VCOM Institutional Policy and Procedure Manual

VCOM Policy and Procedure

Policy #U036

3. FOREIGN ADVERSARY RESTRICTIONS FOR RESEARCH PARTNERSHIPS VCOM prohibits faculty, staff, students, and affiliated researchers from engaging in a research partnership with an academic or research institution, government agency, nonprofit organization, or private sector company or individual that is: • Located in or acting on behalf of a foreign adversary; • Designated as a foreign adversary, covered foreign entity, or other restricted entity under applicable federal or state law; • Included on a United States government restricted, prohibited, or sanctioned entity list; • Known to have ties to a foreign adversary's military, intelligence, or security apparatus; or • Otherwise prohibited under applicable law, regulation, executive order, sponsor requirement, or College policy. This prohibition applies to all forms of research partnerships, including but not limited to joint research projects, sponsored research activities, cooperative agreements, data-sharing arrangements, material transfer agreements, visiting scholar programs, research-related consulting, collaborative publications involving the exchange of non-public information or resources, research-related travel, and any other activity involving the sharing of research data, funding, personnel, intellectual property, equipment, facilities, or other research resources. No federal, state, institutional, or sponsored research funds administered by VCOM may be used to support a prohibited partnership or activity. 3.1 International Research Disclosure, Review, and Approval All proposed international research partnerships, foreign research partnerships, foreign-sponsored research activities, international research agreements, and research-related international travel conducted under the auspices of VCOM must be disclosed to the VCOM Research Department. A VCOM Research Partnerships with Foreign Entities Committee will be appointed to review the proposed research for compliance with VCOM policy prior to approval. No international research activity may begin until all required disclosures, reviews, screenings, and approvals have been completed. The VCOM Research Partnerships with Foreign Entities Committee shall consist of the: • Vice President for Research (Chair); • Provost; • President; • General Counsel; • Associate Deans for Biomedical Affairs and Research; and • Other individuals designated by the Vice President for Research as subject matter experts, as needed. All faculty, staff, students, visiting scholars, contractors, consultants, investigators, and other individuals conducting research under the auspices of VCOM who are seeking approval for an international research activity shall submit an application to the VCOM Research Department, who will convene the Committee as necessary for review. An application is required for activities that include, but are not limited to: • Research involving foreign institutions, organizations, companies, governmental entities, collaborators, or investigators;

VCOM Foreign Entity Relationships and Institutional Security Policy

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