Apollo Education v. National Union Fire Ins. Co. Arizona Supreme Court February 17, 2021 Apollo operates several universities in various countries. National Union insured Apollo’s directors and officers under a directors and officers’ liability policy. The policy included no duty to defend the insured if sued. Instead, Apollo would defend itself against any claims. Correspondingly, the policy contained no clause requiring the insured to cooperate with a defense provided by National Union. The policy also required the insured to obtain the insurer’s consent before admitting liability, settling, stipulating to any judgment or incurring defense cost; and required that the insurer “shall not [ ] unreasonably withh[o]ld consent.”