VCOM Institutional Policy and Procedure Manual

VCOM Policy and Procedure

Policy #U036

• Research supported by foreign funding, gifts, contracts, grants, subawards, sponsored travel, or in kind contributions; • Research requiring international travel; • Research involving foreign data, biological specimens, materials, technology, equipment, software, or intellectual property; • Research involving foreign subcontractors, consultants, subrecipients, or external collaborators; and • Any research activity that may implicate export control, sanctions, research security, foreign influence, or other regulatory requirements. The Committee shall evaluate each proposed activity to determine whether: • The proposed activity is consistent with the mission, strategic priorities, policies, procedures, and best interests of VCOM; • Adequate funding has been identified and all required budgetary approvals have been obtained; • Any time away from institutional duties has been appropriately reviewed and approved by the applicable Campus Dean or supervisor; • The collaborating institution, organization, entity, and all known participants have successfully completed restricted-party and research security screening and are not identified on any applicable sanctions, export control, restricted entity, prohibited party, or foreign adversary list; and • The proposed activity complies with all applicable federal, state, sponsor, accreditation, and institutional requirements. When a project includes a subrecipient, subcontractor, consultant, collaborating institution, or other external research partner, the principal investigator shall ensure that such entity complies with applicable research security requirements. VCOM may require external collaborators to complete research security certifications, provide documentation of institutional compliance programs, or submit additional information necessary to conduct due diligence and risk assessments. VCOM reserves the right to deny, condition, suspend, or terminate any partnership when sufficient information is not provided to permit an appropriate compliance review. Researchers have a continuing obligation to maintain accurate disclosures throughout the life of the project. Prior to implementation, updated disclosures must be submitted for review by the Committee within thirty (30) days of any proposed material change, including: • Addition of a foreign collaborator, institution, or sponsor; • Receipt of foreign funding, gifts, sponsored travel, or other support; • New foreign appointments, affiliations, employment relationships, or financial interests; • Changes in project scope involving international activities; or • Any circumstance that may affect compliance with federal, state, sponsor, or institutional requirements. All approval criteria must be satisfied before a proposed international research activity may be approved, initiated, or modified. The Committee shall meet on an ad hoc basis as needed to ensure timely review. Approval shall require a majority vote of the Committee. Submission of false, incomplete, or misleading information, failure to make required disclosures, failure to update disclosures, or failure to cooperate with required screening or compliance reviews may result in

VCOM Foreign Entity Relationships and Institutional Security Policy

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