Grand Canyon Education Inc

We have adopted a business code of conduct, which applies to all of our employees, directors, and consultants. The code of conduct includes particular provisions applicable to our senior financial management, which includes our Chief Executive Officer, Chief Financial Officer, and other employees including our principal accounting officer, performing similar functions. A copy of our code of conduct is available on the Corporate Governance section of the Investor Relations page on our website at* www.gce.com.* We intend to post on our website any amendment to, or

waiver from, a provision of our code of conduct that applies to any director or officer, including our Chief Executive Officer, Chief Financial Officer, and other persons including our principal accounting officer performing similar functions, promptly following the date of such amendment or waiver.