VCOM Institutional Policy and Procedure Manual

VCOM Policy and Procedure

Policy #U036

denial of project approval, suspension or termination of research activities, disciplinary action, and any other corrective measures authorized by applicable law or College policy. 3.2 Research Security Training VCOM supports federal efforts to strengthen research security and protect research integrity, intellectual property, sensitive information, and national security interests. Individuals who are designated as covered individuals under applicable federal laws, regulations, executive guidance, sponsor requirements, or funding agency policies shall complete research security training as a condition of participation in covered research activities. Research security training shall be completed prior to proposal submission, award acceptance, project participation, or other timeframes established by the applicable sponsor or funding agency. Training may be satisfied through institutionally approved programs, including modules addressing: • Research security and research integrity; • Foreign influence and foreign interference risks; • International research collaborations and foreign travel; • Disclosure of foreign affiliations, appointments, support, and financial interests; • Conflicts of commitment and conflicts of interest; • Cybersecurity and data protection; • Export controls and sanctions compliance; and • Stewardship of sponsor funds and other research resources. Documentation of completed training shall be maintained in accordance with institutional procedures. Failure to complete required training may result in ineligibility to participate in applicable research activities or federally sponsored projects. 4. FOREIGN ADVERSARY RESTRICTIONS FOR NON-RESEARCH ACTIVITIES In addition to the research restrictions stated in this policy, VCOM shall not knowingly accept, enter into, purchase from, obtain, sponsor, or participate in any of the activities described below when the proposed source, provider, partner, intermediary, or controlling entity is a foreign adversary or is owned, controlled, directed, or acting on behalf of a foreign adversary. This prohibition applies to direct and indirect arrangements. • Gifts, Grants, Contracts, and Other Items of Value VCOM and its affiliate organizations shall not accept any gift, grant, endowment, award, donation, pledge, contract, service, or other item of economic value from a foreign adversary source, whether offered directly or through an intermediary. • Academic Partnerships and International Cultural Exchange Agreements VCOM shall not establish, renew, or participate in an academic partnership, cultural exchange agreement, faculty or student exchange program, study abroad program, matriculation or recruiting arrangement, dual-degree program, or similar educational collaboration with a foreign adversary source or an entity owned, controlled, directed, or substantially influenced by a foreign adversary.

VCOM Foreign Entity Relationships and Institutional Security Policy

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