Press Release: 6/24/2026
EF Explore America and EF Institute for Cultural Exchange pay $500,000 Civil Penalty for Repeatedly Violating Conflict of Interest Law
June 23, 2025
State Ethics Commission
Contact: Gerry Tuoti, Deputy Chief, Public Education & Communications Division
617-371-9533
Student educational travel companies repeatedly gave public school employees cash stipends and travel rewards for organizing school trips and recruiting student travelers
EF Explore America, Inc. and EF Institute for Cultural Exchange, Inc., which offer educational student travel programs, have together paid a $500,000 civil penalty for repeatedly violating the Massachusetts conflict of interest law. The two companies violated the law by repeatedly offering and giving cash stipends and personal travel rewards to Massachusetts public school employees, primarily teachers, for organizing school trips and recruiting students for the trips. The State Ethics Commission has approved a Disposition Agreement in which the corporations, together referred to as EF, admit to the violations, waive their right to a public hearing, and pay the $500,000 civil penalty. EF has also agreed to cease and desist from offering or providing 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 their official acts in connection with school-sponsored trips.
From January 2021 through October 2025, EF provided international and domestic student trips approved by more than 100 public schools in Massachusetts. Travel costs for the Group Leaders, who were mostly teachers, were covered by fees paid to EF by the student travelers. EF offered the Group Leaders travel rewards and cash stipends for their personal use for recruiting and enrolling certain numbers of students as paid travelers on EF trips, referring friends and colleagues to EF, and repeatedly organizing EF trips. Bonuses for recruiting certain numbers of students for EF trips ranged from $250 to $4,250 per Group Leader per trip. EF’s bonuses to Group Leaders for repeated travel ranged from $500 to $1,000 per trip.
“When a private business gives anything of value to a public employee for their official actions, especially when those actions generate revenue for the business, the public has reason to ask whether what was given was given lawfully and whether the official actions were in the public interest,” said David A. Wilson, Executive Director of the State Ethics Commission. “Here, EF’s provision of cash stipends and travel rewards to public school employees for their private use was not lawful and could cause the public to question whether the public school trips were organized and run first and foremost in the public interest for the educational benefit of the student travelers and not improperly motivated and influenced by the personal incentives and rewards provided to the organizers by EF. EF’s discontinuance of these personal benefit rewards for public school employees involved in its school trips will, going forward, help eliminate a significant threat to the integrity of public school employee decision-making concerning school trips and help ensure public confidence that those decisions are made in the public interest.”
The conflict of interest law prohibits anyone from, otherwise than as provided by law for the proper discharge of official duties, giving or offering anything worth $50 or more to a public employee for or because of or to influence an official act. EF repeatedly violated this prohibition by offering and giving stipends, rewards, and bonuses to public school employees for their private use for their official actions in organizing and gaining official approval of school trips and recruiting students as paying customers for those trips. While a teacher may, if they first make a written disclosure to their appointing authority and obtain the authority’s prior written approval pursuant to regulations promulgated by the State Ethics Commission, be lawfully provided with payment of their travel expenses as a chaperone for a school trip, the law prohibits a travel company’s provision of a personal stipend or travel reward valued at $50 or more to a teacher planning or participating in a school trip. EF’s provision of personal stipends and rewards to public school employees for their Group Leader work for school-sponsored trips also violated the law’s prohibition against, otherwise than as provided by law for the proper discharge of official duties, offering or giving compensation to a municipal employee in relation to a matter in which the municipality is a party or has a direct and substantial interest.
The Commission encourages public employees to contact the Commission’s Legal Division at 617-371-9500 for free advice if they have any questions regarding how the conflict of interest law may apply to them.
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