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 Unpublished enrollment and registrations (including expected growth rates, applications,
and inquiries)
 Unpublished financial figures (including revenues, expenses and earnings, as well as their
growth rates)
 New programs or lines of business in development or to be launched
 Changes in conversion rates, bad debt expense, receivables, Title IV, and student
financing information
 Positive or negative regulatory, governmental, or accrediting agency developments
 A significant merger or acquisition involving the Company
 A change in control or a significant change in management of the Company
 The public or private sale of a significant amount of additional securities of the Company
 Significant intellectual property developments
 Establishment of a program to repurchase securities of the Company

Unless authorized by a designated spokesperson, employees are prohibited from communicating
company information on social media, blogs, and other electronic media, other than what is already
publicly available on the APUS and APEI websites.

Questions regarding APEI’s insider trading policy or the nature of specific company information should
be directed to the APEI Vice President of Corporate Communications.

Non-Disclosure
Employees will be required to sign a non-disclosure agreement as a condition of employment.
Any employee who improperly uses or discloses trade secrets, confidential business information, and
inside information may be subject to disciplinary action, up to and including separation, and may be
subject to legal action.

The protection of confidential business information and trade secrets is vital to the interests and the
success of APUS. Such confidential information includes, but is not limited to:

• Student information
• Financial information
• Marketing strategies
• New material research
• Pending projects and proposals
• Research and development strategies
• PAD business design

Pursuant to 18 U.S.C. § 1833(b), an individual may not be held liable under any criminal or civil federal or
state trade secret law for disclosure of a trade secret: (1) made in confidence to a government official,
either directly or indirectly, or to an attorney, solely for the purpose of reporting or investigating a
suspected violation of law or (2) in a complaint or other document filed in a lawsuit or other proceeding,
if such filing is made under seal. Additionally, an individual suing an employer for retaliation based on the
reporting of a suspected violation of law may disclose a trade secret to his/her attorney and use the trade
secret information in the court proceeding, so long as any document containing the trade secret is filed
under seal and the individual does not disclose the trade secret except pursuant to court order.

2019 Employee Handbook, Revised January 2019 35