ITT Tech's Response to Senator Harkin

In response to Senator Tom Harkin's depiction of ITT Tech's ESI recruitment practices, Kevin M. Modany, Chairman and CEO of ITT Tech, issued the following statement:

“The training documents referenced by Senator Harkin do not in any way reflect our company's core principles. Those documents were created by a non-ITT Tech source and adapted by ITT Tech personnel outside of their company authority. The materials Senator Harkin referenced were not authorized for use by this company. The recruiting tactics mentioned in those documents are completely unacceptable for the standards that we set, and we sincerely regret that they were used during any recruitment activities.

Our internal investigation shows that one of the documents appears to have been created by a third party, The Sandler Sales Institute. The document was not reviewed by ITT Tech, nor did we sanction the use of the recruiting tactics mentioned in the document.

We do not in any way condone this recruitment practice or any other practice that involves high-pressure sales tactics. We have a very strong training and enforcement program, including:

• a code of business conduct and ethics;
• a vigorous 19-module training program that all admissions representatives must complete prior to meeting with any prospective students;
• standardized, enterprise-wide recruitment presentations;
• regular internal audits and enterprise risk management assessments of recruitment practices;
• a toll-free telephone number for reporting any suspected ethics concerns;
• a “mystery shopper” program that involves multiple shops of each campus annually; and
• a requirement that all admissions representatives sign a statement of legal and ethical principles that they must follow.

We have zero tolerance for practices that violate corporate policies and standards. ITT Tech has a history of acting swiftly when we find an employee has violated our policies and procedures, taking appropriate disciplinary action, including termination of employment. However, despite all of our safeguards, no system is 100% effective.

We hold our employees to very high standards. ITT Tech requires that all materials used to communicate with prospective students and other customers be reviewed and approved by company executives. The materials pointed out by Senator Harkin were neither reviewed nor approved by company executives. All ITT Tech employees go through an orientation course and a course on the company's Code of Business Conduct and Ethics which must be retaken every other year.

As part of our internal auditing, enterprise risk management and quality control programs, each campus is audited annually. During those audits, recruitment materials are reviewed. Our auditors have been directed to expand the scope of those reviews to include training materials as well.

ITT Tech sincerely regrets the suggested use of any of the high pressure sales tactics by individual employees that are not consistent with the standards and principles of our institution. Such conduct does not represent the efforts of our more than 10,000 employees at ITT Tech's 130 locations across the US working day in and day out to improve the lives of our students. Our employees are dedicated to helping students succeed in their pursuit of a high-quality postsecondary education and are committed to doing so while adhering to company policies that are intended to foster student success and comply with all applicable laws and regulations.”