Settlement  Disposition Agreement in the Matters of EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc.

Date:	06/23/2026
Organization:	State Ethics Commission
Docket Number:	26-0007
Location:	Boston
Referenced Sources:	G.L. c. 268A, the Conflict of Interest Law, as Amended by c. 248, Acts of 2024

Disposition Agreement

The State Ethics Commission (“Commission”) and EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc. enter into this Disposition Agreement pursuant to Section 3 of the Commission’s Enforcement Procedures.  This Agreement constitutes a consented-to final order enforceable in the Superior Court, pursuant to G.L. c. 268B, § 4(j).

On November 21, 2024, the Commission initiated, pursuant to G.L. c. 268B, § 4(a), a preliminary inquiry into possible violations of the conflict of interest law, G.L. c. 268A.  On November 20, 2025, the Commission concluded its inquiry and found reasonable cause to believe that EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc. violated G.L. c. 268A, §§ 3(a) and 17(b). 

The Commission and EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc. now agree to the following findings of fact and conclusions of law:

Findings of Fact

1. EF Institute for Cultural Exchange, Inc. markets international “educational travel programs” to Massachusetts students and their parents, teachers, and schools that are operated under the trade name “EF Educational Tours.”  EF Explore America, Inc. operates domestic “educational travel programs,” which it markets to Massachusetts students and their parents, teachers, and schools.  These two corporations are herein referred to collectively as “EF.”
2. The time period here relevant is January 2021 through October 2025.
3. During the relevant period, EF marketed “educational travel programs” to Massachusetts public schools, teachers, other school employees, and students and their parents, and organized one or more student trips approved by more than 100 public schools in Massachusetts. 
4. EF marketed to Massachusetts public school employees the opportunity to serve as Group Leaders, that is, adult organizers and chief chaperones, for each of the student trips.
5. EF provided airfare, ground transportation, and lodging at no cost to each student trip chaperone, including the Group Leader, per every six students, the cost of which was covered by program fees paid to EF by the student travelers. 
6. The overwhelming majority of EF’s Massachusetts-based Group Leaders were teachers and other educators. 
7. Most secondary school teachers in Massachusetts are, and were during the relevant period, public employees. 
8. EF offered Group Leaders certain “teacher benefits,” including points in its Global Rewards Program. Group Leaders accrued points for specific actions, including enrolling students in trips or referring friends or colleagues to EF to serve as Group Leaders.   
9. EF marketed points in its Global Rewards Program as redeemable for certain personal benefits, including personal travel opportunities, and for certain benefits for schools or their students, for example, student scholarships. 
10. During the relevant time period, several Massachusetts public school employee Group Leaders raised questions with EF as to whether aspects of EF’s Global Rewards Program complied with the conflict of interest law and guidance on the law provided by the State Ethics Commission.

Cash Rewards

11. During the relevant period, EF, through its Global Rewards Program, also offered Group Leaders, including Massachusetts public school employees, cash stipends for recruiting certain numbers of students for their trips (the “Group Size Bonus”) and for repeatedly running student trips (the “Repeat Bonus” or “Travel Again Bonus”).  
12. After the Group Leader had recruited the number of students required for the Group Size and Repeat and/or Travel Again Bonuses and, in the case of the Group Size Bonus, the required number of students were committed to the trip, EF would calculate the stipend amount and notify the Group Leader that they could claim the reward.
13. EF marketed this cash stipend as a reward that Group Leaders could use as they saw fit, including for their personal benefit. While some Group Leaders chose to have the cash stipend sent directly to their school or used it for tour-related group expenses, other Group Leaders received the cash stipend for their personal use. Still other Group Leaders elected to receive the reward in the form of points on their Global Rewards Program accounts. 
14. If a Group Leader chose the cash stipend reward, EF’s default practice was to issue the stipend in the form of a check payable to the Group Leader. If a Group Leader wanted the stipend directed to their school instead of themself, that choice required action on the part of the Group Leader, as did opting out of the Global Rewards Program.
15. The amounts of Group Size Bonuses EF gave to Group Leaders who were Massachusetts public school employees ranged from $250 to $4,250 per trip.
16. The amounts of Repeat and/or Travel Again Bonuses EF gave to Group Leaders who were Massachusetts public school employees ranged from $500 to $1,000 per trip.
17. On or around October 6, 2025, EF implemented a policy change to its Global Rewards Program whereby Massachusetts-based public school employee Group Leaders could no longer redeem Global Rewards points for personal cash stipends.

School-Sponsored Trips

18. During the relevant time period, EF offered these cash stipends and other valuable rewards to public school educators who were Group Leaders in Massachusetts, including to those who led EF “educational travel programs” as school-sponsored trips. 
19. A school-sponsored trip is a trip for which the trip leader, e.g., the Group Leader of an EF trip, typically a public school employee, is required by the school to obtain school committee approval and/or formal approval by the superintendent and/or principal in order for the trip leader to recruit the school’s students for the trip.
20. For schools that required the school committee’s approval by vote to make a student trip a school-sponsored trip, the Group Leader needed to get the EF “educational travel program” before the school committee for its decision and approval either by applying directly for such approval or by applying indirectly through the school’s administration.
21. For schools that only required formal administrative approval to make a student trip school sponsored, the Group Leader needed to get the EF “educational travel program” before the principal and/or superintendent for their decision and approval to make the trip a school-sponsored trip.
22. Many of EF’s Massachusetts public school employee Group Leaders ran school-sponsored trips.   
23. Generally, once the school committee or school administration approved a student trip, the Group Leader would recruit students as paying travelers for the trip through various methods, including through use of their school position-based network with students, parents, and other public school employees, their school email address and signature, and school facilities.

Specific Examples

24. The following paragraphs state facts regarding EF’s dealings with several of the many Massachusetts public school teachers with whom EF did business during the relevant period.

Teacher A

25. In 2022, Teacher A obtained school committee approval to offer an EF trip to Italy to school students during the April 2023 school vacation. Once the number of students committed to take the trip was fixed, Teacher A received 625 “Group Size Stipend” points from EF into their Global Rewards Program account, plus 272 points for their status as a “bronze” level Group Leader leading 34 paying travelers—whom Teacher A recruited—over eight days of travel.  That same month, Teacher A took the 625-point Group Size Stipend as a $1,250 check.  The remaining points remained in their account and in October 2023, they redeemed 600 points to obtain a $1,200 credit applied toward the cost of their child traveling on an EF trip.

Teacher B

26. In 2022, Teacher B obtained school committee approval to offer an EF trip to Delphi and Vesuvius to school students during the April 2024 school vacation.  Once 35 paying travelers were committed for the eight-day trip and the group size was fixed, Teacher B received a 750-point “Group Size Stipend” from EF into their Global Rewards Program account as well as 560 points for their status as a “silver” tier Group Leader.  The following month, Teacher B took the Group Size Stipend as a $1,500 check from EF.

Teacher C

27. In 2022, Teacher C obtained principal and then school committee approval to offer an EF trip to Costa Rica to school students during April 2024 school vacation.  Once 27 students were committed for the 9-day trip and the group size was fixed and Teacher C chose the stipend option, Teacher C received $1,000 via check from EF as a Group Size Stipend.  EF also gave Teacher C 729 Global Rewards Program points for this trip as Teacher C was a “gold” tier Group Leader for EF.  In 2024, Teacher C redeemed a total of 1,278 Global Rewards Program points ($2,556 in value) for personal flights, some of which were accrued from acts Teacher C took in relation to EF student trips before the 2024 trip to Costa Rica.

Teacher D

28. In 2021, Teacher D obtained school committee approval to offer a summer 2023 trip to Spain.  In or around July 2023, Teacher D received 500 Group Size Stipend points and 1120 Platinum points from EF into their Global Rewards Program account in connection with Teacher D’s acting as a Group Leader for this 10-day, 28-student trip. In September 2023, Teacher D received 300 Repeat Bonus Points from EF for recruiting students for EF student trips in consecutive years. The following February, Teacher D redeemed Global Rewards Program points worth more than $4,600 for personal flights.

Conclusions of Law

Section 3(a)

29. Section 3(a) of the conflict of interest law prohibits anyone from knowingly, otherwise than as provided by law for the proper discharge of official duty, directly or indirectly, giving, offering, or promising anything of substantial value to any present or former state, county, or municipal employee for or because of any official act performed or to be performed by such an employee or to influence, or attempt to influence, an official action of the state, county, or municipal employee.
30. An employee of a Massachusetts city or town school district is a municipal employee under the law.
31. An employee of a Massachusetts regional school district is a municipal employee of each town in that school district under the law.
32. An employee of a Massachusetts charter school is a state employee under the law.
33. Substantial value is $50 or more.
34. The conflict of interest law defines “official act” to include “any decision or action in a particular matter” and in turn defines “particular matter” to encompass “any. . . submission, . . . decision, [or] determination. . . .”
35. During the relevant period, for each EF “educational travel program” that constituted a public school-sponsored student trip, a public school employee, typically a teacher, was required to act as such a public school employee, by applying, directly or through school administration, to the school committee, or by applying to school administrators for direct approval, in the particular matter of the school’s decision to approve the trip.
36. For these public school employee Group Leaders, their direct or indirect application to the school committee or school administration was an official act.
37. In each instance where the school committee and/or school administration decided to approve the trip, the public school employee Group Leader was thus authorized to use their position as a public school employee to recruit students for the trip, for example, by contacting parents via a school contact list and/or holding informational sessions at the school, and those recruitment actions were therefore official acts in connection with the particular matter of the school’s decision to approve the trips.
38. During the relevant period, for each EF “educational travel program” that constituted a public school-sponsored trip, EF Institute for Cultural Exchange, Inc. or EF Explore America, Inc. offered Global Rewards Program rewards including cash redemption options worth well over $50 and therefore of substantial value, to public school employees who were municipal or state employees, as Group Size and Repeat and/or Travel Again Bonuses, for securing certain numbers of paying travelers for an EF trip or multiple trips.  
39. To qualify for the Global Rewards Program offerings, including Group Size and Repeat and/or Travel Again Bonuses, each of these public school employees had to secure a certain number of students as paying travelers, which depended on the public school employee’s successful completion of (1) applying to the school committee and/or obtaining formal school administration approval and (2) recruiting students for the trip, which generally involved use of their public school employee position.
40. Accordingly, the Global Rewards Program offerings of personal benefit and substantial value that, as described above, EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc. each knowingly offered, promised, or gave to Massachusetts public school employees who were or became Group Leaders for school-sponsored trips, were offered, promised, or given by EF for or because of official acts performed or to be performed by those Massachusetts public employees. 
41. Therefore, EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc. each repeatedly violated section 3(a) of the conflict of interest law.

Section 17(b)

42. Section 17(b) of the conflict of interest law provides that no person shall knowingly, otherwise than as provided by law for the proper discharge of official duties, directly or indirectly give, promise, or offer compensation to an employee of a municipality or municipal agency in relation to any particular matter in which the employing city, town, or agency is a party or has a direct and substantial interest.
43. EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc. are each “persons” as the term under Massachusetts law includes corporations as well as natural persons.
44. EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc. knowingly offered, and where the public school employees accepted—gave—its Global Rewards Program offerings to Massachusetts public school employees where those public school employees secured certain numbers of paying travelers for an EF trip or trips, without EF precluding the Massachusetts public school employee from using the rewards for their personal benefit in instances where that public school employee led an EF “educational travel program” as a school-sponsored trip for a public school.
45. For each EF school-sponsored trip, the school’s governing school committee and/or administrators made the decision regarding whether or not to approve the tour program and resulting efforts to recruit its students to participate in the trip.  Each such decision by the school committee and/or by the school’s administrators was a particular matter pursuant to G.L. c. 268A, § 1(k) because the municipality or municipalities served by each such school and the school itself had a direct and substantial interest in each such decision which would impact student learning outside of the classroom, student safety, and school liability, among other things.
46. As EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc. each knew, in order for an EF school-sponsored trip to proceed, the school committee and/or school administrators had to approve the trip to allow the public school employee Group Leader to recruit the student travelers for the trip and to qualify for EF’s Global Rewards Program offerings, including Group Size and Repeat and/or Travel Again Bonuses, which were conditioned upon the public school employee Group Leader securing certain numbers of paying travelers for an EF trip or trips.
47. The conflict of interest law defines “compensation” as “any money, thing of value, or economic benefit conferred on or received by any person in return for services rendered or to be rendered by [that person] or another.”
48. EF’s Global Rewards Program offerings of personal benefit, rather than of benefit to the school or to students, were, as things of value conferred on the Group Leaders in return for services rendered, compensation which EF gave, promised, or offered to Massachusetts public school employee Group Leaders otherwise than as provided by law for the proper discharge of their official duties as public school employees.
49. Accordingly, for school-sponsored trips, the Global Rewards Program offerings of personal benefit that, as described above, EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc. each knowingly offered, promised, or gave to Massachusetts public school employees who were Group Leaders, were compensation, otherwise than as provided by law for the proper discharge of official duties, in relation to the schools’ decisions to offer the trips to students, particular matters in which the schools’ municipalities had a direct and substantial interest.
50. Therefore, EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc. each repeatedly violated G.L. c. 268A, § 17(b).

Disposition

In view of the foregoing violations of G.L. c. 268A by EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc., the Commission has determined that the public interest would be served by the disposition of this matter without further enforcement proceedings, on the basis of the following terms and conditions agreed to by EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc.:

1. That EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc., collectively pay to the Commonwealth of Massachusetts, with such payment to be delivered to the Commission, the sum of $500,000 as a civil penalty for repeatedly violating G.L. c. 268A, §§ 3(a) and 17(b);
2. That EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc. cease and desist from offering, promising, or giving personal travel benefits or cash stipends of substantial value and personal benefit to any Massachusetts public employee in relation to or for or because of an official act of that public employee in connection with a school-sponsored trip of a Massachusetts public school; and
3. That EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc. waive all rights to contest, in this or any other administrative or judicial proceeding to which the Commission is or may be a party, the findings of fact, conclusions of law, and terms and conditions contained in this Agreement.

By signing below, the individuals representing EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc. each acknowledge that they have personally read this Disposition Agreement, that it is a public document, and that they have the power to bind EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc., respectively, to all of the terms and conditions herein, to which EF Institute for Cultural Exchange, Inc. and EF Explore America, Inc. hereby agree. 

1 Some Massachusetts public teachers acted as Group Leaders for EF Institute for Cultural Exchange, Inc. and/or EF Explore America, Inc. on non-school-sponsored trips, meaning that the teacher did not obtain approval from their school committee or school management to run the trip as a school trip. These trips, and the application of the conflict of interest law to them, are not within the scope of this agreement.