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discrimination in employment in every location in which the company has employees.

This policy applies to all terms and conditions of employment, including, but not limited to, hiring,
placement, discipline, promotion, termination, layoff, recall, transfer, leaves of absence, compensation,
and training.

Gift Giving

Internal Gifts: In general, internal gifts purchased with company funds should maintain a nominal value
(no greater than $25) per item, but in all cases the value per item gifted must not exceed $400. Internal
gift giving can have no direct or indirect ties to securing student enrollments and should be offered only
on a non-routine and infrequent basis. Subject to the limitations discussed above, the following
represents a non-exhaustive list of activities through which internal gift giving may be permissible:

 Raffles
 Contest prizes
 Holiday party/summer picnic gifts
 Tokens of appreciation for exceptional work performance where such gift is not directly or
indirectly tied to securing student enrollments

External Gifts: Employees shall not directly or indirectly solicit or accept for personal benefit any gift,
loan, discount, or any item of substantial monetary value (valued at $200 or more) from any person or
company that is seeking to conduct or is currently conducting business with the company.

Employees are prohibited from accepting gifts of any cash value, gift cards, and any other item the
acceptance of which may be directly or indirectly tied to securing student enrollments.

Other gifts, including but not limited to meals and accommodations, of a reasonable and nominal value
of less than $200 provided to employees may be accepted, and to the extent possible should be used to
benefit the applicable team.

Tax Disclaimer
APUS is not a tax advisor and is not responsible for any tax consequences that may result from an
employee giving and/or receiving any gift. Employees are encouraged to contact their personal tax
advisor for more information about any tax implications posed by gifts.

Employees are encouraged to consult with their managers and HR with questions about this policy in
advance of approving any gift giving proposal or accepting any gift. Failure to abide by this
Internal/External Gift Giving Policy may result in disciplinary action, up to and including termination of
employment.

Intellectual Property
As the employer of record, APUS wishes both to encourage the development of such Intellectual
Property (IP) for the public benefit and to establish clear procedures under its IP Policy. The goal of the
document is to ensure APUS’ rights and due compensation in those limited instances in which it shares or
outright owns the IP. Those domains focus on APUS-sponsored research or commissioned works and,
especially, classroom syllabi and course-related products.

2019 Employee Handbook, Revised January 2019 41