VCOM Institutional Policy and Procedure Manual

VCOM Policy and Procedure

Policy #U036

• Student and Scholar Associations A student or scholar association affiliated with VCOM shall not accept a gift or grant from, enter into a contract or agreement with, or be directed or controlled by a foreign adversary, a foreign adversary government, or an agent acting on its behalf. Student or scholar association member dues or fees paid by individual members are not treated as gifts or grants from a foreign source or a foreign adversary. • Foreign Travel VCOM employees, researchers, students, or volunteers may not accept transportation, lodging, reimbursement, travel support, a gift, or any other item of value in a country that is a foreign adversary that is paid for by the foreign adversary or a foreign adversary source when offered in connection with the individual’s position or affiliation with VCOM. • Conferences/Events VCOM employees, researchers, students, and volunteers may not solicit or accept any gift, payment, reimbursement, travel support, or other item of value from a foreign adversary or foreign adversary source when such support is offered in connection with the individual's position at, affiliation with, or activities on behalf of VCOM. This prohibition includes support for travel to, attendance at, or participation in conferences, meetings, educational programs, or other events held in a foreign adversary nation or hosted by, on behalf of, or for the benefit of a foreign adversary or a principal of a foreign adversary. • Educational Software and Technology VCOM shall not enter into or renew a contract for educational software, educational technology, or related technology services provided by an entity domiciled in, owned or controlled by an entity domiciled in, or acting on behalf of a foreign adversary country. Educational software and technology shall be screened before acquisition, contracting, renewal, or implementation. • Foreign Recruitment Programs VCOM student applicants, employee applicants, faculty, staff, and other employees shall not participate in a foreign talent or recruitment program sponsored, funded, directed, managed, or controlled by a foreign adversary nation or an entity acting on its behalf. 4.1. International Non-Research Screening and Review Before VCOM accepts, executes, renews, purchases, implements, sponsors, or otherwise participates in a covered non-research activity, the responsible College office shall obtain sufficient identifying and ownership information to determine whether each source, provider, partner, intermediary, and controlling entity is a foreign adversary or appears on an applicable federal or state restricted-party list. The responsible College office, in consultation with General Counsel and other offices as appropriate, shall document the review. The review may include restricted-party screening, ownership and control review, verification of the source of funds or support, and evaluation of whether an intermediary is acting for or on behalf of a foreign adversary. A covered non-research activity shall not proceed if screening identifies a foreign adversary, an entity owned or controlled by a foreign adversary, an agent acting on behalf of a foreign adversary, or information that is insufficient to complete the review.

VCOM Foreign Entity Relationships and Institutional Security Policy

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