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at every level. Employees have the option of reporting concerns anonymously.

               In  any  organization,  problems  or  differences  of  opinion  over  work-related  matters  may  occasionally
               arise between an employee and manager, fellow employees, or APUS in general. If this should occur,
               please follow the procedure outlined below.

                           Employees  are  encouraged  to  bring  any  concerns  they  might  have  to  their  immediate
                          manager or HR  if the employees believe it would be inappropriate to discuss the matter with
                          their manager;
                           If  employees  are  not  satisfied  with  their  manager's  resolution  of  the  problem;  they
                          should discuss it with the next level of management or HR;
                            If the concern is unresolved, employees must communicate to their department head or HR;
                           If  the  concern  is  unresolved,  contact  HR  so  the  situation  can  be  elevated  to  the
                          appropriate levels for further action.

               Leadership  encourages  employees  to  bring  their  problems  and  questions  to  our  attention.  The
               company  will  thoroughly  discuss  and  evaluate  each  issue  and  take  the  necessary  actions  to  reach  a
               solution.

               The Alertline was established to assure the highest ethical standards and provide a system for reporting
               violations  of  the  code  of  ethics  and  business  conduct.  This  system  is  operated  by  a  third  party
               organization,  Navex  Global,  and  provides  employees  an  avenue  to  share  their  concerns  relative  to
               management practices, policy issues, interpersonal concerns, threats or violence, etc. This system offers
               anonymous reporting opportunities and 24/7 access. Employees can utilize this resource by calling the
               Alertline at 866.648.0636 or logging onto the alert line at https://secure.ethicspoint.com . Messages left
               on the Alertline are completely confidential – once recorded, the message will be transcribed into text
               to protect the privacy of the user. The confidential text message will be sent to APEI’s Vice President of
               Internal Audit and the APEI Audit Committee Chairperson for investigation.

               Workplace Violence
               APUS provides a safe workplace for all employees. To ensure a safe workplace and to reduce the risk of
               violence, all employees should review and understand all provisions of this workplace violence policy.

               Prohibited Conduct
               APUS does not tolerate any type of workplace violence committed by or against employees, vendors,
               or students. Employees are prohibited from making threats or engaging in violent activities.
               This list of behaviors, while not inclusive, provides examples of conduct that is prohibited:

                       •  Causing physical injury to another person;
                       •  Making threatening remarks;
                       •  Aggressive  or  hostile  behavior  that  creates  a  reasonable  fear  of  injury  to  another
                          person  or subjects another individual to emotional distress;
                       •  Intentionally damaging employer property or property of another employee;
                       •  Possession of a weapon while on company property or while on company business;
                       •  Committing acts motivated by, or related to, sexual harassment or domestic violence.

               Reporting Procedures

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