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SEC Filings

APOLLO EDUCATION GROUP INC filed this Form DEF 14C on 12/27/2013
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Certain Relationships and Transactions with Related Persons
The Audit Committee reviews on an ongoing basis and at least annually all reportable related party transactions, which are transactions with the Company in which directors, executive officers or their immediate family members have an interest, for potential conflict of interest situations. A conflict of interest occurs when an individual’s private interest interferes, or appears to interfere, with our interests. The Committee’s responsibility is set forth in the Audit Committee Charter and the Audit Committee’s written policy regarding Related Party Transaction Oversight Procedures. The Committee evaluates related person transactions in accordance with the standards set forth in our Code of Business Ethics. To identify transactions with related persons, we annually require our directors and executive officers to complete questionnaires identifying any transactions with us in which the executive officer or director or their family members have an interest. We also obtain reports on related party transactions from our accounting and procurement departments on an ongoing basis. Related party transactions that involve or are expected to involve amounts in excess of $120,000 require advance approval by the Committee.
FuzeBox, Inc.
During fiscal year 2011, we entered into an agreement with FuzeBox, Inc., for licenses and services under a pilot program for Internet-based video conferencing. Peter V. Sperling, the Chairman (then Vice Chairman) of our Board of Directors, is the Chairman of the Board and co-founder of FuzeBox. We paid for a second pilot program in fiscal year 2012. Each of these transactions was approved in advance by the Audit Committee. During fiscal year 2013, we paid FuzeBox approximately $140,000 to renew a portion of the relevant licenses and services. This payment was made prior to approval by the Audit Committee, which was required by the Committee’s Related Party Transaction Oversight Procedures. The payment was subsequently approved by the Committee following the Committee’s determination that the transaction did not violate the Conflict of Interest Policy contained in our Code of Business Ethics.
Ensuring Auditor Independence
Apollo Education Group has taken a number of steps to ensure the continued independence of our independent registered public accounting firm. Our independent registered public accounting firm reports directly to the Audit Committee, which is required to approve in advance or reject any non-audit services proposed to be conducted by our independent registered public accounting firm.