Document Destruction Policy

Any individual performing services for APA who becomes aware of a threatened civil lawsuit or governmental or criminal investigation or proceeding involving APA or related entities should immediately contact any lawyer in the Office of General Counsel (OGC) and should cease destroying any related records or documents (including electronic records or documents), even if such destruction is provided for in the APA policies. Failure to do so is grounds for disciplinary action, including possible termination of any contract for services.

It is also unlawful to alter, destroy, conceal, falsify or make a false entry in, any record or document for the purpose of impeding, obstructing, or influencing an existing or contemplated government investigation. Any individual who takes such action regarding a record or document (including electronic records and documents) will also be subject to disciplinary action, including possible termination of employment or of contracts for services. In addition, individuals risk criminal penalties if they are found to have violated the law.

Please contact any lawyer in the OGC if you have questions about the retention or destruction of any specific document.