VCOM Institutional Policy and Procedure Manual

VCOM Policy and Procedure

Policy #U036

VCOM departments and employees have a continuing obligation to report material changes in a covered relationship, including changes in ownership, control, funding source, intermediaries, or participating entities. VCOM may suspend or terminate an activity when subsequent information indicates that the activity is prohibited or presents an unacceptable legal, security, or institutional risk. 5. REPORTING OF FOREIGN ADVERSARY INTERACTIONS Employees, researchers, students, and volunteers shall promptly disclose to VCOM any interaction, communication, meeting, invitation, request for collaboration, or other substantive contact with a foreign adversary, a principal of a foreign adversary, or an individual acting on their behalf when such contact relates to the individual's role, responsibilities, research activities, educational activities, employment, volunteer service, or affiliation with VCOM. Such disclosures shall be submitted to the Office of the President as soon as practicable, but no later than thirty (30) calendar days following the interaction, communication, or meeting. The disclosure shall include sufficient information to allow VCOM to assess the nature of the contact and any applicable legal, regulatory, contractual, or institutional reporting requirements. VCOM will review reported interactions and, when required by applicable law or regulation, make any necessary reports to governmental authorities or other appropriate entities. VCOM may also investigate any alleged violation of this Policy based upon a disclosure, referral, complaint, audit finding, or other credible information suggesting noncompliance. As part of any review or investigation, VCOM may require individuals to provide records, documents, communications, agreements, correspondence, travel records, research materials, or other information relevant to determining compliance with this Policy. Individuals subject to this Policy shall fully cooperate with any institutional review, inquiry, audit, or investigation and shall provide requested information in a timely manner. Failure to make a required disclosure, failure to cooperate with an institutional review or investigation, failure to provide requested records, or the submission of false, incomplete, or misleading information may result in corrective action, up to and including disciplinary action, termination of employment or volunteer service, dismissal from the academic program, ineligibility to participate in research activities, and any other actions permitted by applicable law or College policy. 6. DURATION OF POLICY The VCOM Foreign Entity Relationships and Institutional Security Policy is effective as of the date above and will remain effective until amended or terminated by the President, with approval by the Board of Directors.

VCOM Foreign Entity Relationships and Institutional Security Policy

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