Artificial Intelligence (AI) is pervading our lives in numerous ways today. It is important to apply ethical principles to guide the development and usage of AI systems to prevent harms or discrimination through AI algorithms. This has led to various ethical regulations and guidelines being formed at the corporate, national and supra-national level. The EU AI Act classifies the usage of AI in education as 'high-risk' as “such systems may violate the right to education and training as well as the right not to be discriminated against and perpetuate historical patterns of discrimination” [1, p. 26]. However, there has been little attention paid to ethics in AI in Education (AIED) in literature and there is only one existing framework to ethically guide AIED. AIED ethics is complex as it has to combine both general AI ethics and the ethics of educational technology. We aim to create a theoretical framework for AIED, comprising implementation guidelines for developers and organizational users of AI in education. In this paper, an existing draft framework by Holmes et al. is adapted by using insights from literature in the ethics of AI, ethics of educational technology and ethics of AIED.