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Western Michigan University strives to treat all students ethically, respectfully, equitably, and professionally in all interactions, prior to, during, and after their academic careers. Ensuring that all members of the University community who are engaged in student recruitment activities are sufficiently trained in, aware of, and adhere to the ethical recruitment practices outlined in this policy is a key institutional priority.

This Policy impacts the University enrollment management, marketing and advising community, those units responsible for preparing, validating and distributing marketing and promotional items; admissions counselors; advisors; college recruiters; student recruitment agents; country liaisons; varsity sports coaches and athletic department personnel; student ambassadors and others who have a direct role in recruiting and admitting incoming 51¸£ÀûÉç students.

3.1 International Student Recruitment Agent: an individual (agent) or organization (agency) operating in the business of recruiting international students. The agent or agency derives income from the educational institutions with which it works, contingent upon the referral of enrollees. A contract or written agreement governs the relationship between the agent or agency and the enrolling institution.

3.2 Student Recruitment activities: any activity, initiative, or interaction that has the direct or indirect possibility of encouraging a prospective student to apply to or enroll at 51¸£ÀûÉç. Examples include, but are not limited to,: verbal, written, or digital communication; on- and off-campus events;, application submission and review processes; and partnerships with others outside 51¸£ÀûÉç (i.e., vendors, school counselors, coaches, agents, etc.).

51¸£ÀûÉç employees and representatives serving in student recruitment or recruitment-supporting roles are responsible for the following:

4.1 Providing accurate, current and publicly posted information to prospective students, families, and influencers (i.e., high school counselors), including information related to consumer protection policies and practices;

4.2 Ensuring that, before the student is enrolled or matriculated into courses, the prospective student has sufficient time to:

• 4.2.1 review the institution’s policies and procedures,

• 4.2.2 to understand the amount of federal, state and institutional financial aid (financial aid award) for which they are eligible;

• 4.2.3 learn how many credits, if any, will transfer;

• 4.2.4 learn whether the transfer credits will be applied to requirements of the major or general education; and

• 4.2.5 inform students of the process and timeline for evaluating those credits

4.3 Ensuring that recruiters do not use high-pressure tactics to influence a student to enroll or matriculate;

4.4 Citing all sources for job placement statistics, salary information, visa requirements, Curricular Practical Training (CPT) and Optional Practical Training (OPT) placement information, and other student outcome data publicized as part of the recruiting process. Cited sources will indicate the portion of the cohort or class represented in outcome data. Completing students will be included in the published data even if they did not utilize the institution’s career, advising, or other services;

4.5 Ensuring that no staff member applies pressure to students to enroll or register with the promise of cash, goods, and/or services outside of the regular process of scholarship monies, institutional discounting, fee waivers, financial aid, or other assistance;

4.6 Ensuring that employment is not directly or indirectly offered, or is more likely related to its education and provide no guarantees of employment related to that education.

4.7 Providing complete and accurate information about the estimated cost of attendance at 51¸£ÀûÉç without requesting or requiring that the student confirm enrollment at 51¸£ÀûÉç prior to awarding a financial aid package (provided students submit and complete necessary financial aid documents in a timely manner);

4.8 Refraining from basing admissions decisions solely on the results of standardized test scores (i.e., ACT, SAT, GRE, etc.);

4.9 Following application and commitment deadlines, if any, as outlined by national professional organizations. If no timelines exist for a given population, the University will ensure that students have sufficient time to make an educated decision about their continued education prior to requesting or requiring an application submission or enrollment commitment;

4.10 Ensuring that staff members meet the minimum position requirements and receive regular training for their position. Trained and qualified 51¸£ÀûÉç personnel must oversee any third-party contractors performing recruitment and/or marketing activities towards prospective students;

4.11 Complying with requests from students who wish to remove themselves from contact lists. Information obtained through the admissions, recruiting, or lead generation procedures will be handled in accordance with National Association for College Admissions Counseling (NACAC) and the National Collegiate Athletics Association code of ethics;

4.12 Complying with all Federal, State, and University non-discrimination policies, along with the Michigan Constitution, including non-discriminating on the basis of race, color, religion, national origin, sex, sexual orientation, gender identity, age, protected disability, veteran status, height, weight, or marital status;

4.13 Providing guidance on completing admissions and financial aid applications without completing the applications on behalf of a prospective or current student;

4.14 Ensuring students have the right and responsibility to register for each academic term in which they are enrolled. In no case will the institution automatically register a student in the next term without obtaining that student’s consent or providing the student the opportunity to cancel that registration before the student is assessed tuition or fees for that term;

4.15 Communicating the institution’s refund policy and relevant dates with students; and

4.16 Refraining from speaking disparagingly about other higher education institutions while serving in student recruitment or recruitment-supporting roles.

4.17 Exceptions N/A

4.18 Implementation/Communication

• 4.18.1 Upon certification and adoption of this policy, responsible enforcement officials will distribute the policy to all relevant personnel and hold sessions to discuss details and answer questions. Staff will be required to acknowledge receipt and understanding of the policy.

• 4.18.2 This policy will be presented to and acknowledged by new employees during the on-boarding process for recruitment-related positions.

5.1 The University must comply with federal requirements and assumed practices of the Higher Learning Commission for its reaffirmation of accreditation. Federal compliance requirements for accreditation are not optional and can result in actions being taken against the University.

5.2 The University must comply with federal immigration and nonimmigrant visa requirements, including CPT and OPT eligibility and requirements.

5.3 Failure to follow this Policy and any associated procedures may subject 51¸£ÀûÉç employees to disciplinary action, up to and including dismissal from employment by the University, consistent with applicable procedures and Collective Bargaining Agreements.

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