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Examples of such conduct include, but are not limited to:
 Offensive or unwelcome sexual flirtations, advances or propositions
 Verbal abuse of a sexual nature
 Graphic or verbal commentaries about an individual’s body
 Sexually degrading words used to describe an individual
 Sexually oriented jokes or offensive literature
 Unwelcome physical touching of others
 Unwelcome conduct such as standing too close, leering or sexually suggestive
gestures or physical movements

Notwithstanding the foregoing, any instance of sexual harassment involving an employee and a student
that denies or limits on the basis of sex, an employee’s ability to provide aid, benefits, or services to
students, or a student’s ability to participate in or benefit from APUS’s programs and activities, shall be
addressed under APUS’s Title IX Compliance Policy and Title IX Grievance Procedures available here.

Notice of Nondiscrimination – Discrimination on the Basis of Sex
APUS does not discriminate on the basis of sex in its education programs and activities, and it is required
by Title IX of the Education Amendments of 1972 (“Title IX”) not to discriminate in such a manner.
Questions regarding Title IX may be referred to the APUS Title IX Coordinator, or the Office for Civil
Rights at the United States Department of Education. APUS’s Title IX Coordinator Caroline Simpson may
be contacted by email at: TitleIX@apus.edu, by phone at: 703-396-6428, and by mail at: American Public
University System, Inc. Attn: Caroline Simpson 10110 Battleview Pkwy Suite 114, Manassas, VA 20109.
For more information please see APUS’s Title IX Compliance Policy and Title IX Grievance Procedures
available here.

Harassment Other than Sexual Harassment
Harassment is verbal or physical conduct that denigrates or shows hostility or aversion to an individual
because of to race, color, religion, sex, sexual orientation, national origin, age, disability, genetic
information, status as a covered veteran, or other protected characteristic in accordance with applicable
federal, state, and local laws, when such conduct has the purpose or effect of: unreasonably
interfering with an individual’s work performance; creating an intimidating, hostile, or offensive work
environment; or otherwise adversely affecting an individual’s employment opportunities. Harassment
may include, but is not limited to: verbal abuse or ridicule, including slurs, epithets, and stereotyping;
offensive jokes and comments; threatening, intimidating, or hostile acts; and displaying or distributing
offensive materials, writings, graffiti, or pictures.

Harassment or discrimination by an employee in violation of this policy will result in disciplinary action
up to and including separation from employment. For more information on disciplinary actions that may
result from harassment or discrimination of a sexual nature between an employee and a student please
see APUS’s Title IX Compliance Policy and Title IX Grievance Procedures available here.

Procedure
If employees experience, observe or become aware of behavior which they believe to be harassing or
discriminatory in nature, which is inappropriate or offensive, or which makes them or others
uncomfortable, they should report the behavior immediately to a manager or the HR Department.
Reports may be made in person at the employee’s manager’s office or the HR department at 111 W.
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