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As a publicly traded company that is subject to the rules and regulations of the U. S. Securities and
Exchange Commission (SEC) and other regulators, all employees must follow company policy regarding
communications to non-employees.

Employees are not authorized to disseminate information that is considered to be outside the realm of
normal business (“prohibited non-public information”) and/or material non-public information ("inside
information") to non-employees. Such information includes, but is not limited to:

• Information not previously provided in press releases or in SEC filings
• Current/future enrollment and registrations (including retention and conversion rates)
• Current/future financial information (including growth rates and expected earnings)
• New product introductions
• Pending mergers and acquisitions

It is APUS policy that all employees immediately refer all questions from the financial community,
shareholders, and financial media to the Chris Symanoskie, Vice President of Corporate
Communications, at 703-334-3880 or csymanoskie@apus.edu. Questions related to the definition of
inside information or prohibited non-public information may also be directed to Mr. Symanoskie.

Outside Employment
Full-time staff and full-time faculty should not hold other jobs that interfere or conflict with the duties at
APUS. Full-time staff and full-time faculty must gain approval for outside employment from their
manager and/or department head. Failure to notify management of outside employment may result in
disciplinary action, up to and including separation of employment.

Performance Appraisals
Managers will periodically review employees’ performance. APUS normally conducts performance
reviews:
 At the conclusion of the introductory period;
 At least annually thereafter; and
 As necessary when performance is below the expected level, or to track rapidly changing
job content.

Visitors
Employees should avoid having social visitors and social telephone calls during work hours. If it is
necessary that family members or friends call or visit during work hours, they should make the call or
visit as short as possible.

Whistle Blower/Alertline:
APUS is proud of its reputation for employing ethical business practices throughout the organization.
APUS promotes an open door policy that encourages employees to discuss issues or problems related to
their job, their managers, their coworkers or others within the company. The company strives to provide
an effective way for employees to bring problems or concerns to the attention of management.
Management is always open to listening to employees’ concerns.

This Alertline is for all employees to report concerns about the possibility of questionable accounting,
operational reporting, auditing procedures, other types of fraud, management practices, policy issues,
interpersonal concerns, threats or violence, ethics and governance policy violations, etc. by employees
2019 Employee Handbook, Revised January 2019 36