related to NewU's exempt purpose;
2. the activity is a trade or business; and
3. NewU carries on the activity regularly.

• Substantially related: an activity that contributes importantly to NewU's tax-exempt purposes. An activity is related only when its conduct has a substantial causal relationship to achieving those purposes.
• Trade or business: any activity carried on to produce income from selling goods or performing services, in a manner similar to a for-profit business.
• Regularly carried on: judged by the frequency and continuity of the activity and the way it is pursued. An activity that commercial organizations normally conduct year-round is not regularly carried on if NewU conducts it for only a few weeks.

Anyone planning an activity that may earn income outside NewU's educational mission contacts the CFO first.

Sales Tax

NewU collects, records, reports, and remits sales tax on time wherever the law requires it. DC and other jurisdictions require sellers to collect sales tax on the sale or rental of tangible personal property and on selected services. NewU collects sales tax on the sale or rental of tangible personal property (such as mugs, T-shirts, and concessions), on selected services, and on ticket sales for admission to public events. Services related to NewU's core educational mission, such as teaching services, internships, research, and related consulting agreements, are generally not subject to sales tax. NewU's exemption from sales tax on qualified purchases for its educational operations does not extend to resale by other groups or individuals, such as students or employees.

Contractor Tax Reporting

NewU collects a Form W-9 from every U.S. contractor before the first payment and files the required Forms 1099. Payments to non-U.S. persons are reviewed for tax withholding before payment.

Unclaimed Property

Unclaimed property is any tangible or intangible property, presumed abandoned, that NewU holds or owes in the normal conduct of its business and that the owner (a student, employee, vendor, or other person) has not claimed for more than the required period after it became payable or distributable. It includes unclaimed checks and credit balances on accounts.

• Each year, NewU reviews its records and reports and remits unclaimed property to the District of Columbia Office of Finance and Treasury, Unclaimed Property Unit, as District of Columbia unclaimed property law requires.
• The dormancy period for most items is three years; for unclaimed payroll checks, it is one year.
• NewU makes a good faith effort to find the owner. Where the property is a check NewU issued, NewU notifies the owner by email or by letter to the last known address and issues a replacement check on request. If the owner does not respond by the deadline, NewU remits the property to the Unclaimed Property Unit.
• The CFO or a designee identifies, reports, and remits unclaimed property for the period ended June 30 before November 1 of each year, on the District's required form.

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4.16 Background Screening

Applies to: employees, contractors (including all faculty), volunteers, vendor personnel with ongoing access to students, and candidates for these roles. Approved by: the President. Reviewed: October 2026.

Every offer of employment, every faculty and staff contract, every volunteer role, and every other contractor or vendor role with recurring contact with students is contingent on clearing a background check. All hiring and contracting decisions that involve contact with minor students include background screening, reference checks, and probationary monitoring, as Child Protection and Safeguarding requires. Checks are completed on the timing set in the person's employment or engagement terms.

What the Check Covers

• Prior employment: NewU confirms the candidate's employment with the employers listed, including dates of employment, positions held, and any available information on performance, reason for leaving, and eligibility for rehire. This covers the past two employers or the previous five years, whichever comes first.
• References: NewU contacts the personal and professional references the candidate lists.
• Education and credentials: NewU confirms the educational institutions the candidate claims, the years attended, and the degrees or diplomas received. For faculty, NewU also verifies educational credentials and professional qualifications.
• Criminal history: NewU reviews criminal convictions and probation, considering the nature of any crime and its relationship to the role, the time since the conviction, the number of convictions, and whether engaging the person would pose an unreasonable risk to NewU, its employees, or its students.

Procedure

Candidates offered employment or a contract, and volunteers, complete a background check authorization form when the offer is made and return it to the HR office at [email protected]. NewU asks about and investigates criminal history only after extending a conditional offer of employment or engagement. NewU runs background checks in-house and may also use a screening service. The HR office reviews all results.

Where a check returns negative or incomplete information, the President assesses the risks related to the role and decides whether to proceed. If NewU decides not to proceed based on a report from a screening service, NewU follows the requirements of the Fair Credit Reporting Act (FCRA).

Faculty and student-facing staff also complete the safeguarding compliance orientation required by Protection of Minors.

Records

Background check information is kept separate from personnel and contractor files for at least five years (Records Retention and Destruction).

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4.17 Personnel and Contractor Files

Applies to: employees and contractors (including all faculty). Approved by: the President. Reviewed: October 2026.

The EVP and Chief Financial Officer (CFO) keeps personnel files for employees and contractor files for faculty and other contractors, including their credentials. These files are confidential. Background check information is kept separately (Background Screening). Student education records are governed by Privacy and Education Records.

Access to Your File

Employees and contractors, or their representatives, may ask in writing to see their own file, by email to the HR office at [email protected]. Access is generally given within 3 days of the request. The file is reviewed in the presence of the record keeper, or a copy is provided. Access does not extend to:

1. confidential information from a source who was promised that their identity would not be disclosed, unless all information identifying the source is removed;
2. medical records that, in the opinion of the person's doctor, would harm the person's health if disclosed;
3. criminal investigation records.

Representatives of government or law enforcement agencies may be given access to file information when their official duties require it.

Correcting Your File

Each employee and contractor may add information directly relevant to anything in their official file and may ask to have irrelevant, immaterial, or untimely information removed. Information other than a record of an official personnel action is untimely if it concerns an event more than 3 years in the past on which an adverse action could be based. The President decides disputes about access and requests for removal. Information the President finds immaterial, irrelevant, or untimely is removed from the file.

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4.18 Relatives and Domestic Partners

Applies to: everyone acting for NewU (directors, officers, employees, contractors including all faculty, and volunteers), and applicants. Approved by: the President. Reviewed: October 2026.

This policy keeps decisions fair, prevents conflicts of interest, and maintains professionalism and trust at NewU. Relationships between anyone acting for NewU and a student are governed by Adult-Student Boundaries and Code of Interactions.

Definitions

• Relative: any person related by blood, adoption, or marriage, including siblings, parents, children, grandparents, spouses, in-laws, and cousins.
• Domestic partner: a person, of any gender, who shares an ongoing, committed relationship and a shared home with another person, without a formal or legal marriage.

Rules

1. Fair decisions: all hiring, engagement, promotion, and other employment and contracting decisions are based on individual qualifications, job requirements, and performance, without regard to a person's relationship to anyone at NewU.
2. Disclosure: everyone covered by this policy discloses, in writing to the President through the HR office at [email protected], any relative or domestic partner who also works at NewU or serves on the Board of Directors, at hiring or engagement, at promotion, or when the relationship develops.
3. Work assignments: relatives and domestic partners do not work directly under or supervise one another, and are not placed where one influences the other's terms of work, including pay, hours, benefits, duties, and evaluations.
4. Hiring: applicants related to current employees, contractors, or directors go through the same selection process as every other candidate. Anyone with a conflict of interest, or the appearance of one, because of a relationship with an applicant recuses from the decision.
5. Related parties: any engagement or pay of a relative or domestic partner of a director or officer is a related-party matter and needs prior approval of the Board of Directors (Conflict of Interest; Financial Management and Approval Authority).
6. Benefits: where NewU offers benefits to family members, relatives and domestic partners of employees are eligible on the usual terms. Any tax consequences are the employee's responsibility.
7. Conflict resolution: if a conflict between relatives or domestic partners affects work, they may be asked to seek mediation or counseling. If the issue continues, NewU may change their assignments.
8. End of a relationship: if a romantic relationship between people who work at NewU ends, both are expected to remain professional at work. If issues arise, the President addresses them, which may include a change in work assignments or other appropriate action.

Exemptions

Relatives and domestic partners whose relationship existed before NewU's incorporation are exempt from the work-assignment and supervision rule (rule 3) only. The President may also exempt senior leadership, specialized technical, or other critical roles from rule 3, case by case. The disclosure rule and the related-party rule always apply, with no exemption.

Consequences

Failure to follow this policy, or to disclose a relationship as required, may lead to discipline, up to and including termination of employment or of the contract (Code of Ethics and Conduct).

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4.19 Safety and Security

Applies to: everyone (students and everyone acting for NewU), and visitors, vendors, and guests. Approved by: the President. Reviewed: October 2026.

NewU does not tolerate acts or threats of violence by or against students, employees, faculty, contractors, volunteers, visitors, or other third parties on NewU premises, in NewU online settings, or in connection with NewU events or programs. NewU uses every useful strategy to identify and prevent violence, to reduce its effects on victims, and to respond to those who threaten or commit it. Student conduct rules, including the rules on violence and weapons for students, are in the Code of Conduct.

Emergencies

If anyone is in danger or needs medical help, call 911 first. Then reach the President or the EVP and Chief Financial Officer (CFO) by the fastest means available. NewU's text line, 202.968.1005, is also its emergency broadcast number; save it and do not reply STOP to it (Institutional Communications).

Respect and Civility

Members of the NewU community treat one another with civility, respect, and consideration, recognizing that disagreement and informed debate are valued in an academic community. Demeaning, intimidating, threatening, or violent behavior that affects the ability to learn or work at NewU departs from this standard and has no place at NewU.

Violence and Threats

Violence is behavior that causes harm to a person or damage to property, or causes fear for one's own safety or the safety of others, including harmful physical contact and expressions of intent to cause physical harm. A threat includes verbal or physical harassment or abuse, attempts to intimidate others, menacing gestures, stalking, and any other hostile, aggressive, or destructive action taken to intimidate. Threats, threatening language, and acts of aggression or violence are not tolerated. Do not engage in a physical confrontation with a violent or potentially violent person. NewU refers violence to law enforcement and cooperates fully with prosecution.

Weapons

Weapons of any kind are prohibited on NewU premises and at NewU activities at all times. No one acting for NewU carries a weapon of any type while performing services for NewU. Weapons include handguns, rifles, automatic weapons, knives that can be used as weapons (but not pocketknives, utility knives, and similar tools used to open packages, cut string, and do other everyday tasks), martial arts weapons, stun guns, and tear gas. Anyone acting for NewU who violates this rule is subject to discipline, up to and including termination of employment or of the contract, for the first offense.

Reporting Threats and Unsafe Conditions

• Imminent danger: call 911, then tell the President or the CFO.
• Other violent, potentially violent, or threatening behavior, or advice on what to do: tell the President at [email protected] or the CFO, who heads campus operations. Students may also report through [email protected].
• Harassment or a concern about a minor: follow Anti-Harassment and Discriminatory Conduct and Mandated Reporting.

All threats are investigated promptly, and appropriate action is taken. No one is subject to retaliation for reporting in good faith (Whistleblower and Non-Retaliation).

Safety Responsibilities

Everyone acting for NewU carries out their work safely, in compliance with local, District, and federal safety and health regulations and standards and with the safety concerns NewU identifies, and takes responsibility for individual and organizational safety. Each person learns the emergency procedures for the places where they work. NewU's campus emergency plan sets out procedures for fire, weather emergencies, medical emergencies, and violence, and is posted on campus. Report each safety or health incident you cause or witness to the President in an accident and incident report. Each employee signs a safety statement at orientation. The CFO, who heads campus operations, develops and implements NewU's safety and health program.

Visitors

Visitors, vendors, and the families of members of the NewU community follow this policy. Behavior that does not comply leads to removal from the campus (Guests and Visitors).

Violations

Anyone who violates this policy, or whose conduct places a student, employee, contractor, volunteer, visitor, or property at risk, is subject to discipline, which may include separation from NewU: for students under Student Discipline, and for everyone acting for NewU under the Code of Ethics and Conduct.

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4.20 Guests and Visitors

Applies to: everyone (students and everyone acting for NewU), and every guest and visitor. Approved by: the President. Reviewed: October 2026.

NewU strives to create a welcoming environment for students, faculty, staff, and approved visitors and guests. To ensure the proper conduct of university business and the safety and security of our community, this policy sets out the rules governing guests and visitors on NewU premises or at NewU-sponsored activities.

Who Is a Guest or Visitor

Any person who is not a member of the NewU community at the time of that person's physical or virtual visit is a guest or visitor for purposes of this policy.

Members of the NewU community include only the following: actively enrolled students, current employees, faculty and other contractors currently engaged by NewU, current volunteers under a signed volunteer agreement, current board members, and current officers of NewU Inc.

Anyone else is a guest or visitor, including but not limited to relatives, friends, acquaintances, business associates, prospective students, former students, alumni, guest speakers, business or academic partners, regulators, and donors.

Authorization to Visit

All guests and visitors must be approved to visit by express written permission issued by an authorized NewU representative in advance of each visit. Written permission includes email. Verbal approvals do not satisfy this requirement.

Authorized NewU representatives include only current NewU faculty, current members of the NewU Executive Team (direct reports to the President), the President, or designees of the President.

Waivers

Each guest or visitor must sign the NewU Waiver and Release from Liability Form prior to any physical visit on campus or at any NewU facility or off-site event. For group visits, an authorized group leader may sign a group waiver on behalf of the group in lieu of individual waivers, subject to the form and conditions set by the Office of the President.

Waivers are not required for virtual-only visits, though the President or a designee of the President may require additional documentation for virtual visits where appropriate.

Supervision During Visits

Any approved guest or visitor must be accompanied by a NewU community member at all times during each physical visit and may not be left unattended on NewU premises.

Building Rules and Landlord Requirements

NewU leases its campus at 1400 16th Street NW, Washington, DC. NewU's lease requires NewU to take responsibility for all persons it authorizes to enter the building and limits the permitted use of the premises to general office and classroom use. The landlord reserves the right to exclude any person not known to building management and may at its option require registration of persons entering or leaving the building.

Accordingly, NewU community members authorizing guests or visitors are responsible for the conduct of those guests and visitors while on NewU premises, including compliance with building rules, and are responsible for any damage caused by those guests or visitors.

Guests and visitors may not use the premises for any purpose inconsistent with general office and classroom use, including but not limited to commercial activity, lodging, or any unlawful, disorderly, or hazardous purpose. Solicitation and distribution of written material on NewU premises, including raffles, sales of merchandise, posting or handing out notices, and requests for membership in or support of organizations, require the President's prior approval.

Minors

Guests and visitors under the age of 18 are subject to the additional requirements of Minors on Campus, which governs when minors may be present on NewU premises, the documentation required, and the categories of minors not permitted on campus. In any conflict between this policy and Minors on Campus, Minors on Campus controls. Vendor personnel and other non-community members who interact with minor students are screened and supervised under Child Protection and Safeguarding.

Enforcement

Members of the NewU community found in violation of this policy may be subject to disciplinary action or other sanctions in accordance with NewU policies. Unauthorized guests or visitors may be asked to leave, removed from the premises, or removed from a virtual event in accordance with applicable law and the rules of the building or platform on which the event takes place.

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4.21 Institutional Communications

Applies to: everyone acting for NewU (directors, officers, employees, contractors including all faculty, and volunteers). Approved by: the President. Reviewed: October 2026.

NewU communicates as an institution, not through personal relationships. NewU business belongs on NewU channels. These rules let NewU answer a student the same way twice, address faculty and staff needs efficiently, hand off work without dropping it, and keep a record when it matters.

NewU Channels

What matters is the account, not the device. No one at NewU has a work phone, and reading NewU email on a personal device is fine. NewU email (newu.edu) on a personal phone is a NewU channel. A text from a personal number is not, and neither are personal email accounts, WhatsApp, or social media. A conversation that lives on someone's phone is one the institution cannot address properly, whoever it is with: students, colleagues, volunteers, or vendors.

• Conduct NewU business through NewU email and NewU systems, such as Populi and Google Meet.
• When a student texts or calls your personal number, move the conversation to NewU email.
• When a regulator, a journalist, or a vendor reaches you on a personal phone, send a summary from your NewU email afterward to the office that handles the matter.
• Communications with minor students also follow Protection of Minors and Adult-Student Boundaries and Code of Interactions.

Institutional Phone Lines

202.968.1005 is the institutional text message line for both NewU University and NewU Dual Academy, and it is also NewU's emergency broadcast number. It is not anyone's personal number. 202.968.1001 is NewU's voice line: it takes voicemail messages and places outbound calls on limited occasions. Save both numbers in your phone as NewU / Dual Academy. Do not block either number, and do not reply STOP to a message from either number, because that causes a phone company block.

Emergencies

If anyone is in danger or needs medical help, call 911 first, then reach the President or the EVP and Chief Financial Officer (CFO) by the fastest means available. The routing and response times below do not apply to emergencies.

Who Handles What

Students learn at orientation that academic questions go to their professor first. Faculty and staff remind them regularly.

Media, Government, and Legal Requests

No one agrees to or responds to a request from the media, the press, a government body, a regulator, or a legal party for a comment, interview, or response without the President's prior approval. Send every such request to [email protected]. This rule does not limit any report the law requires, including a report of suspected child abuse or neglect, or a report made under Whistleblower and Non-Retaliation.

Offices, Not Individuals

Questions, requests, and grievances are addressed in NewU's institutional capacity, from an institutional office, not personally by a member of the administration. Send students to the relevant institutional office, never to an individual administrator.

Software Use and IT Support

How to use software is not an IT question. Where to click in Populi, how to post an assignment, how to enter attendance and grades, and the same for any other software NewU uses: faculty answer these questions for their students, and each person is expected to know the tools of their own role. Start with the vendors' own free training, such as the Populi Knowledge Base and Google's Meet help (screen sharing, layouts, pinning, and recordings).

IT, at [email protected], handles access and outages, not instruction or business process. A pattern of issues is a training gap, not a support ticket: discuss it with your supervisor or write to [email protected] to request training for the community. Unresolved issues and corner cases are discussed at the next faculty meeting.

Hands-on IT support on campus comes from a member of the administration or another faculty member who is capable and available, never from a student. No one other than IT removes, reconfigures, or moves cables, equipment, software, or services on NewU-owned equipment.

Response Times and Escalation

Allow one business day for a response and up to a week for resolution in most cases. During breaks, allow more time. Only if something is pressing, or is not moving in a reasonable time, escalate it to the head of the relevant function:

• IT: the head of IT.
• Finance, campus operations, student services, registrar, and academics and instruction: the CFO.
• Admissions, HR, and anything else: the President, at [email protected].

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4.22 Records Retention and Destruction

Applies to: everyone acting for NewU (directors, officers, employees, contractors including all faculty, and volunteers) who creates, receives, or keeps NewU records. Approved by: the President. Reviewed: October 2026.

Keeping records properly is essential to conducting NewU's business, to protecting the legal interests of NewU and its students, and to complying with applicable laws and regulations. Records that are no longer needed are disposed of on time, to use physical and digital storage efficiently. This policy applies to records in all formats, including paper records, electronic records, and data in NewU's systems.

Student Records

Education records include any personally identifiable records NewU keeps about a student, including academic, disciplinary, and administrative records (Privacy and Education Records). To protect students' rights in their records, NewU:

1. meets legal standards for protection, storage, accessibility, and disposition;
2. gives students an annual notice of their rights;
3. controls access to education records under law and policy;
4. keeps records as required by law and policy;
5. gives students the right to request amendment of their education records and the right to a hearing about them; and
6. provides complete records, from every NewU office, when a student asks for their records.

Storage

NewU keeps records in a safe, stable, and secure way that supports timely and accurate retrieval and controls access appropriately. To do this, NewU:

1. uses consistent and accurate filing, classification, and indexing that everyone understands and follows, so records can be found efficiently;
2. stores records in secure and stable environments, including electronic storage on stable media and in accessible formats;
3. determines the confidentiality and privacy status of all records and applies security measures that fit them;
4. documents how records are organized, where they are stored, and how they are secured; and
5. when converting paper records to electronic form, disposes of the original unless there is a legal reason to keep it, makes sure scanned images are fully legible and contain all the information in the original, and stores electronic records in established secure locations with security and backup. Consult IT at [email protected] before converting student records from paper to electronic form.

Disposition and Destruction

Every office knows what to do with records once they are no longer in active use. Typical dispositions are confidential destruction, transfer to NewU's archives for permanent retention, and transfer to the archives for short-term storage (for records with a set retention period that are not used often).

1. Check the retention schedule below before disposing of any record.
2. If a type of record does not appear to be covered by the schedule, or you are unsure whether a record can be destroyed, ask the registrar office at [email protected] for student records, or the office that keeps the record for other records.
3. Only one copy of a document is kept, by the office responsible for it. Drafts and notes are destroyed unless they are important to documenting official business or an action of NewU, in which case they are stored with the document.
4. Unless the schedule says otherwise, the retention period runs from the date the record was created or received.
5. Electronic records are treated like any other record and follow the same schedule.
6. Where another policy on this page sets a retention period for a record, that period applies.
7. Records relevant to an investigation, audit, legal claim, or government inquiry are preserved until the matter ends, whatever the schedule says.

Retention Schedule

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