At Passage, our mission is simple but powerful: to provide access to life-changing opportunities. Every time we help the right talent connect with the right path, we make a lasting impact on someone’s life.
This means our job is not just about numbers, it’s about people. We must present opportunities honestly, set clear expectations, and stay committed to every individual’s success. The reward is seeing lives transform because of the work we do.
Referral Partners must act in the best interest of the student's career success.
Last Updated: Jan 26, 2026
I. Student Application Integrity
Ensuring that every data point entering the Passage ecosystem is verifiable and honest.
Accuracy Standard: All submissions to Passage must be genuine, accurate, and complete. Fake, duplicated, or misleading applications are strictly prohibited.
Document Authenticity: Referral Partners must not alter, forge, or "clean" student financial statements or academic records. Every document must be a true scan of the original.
Single Identity Policy: Creating multiple accounts for a single student to "test" the eligibility algorithm is considered gaming the system and is a violation of this code.
II. Ethical Student Advocacy
Protecting the student’s future is the primary objective of every interaction.
Student-First Mandate: Referral partners must act in the best interest of the student at all times and must not prioritize financial incentives over student outcomes.
Anti-Coercion: Students must not be pressured, misled, or coached to misrepresent information (e.g., coaching a student to lie about their intent to return home or their available assets).
Transparent Disclosure: Referral Partners must clearly explain that Passage provides a loan that requires repayment, ensuring the student fully understands the long-term financial commitment before signing.
Informed Consent: Students must be the ones to personally sign all final agreements. Referral Partners are prohibited from signing on behalf of a student, even with their verbal permission.
III. Mission & Brand Alignment
Maintaining the reputation of Passage as a high-trust talent success platform.
Value Synchronization: All referrals must align with Passage’s mission, values, and eligibility standards. Any attempt to game or bypass controls is a violation.
Brand Representation: Partners must use only Passage-approved marketing materials. Creating "shadow" websites or social media pages that mimic the official Passage brand is prohibited.
IV. Commission & Incentive Governance
Creating a fair and transparent reward structure for honest work.
Anti-Fee Stacking: As per our commission-split policy, the total cost to the student must remain identical; Referral Partners may not charge students "administrative fees" for accessing Passage funding.
No Internal Kickbacks: Internal sales team members must not accept any private compensation from Referral Partners in exchange for expedited processing or "favoring" certain applications.
V. Ethical recruiting & anti-bribery
Direct communication: Referral Partners must never intercept or withhold communication between Passage and the student. The student must have direct access to their own Passage dashboard.
Anti-kickback policy: Referral Partners must not offer or accept any undisclosed kickbacks from colleges or service providers in exchange for steering a student toward a specific Passage-funded program.
Credential integrity: Referral Partners must verify the authenticity of student documents (transcripts, identity papers) before submission. Any Referral Partner found knowingly submitting fraudulent documents to Passage will have their partnership terminated immediately.
VI. Audit, Enforcement & Accountability
The mechanisms used to verify compliance and protect the ecosystem.
Right to Audit: Passage reserves the right to audit submissions, request original documentation, and conduct "mystery shopper" calls to verify the quality of advice being given.
Clawback Policy: Passage reserves the right to withhold or reverse incentives for any non-compliant activity, even if the violation is discovered after the incentive has been paid.
Termination: Violations of this Code of Conduct may result in the immediate loss of accrued incentives and the permanent termination of the referral relationship.