Applies to: Faculty (including part-time, adjunct and visiting faculty), postdoctoral scholars, staff (including graduate/undergraduate student workers and graduate assistants) employed by University of Southern California (“USC“ or the “University“) and including those working for Keck Medicine of USC (“USC Employees”), students and Recognized Student Organizations. This policy continues to apply to individuals who are on sabbatical or other leaves, or who are visiting other institutions.
1. Policy
Issued: February 15, 2022
Last Reviewed: September 26, 2024
Last Revised: September 26, 2024
2. Policy Purpose
The purpose of this policy is to ensure that the University of Southern California (“USC”) complies with applicable laws when hosting site visits and events with Government Officials and Political Candidates. USC does not endorse Political Candidates, contribute to their campaigns, or otherwise permit the use of USC resources to support or oppose candidates or political parties. Faculty and staff should also consult the Conflicts of Interest and Commitment Policy when contemplating political activities or gifts to Government Officials to ensure the engagement does not create, or appear to create, a conflict of interest.
3. Scope and Application
This policy applies to all individuals and groups, including faculty, staff, students, and student organizations, that wish to host Government Officials, Political Candidates, and their staff members on USC’s campus, at a USC or Recognized Student Organization (RSO) event, and/or utilizing USC or RSO resources. This policy applies regardless of whether the site visit or event qualifies as an “event” requiring a University Event Permit. Hosting a site visit or event requires coordination and input from the Office of University Relations, Office of Culture, Ethics and Compliance and Office of Media and Public Relations in order to achieve all participants’ objectives while complying with applicable laws.
4. Definitions
| Term | Definition |
| Government Official | Elected or appointed public officials (typically including most of their staff members) or government employees empowered to make governmental decisions. Government Officials may also be Political Candidates. |
| USC or University | Includes departments, schools, other units, and the health system. |
| Recognized Student Organization (RSO) | Student organizations that have been approved for recognition in accordance with the USC Student Handbook and who are in good standing as defined by USC Student Life. |
| Political Candidate | A person running for elected office in the United States, regardless of whether the election is considered partisan or nonpartisan. Political Candidates may also be Government Officials. |
5. Policy Details
(A) Site Visits and Events (Generally):
- Members of the University community may host site visits or events involving Government Officials or Political Candidates, subject to the restrictions contained in this policy, as well as all other applicable laws and USC policies or guidance. For example, a faculty member may invite a Government Official to participate in a lecture or class.
- A site visit or event may include a speech by the Government Official or Political Candidate, reception, photo opportunity, and/or presentation of an award. Event organizers may invite stakeholders, such as faculty, students, employees, or beneficiaries of USC programs.
- Site visit and event organizers must notify University Relations in advance of any site visit or event that will include a Government Official or Political Candidate and must coordinate with University Relations on the purpose of the event, desired outcomes, and details such as dates, locations, and whether the event is open to the press. Press may be invited to events with Government Officials or Political Candidates only with the approval of University Relations, who shall seek input from University Communications as appropriate.
- Gifts of goods or services to Government Officials and Political Candidates may be prohibited, limited, and/or reportable by the University under applicable laws (which vary depending on the jurisdiction – City, County, State, and Federal). Gifts may not be given to Government Officials or Political Candidates without first consulting the Office of Culture, Ethics and Compliance, who will coordinate with University Relations as needed.
(B) Additional Rules Applicable to Site Visits and Events with Political Candidates:
- Generally, site visits and events with Political Candidates are permissible only when the Political Candidate is invited, and agrees to participate, in a non-candidate capacity. Political Candidates must be invited solely for reasons other than candidacy for public office.
- No USC or RSO funds may be contributed to Political Candidates. Events held at USC, sponsored by USC or an RSO, or events that are supported by USC or RSO funds or resources may not include activities that constitute (or may be regarded as constituting) a contribution to or support of a Political Candidate’s campaign.
- Publicity for a site visit or event with a Political Candidate may not reference the individual’s candidacy or an upcoming election. Event organizers may not reproduce, republish or distribute a Political Candidate’s campaign literature, advertisements, campaign signs or other similar materials at an event or using USC/RSO resources.
- Site visit and event organizers are responsible for ensuring that a site visit or event maintains an atmosphere that is nonpartisan and free of electioneering, and does not become a political rally or campaign event. Organizers must clearly communicate with a Political Candidate about the nonpartisan and electioneering-free nature of the event and must remove any election or candidacy-related elements from the event, such as signs urging the election of the Political Candidate. Political Candidates must understand and agree that the site visit or event will be a) nonpartisan and free of electioneering, b) not a political rally or campaign event, c) that their remarks may not reference their candidacy or the election, and d) they must refrain from fundraising while at USC. At the beginning of an event, the event organizers must remind the audience that the University is prohibited from endorsing or supporting candidates. USC may terminate any event in which a Political Candidate does not adhere to the University’s rules and policies.
- Event organizers may host bona fide candidate debates. These events must adhere to the standards promulgated by the IRS for 501(c)(3) organizations, federal election law and regulations, and any applicable state or local laws or regulations. Certain restrictions in this policy, such as the requirement to invite Political Candidates in their non-candidate capacity and the prohibition on express advocacy by Political Candidates, do not apply to bona fide candidate debates. University Relations must approve all bona fide candidate debates and specifically designate the event as such; any event that occurs without University Relations approval and designation is not a bona fide candidate debate and shall be considered an ordinary event with a Political Candidate under this policy, even if the event purports to be a candidate debate.
6. Procedures
Government Official and Political Candidate site visits and events must
- be approved by University Relations,
- be held in accordance with the University Event Permit Application that has been approved by the Office of Cultural Relations and University Events for that event, and
- adhere to all University policies and procedures for events.
Any person inviting a Government Official or Political Candidate to campus must inform the Office of University Relations at the early stages of planning and before the Government Official or Political Candidate’s participation is confirmed or the event is advertised. Cultural Relations and University Events will work with University Relations (and other appropriate departments) to ensure University protocol is being followed for all events.
While USC endeavors to support events organized by its faculty, staff, and students, the University reserves the right to impose reasonable time, place and manner restrictions on such events and may not authorize site visits and events otherwise permissible under this policy when the activities would be disruptive to the University or otherwise conflict with the University’s policies and procedures for events. See the University’s Freedom of Expression website for additional information.
7. Forms
Complete the Events Permit Application to request an event permit.
8. Responsibilities
| Position or Office | Responsibilities |
| Office of Culture, Ethics and Compliance (Compliance Lead regarding political activities) | Review and respond to inquiries about potential USC political activities, gather information and consult with counsel to determine what is prohibited, acceptable or reportable. |
| Office of University Relations | Review and approve all requests to host Political Site Visits and Events. |
9. Related Information
University’s Freedom of Expression website
10. Contact Information
Please direct any questions regarding this policy to:
| Office | Phone | |
| Office of Culture, Ethics and Compliance | (213) 821-9593 | politicalcompliance@usc.edu |