Issued: October 2, 2002
Last Reviewed: February 15, 2022
Last Revised: February 15, 2022
2. Policy Purpose
As an entity exempt from taxation under Internal Revenue Code Section 501(c)(3), USC is legally prohibited from endorsing, supporting or opposing candidates for political office or a political party, or making contributions to candidates or political parties. Therefore, no individual or organization engaging in political campaign activities supporting or opposing a candidate or political party may imply that the activities are on behalf of the university.
3. Scope and Application
USC, as a tax exempt, nonprofit and educational entity, is subject to Federal, State and Local laws and regulations governing political activities, including campaign activities, lobbying, and gifts to Government Officials and candidates for office. See the Site Visit Policy for specific guidelines on site visits with Government Officials and candidates.
|Government (or public) official||Elected or appointed officials (typically including most of their staff members) or government employees empowered to make governmental decisions. Candidates for political office may be subject to the same policy requirements and limitations|
5. Policy Details
The university is legally permitted to engage in limited political activities relating to specific legislation or ballot initiatives. Any decision to engage in such activities rests with the President of the university.
The university, in exercising its responsibility to provide and maintain an atmosphere of free inquiry and expression, may establish reasonable time, place, and manner restrictions (when USC facilities are permitted to be used for political activities) for the purpose of avoiding disruption to or substantial interference with its regular and essential operations and activities. The university will not base decisions regarding time, place, and manner upon the content of the message, except as permitted in those narrow areas of expression devoid of Federal or State constitutional protection.
While Federal, State, and Local laws limit the university’s participation in political activities using facilities or support, they do not forbid faculty, students, or staff (in their individual capacities) from supporting candidates for office, political parties, or issue-based campaigns.
Political Statements and Use of University Funds
While all members of the USC community are free to express their political opinions and engage in political activities, they do so in their individual capacities. Any political statement made by a member of the USC community, including any statement taking a position or expressing an opinion in connection with proposed or current legislation, a ballot measure, proposition, regulation, law or ruling, is attributable solely to that individual, unless such statement was specifically authorized by the Office of University Relations to be made on behalf of the university.
Any faculty, staff or student with a university title should state that they are speaking as an individual and not as a representative of the university when making any political statement, unless the Office of University Relations has authorized such individual to speak on behalf of the university.
While faculty, staff or students are entitled to identify their employment by or affiliation with USC, no individual is authorized to expend any university funds in connection with such political activities on behalf of USC. Any unauthorized commitment, contract, political statement, or expenditure undertaken that implies it is on behalf of USC is contrary to this policy and shall be void and unenforceable.
USC Name, Logo or Graphic Identity
To avoid any appearance of prohibited political activities, the name, logo, mark, seal, or any other graphic identity of the university or any of its schools, departments, institutes, or divisions may not be used to imply the university is taking a position on any political issue, political party, or candidate, without prior approval from the Office of University Relations. No university services, equipment, supplies, or employees may be utilized for such political purposes, and no university location may be used as a return mailing address for political mailings.
The Office of University Relations, in consultation with the Office of the General Counsel, is the administrative office responsible for the interpretation and application of these policies. All questions on whether any planned political activities are consistent with or otherwise permitted by these policies must be directed to the Office of University Relations.
In general, lobbying is an attempt to influence any legislative or administrative action at the Federal, State, or Local level. A number of laws impose registration and reporting requirements on individuals who engage in certain types of communications with government officials, and these lobbying laws and regulations differ depending on the jurisdiction. Tax-exempt entities, such as USC, are permitted to lobby on certain issues.Because governmental decisions have the potential to significantly impact the university, USC frequently participates in the governmental process at the Federal, State, and Local levels. Since many jurisdictions impose registration and reporting requirements, no individual is permitted to lobby on behalf of the university without prior approval from the Office of University Relations. When such authorized communications are made on behalf of the university, the university may be required to register and report.
To ensure that the university and its authorized representatives and employees fully comply with all applicable laws relating to lobbying:
- Any faculty/staff member who communicates with a Federal, State, or Local Government Official (elected, appointed, or staff) on behalf of the university, and those who research or prepare materials on behalf of the university for the purpose of communicating with a Federal, State, or Local Government Official (elected, appointed, or staff) in an attempt to influence any legislative or administrative action must complete and submit the Lobbying Activity Report Form (see section 7) to the Office of University Relations at the beginning of each month for the prior month’s activity in which such communication, research, or preparation of materials occurs (Communication includes in-person meetings whether on or off campus, telephone calls, emails, letters, or any other means of communication.)
- No outside lobbyist or lobbying firm may be engaged by any school, department, or division without the prior approval of the Senior Vice President of University Relations.
- This policy does not affect communications as individuals. Any faculty/staff member/student may personally choose to participate in voluntary political activities not sanctioned or endorsed by the university.
Many jurisdictions have strict rules regarding giving gifts to Government Officials and their staff members. Gifts and honoraria may be prohibited, limited, or otherwise subject to disclosure. As a nonprofit entity, the university is permitted to give gifts in accordance with all applicable laws and regulations.
Occasionally, the university provides items of value, such as meals or tickets to events, to Federal, State, and Local Government Officials. Depending on the official and the nature of the gift, these gifts may be subject to certain limits and reporting requirements. For example, many California officials are permitted to receive modest gifts up to a certain amount, while gifts to members of Congress and their staff members are generally prohibited, unless an exception applies. Because the limits apply to the university as a whole, and to ensure that the university and its employees fully comply with all applicable laws relating to gifts, no costs or expenses may be incurred to provide anything of value to a Federal, State, or Local Government Official (elected, appointed, or staff) without prior approval from the Office of University Relations. For example, all administrators, faculty, and staff must receive preapproval from the Senior Vice President of University Relations prior to honoring a public official with an award, dinner, or plaque.
All USC faculty, staff and administrators are responsible for informing the Office of University Relations when they plan to invite Government Officials to speak at or attend events OR give them something of value. Any faculty or staff member who communicates with a Federal, State, or Local Government Official (elected, appointed, or staff) on behalf of the university, and those who research or prepare materials on behalf of the university for the purpose of communicating with a Federal, State, or Local Government Official (elected, appointed, or staff) in an attempt to influence any legislative or administrative action must complete and submit the Lobbying Activity Report Form (see section 7) to the Office of University Relations at the beginning of each month for the prior month’s activity in which such communication, research, or preparation of materials occurs.
(Communication includes in-person meetings whether on or off campus, telephone calls, emails, letters, or any other means of communication.) Contact USC University Relations at (213) 740-5371 or email firstname.lastname@example.org for questions or more information.
Complete the Lobbying Activity Report Form when attempting to influence any legislative or administrative action and when communicating with a Government Official on behalf of the university.
Complete the Events Permit Application to request an event permit
|University Relations||Review and respond to inquiries about potential USC political activities, gather information, and consult with counsel to determine what is prohibited, acceptable or reportable.|
|Deputy General Counsel||Provide legal advice and approve policy language.|
9. Related Information