Equal Employment Opportunity & Affirmative Action Statement of Policy

It is the policy of Vista Higher Learning, Inc. not to discriminate on the basis of gender, race, color, religious creed, national origin, sexual orientation, gender identity, physical or mental disability, and/or protected veteran status with regard to any employment practices, including recruitment, advertising, job application procedures, hiring, upgrading, training, promotion, transfer, compensation, job assignments, benefits and/or other terms, conditions, or privileges of employment, provided the individual is qualified, with or without reasonable accommodations, to perform the essential functions of the job. This policy applies to all jobs at the Company. The Company will continue to take affirmative action to employ and advance in employment women, minorities, individuals with disabilities, and protected veterans and to treat qualified individuals without discrimination based upon their gender, race, sexual orientation, gender identity, physical or mental disability, or protected veteran status, in all employment practices.

Employment decisions at the Company are based on legitimate job-related criteria. All personnel actions or programs that affect qualified individuals, such as employment, upgrading, demotion, transfer, recruitment, advertising, termination, rate of pay or other forms of compensation, and selection for training, are made without discrimination based upon the individual’s gender, race, physical or mental disability, protected veteran status, or other protected characteristics. Employees and applicants with disabilities and disabled veterans are encouraged to inform Human Resources if they need a reasonable accommodation to perform a job for which they are otherwise qualified. The Company makes, and will continue to make, reasonable accommodations to the known physical or mental limitations of an otherwise qualified applicant or employee to promote the employment of qualified individuals with disabilities and disabled veterans, unless such accommodations would impose an undue hardship on the operations of the Company’s business.

Vista Higher Learning, Inc. is fully committed to principals of equal employment opportunity and affirmative action. As CEO & Publisher, I support the successful implementation of the Company’s Affirmative Action Programs. I have appointed Laureen Fiola, Vice President, Human Resources Vice President, Human Resources and Affirmative Action Officer for the Company, with responsibility for implementation of the Company’s affirmative action activities. The Affirmative Action Officer has the full support of top management and the staff necessary to fully implement this Program. All managers and supervisors will take an active part in the Company’s AAP to ensure that all qualified employees and prospective employees are considered and treated in a non-discriminatory manner with respect to all employment decisions. Furthermore, Vista Higher Learning, Inc. will solicit the cooperation and support of all employees for the Company’s policy and our AAPs.

Our AAPs include an audit and reporting system, which, among other things, uses metrics and other information to measure the effectiveness of the AAPs. The Affirmative Action Officer has been assigned responsibility for periodically reviewing progress in the compliance and implementation of the policy of affirmative action for women, minorities, individuals with disabilities, and protected veterans. In accordance with public law, the Company’s program of affirmative action for qualified individuals with disabilities and the program of affirmative action for protected veterans are available for inspection in the Human Resources Department, Monday through Friday, from 9:00 am to 5:00 pm upon request, except for company observed holidays when the office is closed.

In addition, employees and applicants will not be subjected to harassment, intimidation, threats, coercion, or discrimination because they have engaged in, or may have engaged in, activities such as filing a complaint, assisting or participating in an investigation, compliance review or hearing, or opposing any act or practice made unlawful, or exercising any other right protected by Section 503 of the Rehabilitation Act of 1973, as amended, the Vietnam Era Veterans Readjustment Assistance Act of 1974, as amended, Executive Order 11246, and/or any other federal, state or local law or regulation regarding Equal Employment Opportunity.

José Blanco, CEO & Publisher