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Compliance with Title IV Program Integrity Rules: Misrepresentation of Information
All APUS employees and employees of third-party vendors that have direct contact with prospective
students and the public must respect and obey the final Title IV program integrity rule on
misrepresentation of institutional information. Consistent with this policy, all APUS employees and
employees of certain third-party vendors are required to complete annual training on Misrepresentation
of Institutional Information and acknowledge their understanding of their obligations under this rule.
Violations of this rule are taken seriously and can result in disciplinary action or in the termination of an
employee found to have provided substantial false, misleading, or erroneous information about APUS to
students, prospective students, or the public.

Discrimination and Harassment; Investigation of Complaints and Grievances
APUS is committed to providing a work environment that is free of all forms of unlawful harassment and
discrimination. In keeping with this commitment, APUS maintains a strict policy prohibiting all forms of
unlawful harassment and discrimination in employment. This policy applies to harassment and
discrimination committed by and/or against all employees, including such conduct between employees,
and such conduct between employees and “non-employee” consultants, contractors, and workers from
temporary service agencies (see Employee Status in this Handbook) and other third parties, including
vendors, visitors, and guests of APUS whose relationship to APUS is through APUS’s facilities, programs,
or activities, and between employees and APUS students. In addition to the policy in this Handbook,
employees must observe all other applicable APUS policies, including the Policy against Harassment,
Discrimination, and Retaliation in the APUS Student Handbook. In the case of discrimination or
harassment between an employee and a student, APUS policies concerning students will be coordinated
with this policy to address the matter.

All employees shall adhere to a strict non-discrimination and anti-harassment policy. Every person is to
be recognized as a unique individual and is to be treated with respect in all interactions. APUS does not
discriminate on the basis 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. APUS complies with all state and local laws to
the extent that they provide broader protections.

Harassment can occur in a variety of circumstances. Unwelcome conduct may occur (i) on APUS
premises; (ii) during business travel or otherwise in connection with APUS-related business; or (iii)
online. The harasser can be the victim’s supervisor, a supervisor in another department, a subordinate,
a co-worker, or a non-employee such as a vendor. Harassment can occur between two members of
the same group (e.g., two individuals of the same sex) or of different groups.

Sexual Harassment in Employment
Sexual harassment, including unwelcome sexual advances, requests for sexual favors, and other verbal,
physical or visual conduct of a sexual or harassing nature, constitutes unlawful sexual harassment when:

 Submission to such conduct is made an explicit or implicit term or condition of
employment; Submission to or rejection of such conduct is used as the basis for
employment decisions affecting an individual;
 Such conduct has the purpose or effect of either unreasonably interfering with an
individual’s work performance or creating an intimidating, hostile, or offensive working
environment.
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