Political Activity Guidelines

Introduction

Brown encourages all members of its community to be active and informed citizens and supports campus-based activities and programs that enhance the individual capacity of members of the Brown community to execute their prerogatives as citizens. However, as a non-profit, private institution of higher education whose activities are regulated in part by Section 501(c)(3) of the Internal Revenue Code (IRS), the University is prohibited from participating in political campaigns for candidates or ballot initiatives and is restricted in conducting lobbying activities. Violation of IRS regulations could have serious ramifications for the University, including loss of its tax-exempt status.

Therefore, Brown provides guidelines on the permitted use and restrictions of University facilities and resources for partisan, politically related activity on campus by students or employees. These guidelines cannot address every potential situation. Questions regarding these guidelines should be addressed to Government Relations and Community Affairs (863-2552) or, if related to student sponsored activities, the Student Activities Office (863-2341).
Brown University reserves the right to amend or modify these guidelines at its discretion or as it deems necessary to comply with the regulations governing political activities of 501(c)(3) entities.

Students and Student Organizations

Recognized campus-based student organizations may participate in a political campaign on behalf of any candidate for public office as long as their campus-based activities comply with University policies and procedures, including these guidelines, and applicable IRS regulations. Organizations created to advocate the election of a political candidate (i.e. Students for Candidate X) or ballot initiative may not receive funding from the University. Other organizations are also prohibited from receiving University funding, including student activities fees, for activities restricted by these guidelines. Student organizations will not be permitted to use University facilities and resources to fundraise for activities prohibited by these guidelines or IRS regulations.

Distribution of campaign materials is generally prohibited on campus, however, recognized student organizations are permitted to reserve information tables for the purposes of distributing information about candidates provided they follow policies and procedures for such tables, including making a reservation through the Student Activities Office. In accordance with University procedures restricting solicitation within on-campus residences, organized campaigning is not permitted in on-campus housing.

Faculty and Staff

Administrative officers, faculty, and staff may take part in partisan political activities freely on their own time, but they must not do so in the course of their regular work and responsibilities for the University. When endorsing or opposing a candidate for political office or taking a position on an issue for the purpose of assisting or opposing a candidate, employees may not give the appearance that they are representing the University.
Brown University employees may not—and should not be asked to—perform tasks related to partisan political activities during working hours.

Campus based faculty and staff groups are prohibited from organizing for the purpose of influencing legislation or participating in political campaigns.

For guidance on interacting with elected officials, please refer to the Lobbying Rules section below. For questions on running for office, see the Seeking Public Office section below.

Use of University Facilities and Resources

All use of University facilities and resources are subject to University policies regulating time, place, and manner of use. The following may generally not be used by any person or organization for activities restricted by these guidelines, regardless as to whether the activity is on or off campus:

• University funds, including the Student Activities Fee, and the University’s sales tax exemption for purchase of goods and services;

• Use of University name and seal – neither the Brown University name, nor that of any University entity that is supported in part or whole by the University’s funds, nor University insignia/crest may appear on stationery or any other material used or intended for political purposes other than the use of Brown University to specify the location of an activity or event or, as appropriate, identifying the sponsor as a Brown chapter or collection of individuals from Brown, but not in such a way as to construe that the event is, in any way, officially endorsed or sponsored by the University;

• Use of University title or position – such information should only be used for identification and not an indication of University endorsement;

• Any University-sponsored campus communication system, including but not limited to the phone system, the campus mail system, and the University’s computer and internet network;

• University bulk-mailing privilege and mailing lists—including the addresses of departmental offices or faculty or staff offices and e-mail addresses; and

• University-provided office supplies, computers, telephones, facsimile machines, copiers or other equipment; however, use of pay-per-use services, such as the campus copying service, may be used as long as the funds to pay for such use are not University funds.

Campaign materials may be posted on public, exterior bulletin boards as long as they are in accordance with University posting and publicity regulations. The sidewalks next to public streets are city property and not subject to these regulations.

Nonpartisan Activities

Brown does not directly or indirectly offer institutional endorsement of political candidates, but certain nonpartisan political activities (such as properly organized voter registration activities and voter education programs) sponsored by a University department or officially recognized campus organization may be held on campus.

On-Campus Appearances by Candidates

Candidates for public office or their designees are welcome to appear on campus for non-campaign related activities, such as an educational or informational talk to the University community. Such appearances must be sponsored by a University department or officially recognized campus organization and satisfy the following criteria:

• The individual(s) is/are chosen to speak for reasons other than candidacy for public office.

• The individual speaks in a non-candidate capacity.

• The event or organization maintains a nonpartisan atmosphere.

• No specific organized campaigning activity occurs in connection with the event.

• The campus event involving a candidate should not be dictated by, or put under the control of, a candidate, his or her representatives, or any outside organization.

• Any such event must be open first to the entire University community (without preference based on political affiliation) and then, if space permits, to the general public (again, without preference based on political affiliation).

• Any additional criteria appropriate for the particular event as determined by the University.

Student organizations must initiate requests for an appearance of a candidate for public office in a non-candidate capacity through the Student Activities Office.

In addition, three options exist for campaign-related appearances of candidates and their surrogates. In all three cases, fundraising is strictly prohibited and approval must be obtained from Government Relations and Community Affairs:

1. Candidate Debates - All candidates duly registered for the ballot must be invited and given a reasonable opportunity to agree to participate, and the event must be managed in such a way as to not favor or endorse any particular candidate. Arrangements and formats for such debates must be reviewed and approved by Government Relations and Community Affairs.

2. Events for Individual Candidates - All candidates for office or their surrogates may be invited once during a primary season and once again during the main election season. If a candidate running for one of these offices speaks at Brown, other candidates for the same office must be given the opportunity to speak in a comparable venue and similar timeframe.

3. Non-sponsored Events - Campaigns are welcome to rent meeting rooms and event spaces and, as such, are subject to the same rules, regulations, and fees for all external users as set by the Conference Services Office. Advertising and publicity material should state that the event is not sponsored by Brown University and all campaign-related activities must be contained within the rented venue or facility.
Approved appearances by candidates or their surrogates sponsored by University departments or campus groups may take advantage of campus promotional outlets provided the communications are designed to promote and support the event, but not the candidate.

Fundraising and Gift Restrictions

Funds or contributions for political candidates or campaigns may not be solicited in the name of Brown University, and University resources may not be used in soliciting such funds. Fundraising activities are prohibited on campus. If Brown students, faculty, or staff make political contributions they do so as individuals and not on behalf of Brown.
Administrative officers, faculty, and staff, and any person or organization acting on their behalf (collectively, “the donees”), may not solicit or accept funds or contributions for political candidates or campaigns (their own or someone else’s) from donors identified through donor rolls or other University records or directories.

Seeking Public Office

Faculty, staff, and students may decide to run for public office while at Brown. To ensure compliance with IRS regulations and University policy, including conflict of interest and/or a conflict of commitment, a plan to manage potential conflicts must be established upon declaration of candidacy. Plans must ensure that other faculty, staff, and students do not experience a compromised educational or work environment or feel pressure to comply with the political goals of candidates.

An employee intending to seek public office must inform his/her supervisor and the Dean of the Faculty or the Vice President for Human Resources to develop a plan to avoid conflicts of interest. It is requested that this notification come as soon as the employee is considering becoming a candidate, but, in all cases, notification must be made no later than immediately upon declaring candidacy. Students intending to seek public office must contact the Office of Student Life, again as early in the process as possible but no later than the declaration of candidacy. Student Life will then work with the student(s) and the appropriate University offices to develop an appropriate plan.

Lobbying Rules

Members of the Brown community may lobby government officials regarding particular issues of interest to them on their own time. If they wish to lobby government officials in their capacity as a Brown faculty member, staff person, or student they must first consult with Government Relations and Community Affairs. If it is determined that Brown should contact a city, state, federal, or international official on a particular policy matter, such efforts must be coordinated through Government Relations and Community Affairs. Due to federal and state lobbying laws, Brown must report any lobbying activities; therefore it must be informed of all such activities conducted by Brown employees.
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Last updated February 23, 2010