It’s always darn interesting to see how the University of Phoenix reflects both the academic and commercial bias, so when I saw this memo from Apollo Group Chairman John Sperling, I thought it was intriguing reading. First I present the memo, then the actual policy itself…
February 8, 2006
To: All Staff and Faculty
From: John Sperling, Chairman
From Apollo Group’s initial founding 30 years ago, I have always stood by three basic values: (1) we treat our fellow employees, students and vendors the way we ourselves wish to be treated; (2) we always strive for the highest quality in our work; and (3) we foster free speech. In resuming the Chairmanship, I want to ensure that our Free Speech Policy is institutionalized so that it creates a robust culture of open communication between and among staff, faculty and students. I am therefore recommending to the Board of Directors that these policies be added to our corporate by-laws so that it becomes the responsibility of the Board to encourage and protect them. In order to assist the Board in these duties, I am appointing an Ombudsperson whose job will be to monitor our culture and to bring to the Chairperson and the Board of Directors any perceived troubles.
The Ombudsperson will be responsible for insuring that every employee and faculty member has access to the Chairman and the Board. The Office of the Ombudsperson is not intended to take the place of normal channels of grievance procedure and communication. In matters of employee grievances, it is intended to be utilized only after traditional avenues have been pursued, such as working with your manager and/or the Human Resources Department.

I am also reinstating the “Comments to the Chair” system and I will welcome recommendations for improving our performance, suggestions for innovations or the need to commend someone whose exceptional performance has been unrecognized. Comments to the Chair can be signed or sent anonymously and I will insure the confidentiality of respondents’ names to the maximum extent possible. There are, of course, certain grievances which involve potential violations of law where confidentiality is not possible.
In addition, the Apollo Fraud/Ethical Violations Hotline is in place to report suspected violations of the law or unethical conduct. The Code of Ethical Conduct is outlined in the Employee Personnel Manual and the number for the Hotline is 1-888-310-9569. Please note that the Fraud/Ethical Violations Hotline can be used anonymously as well.
I am appointing Tracy Holter, Chief Risk Officer, as the first Ombudsperson. Tracy will continue to report to the Audit Committee of the Board of Directors in her role as Chief Risk Officer, while in her role as Ombudsperson, she will report to the Chair with quarterly reports to the Board. Tracy will develop the systems and procedures for this office and she will communicate these to the staff very soon. Her reports to the Board will include her observations and the findings from “Comments to the Chair” as well as pertinent statistical data compiled by Institutional Research. And finally, Institutional Research will be established as an independent entity reporting directly to the President of the University of Phoenix. It will be charged with monitoring academic and operational outcomes and cultural indicators amenable to statistical analysis.
These are both exciting and challenging times for Apollo Group as we literally reinvent the Company in order to keep it competitive and growing. Now, it is more important than ever that we operate in the most open and creative environment possible.

And the University of Phoenix Free Speech Policy…

The Company believes in a free speech ethic, allowing any employee to discuss any Company-related subject with any other employee including Company officers or members of the Board of Directors. Employees may discuss Company-related subjects, including problems or possible improvements in how the company operates, and especially how it treats its customers, employees, or suppliers. Authority goes through channels, but speech does not go through channels. Free speech means free speech.
Each of us is free to discuss any Company-related subject with another employee in one’s own department or someone in any other department, campus, or subsidiary, no matter how sensitive or how painful it might be to one’s supervisor. The Free Speech policy is not to be used as a justification for violating any policy or procedure set forth in the Employee Handbook and the exercise of this right should always be done professionally and with respect for others. Employees who have access to privileged or confidential information and/or information subject to Securities and Exchange Commission (SEC) regulations must insure that the SEC regulations and/or the Family Educational Rights and Privacy Act of 1974 (FERPA) are observed.
COMMENTS TO THE CHAIR
An employee whose free speech has been curtailed by a supervisor, who is unable to obtain an adequate response to a problem or who wishes to recommend changes or special commendations of other employees should contact the Chair, Apollo Board of Directors by phone, e-mail or postal service at the following:
  •   Phone: 800-800-2550, ext. 1182, Tracy Holter, Ombudsperson
  •   Chair -at- apollogrp.edu
  •   Chair, Apollo Board of Directors, C/O: Tracy Holter, Ombudsperson 4615 E. Elwood, Mail Stop AA-B309, Phoenix, AZ 85040
Comments to the Chair can be anonymous, or by name and all names will be kept confidential to the maximum extent practical under the circumstances.

You have to ask: why this policy, and why now?