Issued: February 15, 2022
Last Reviewed: February 15, 2022
Last Revised: February 15, 2022
2. Policy Purpose
The purpose of this policy to ensure that the University of Southern California (“USC”) complies with applicable laws when hosting site visits with Government Officials and candidates.
Site visits are an opportunity for the university to build and maintain relationships with Government Officials. During an event, Government Officials and staff members visit USC’s facilities, meet with relevant stakeholders, and engage in dialogue. Site visits are not campaign events, and Government Officials are not compensated to attend.
3. Scope and Application
This policy applies to all faculty, staff and students that wish to host Government Officials or candidates for office on USC’s campus or at a USC event. Hosting a site visit requires input and coordination with Office of University Relations, Office of General Counsel, and Office of Media and Public Relations in order to achieve all participants’ objectives while complying with applicable laws. It is also important for USC participants to know that USC cannot endorse candidates or contribute to their campaigns. Moreover, faculty, staff and students should consult the Conflicts of Interest in Business Practices 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.
|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.|
|USC/University||Includes departments, schools, other units, the health system and student organizations. Recognized student organizations are also subject to SCampus policies.|
5. Policy Details
Site Visits (Generally):
- USC may be asked to host a site visit, or may wish to extend an invitation to host one. Both sides work collaboratively to discuss the purpose of the event, desired outcomes, and negotiate necessary details, such as dates, locations, and whether the event is open to the press. For example, a Government Official may come to the university campus for a class visit or to participate in a lecture/class.
- A site visit may have a culminating moment, such as a speaking engagement, reception, photo opportunity, and/or presentation of an award. It is common for media representatives to accompany Government Officials. USC may consider inviting stakeholders, such as faculty, students, employees, or beneficiaries of USC programs. A confirmed list of reportable officials and all other attendees should be provided to USC University Relations in advance to determine the applicable laws governing the event. Because gifts of goods or services to Government Officials 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 should not be given to Government Officials without first checking with USC University Relations.
Note that a Government Official could also be a candidate for office (i.e., is up for re-election/re-appointment or is a candidate for another government position). The provisions below must also be adhered to for a site visit by a Government Official who is a candidate for office.
Site Visits by Candidates for Office:
- A site visit by a candidate for political office should be treated similarly to an interaction with a Government Official, and USC University Relations must be informed in advance of such a visit. USC may host a meet and greet event with candidates to discuss and exchange viewpoints. USC may coordinate with a candidate as to the structure, format and timing of the meet and greet. However, the IRS prohibits tax-exempt 501(c)(3) organizations such as USC from contributing to candidates and supporting their campaigns. Therefore, USC may not engage in express advocacy or fundraising for the candidate, and site visits may not include activities that constitute (or may be regarded as constituting) a contribution to or support of a candidate’s campaign.
- If USC extends an invitation to a candidate to speak, USC should also consider extending similar invitations to other viable candidates. In addition, USC may not reproduce, republish or distribute the candidate’s campaign literature, advertisements, campaign signs or other similar materials. While the candidate may expressly advocate for his/her election during the meet and greet, USC may not endorse the candidate and should ensure that the event does not become a political rally. In addition, gifts of goods or services to 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). Therefore, gifts should not be given to candidates without first checking with USC University Relations.
- USC event organizers should ensure that a site visit does not become a political rally by clearly communicating with a candidate about the educational and informative purpose of the event and removing any elements from the event that could be considered express advocacy. Whether invited as part of a forum or series, or as a Government Official serving in his or her official capacity, all candidates must understand and agree that the site visit is not a campaign event. At the beginning of an event, the audience must be reminded that the university is prohibited from endorsing or supporting candidates. USC may terminate any event in which a candidate does not adhere to the university’s rules.
- Gifts to Federal, State, and Local Government Officials may be subject to prohibitions, limits and exemptions. Gifts may also trigger conflicts of interest rules that prevent an official from participating in a decision that may impact USC. Therefore, this policy requires the Office of University Relations to review all gifts to ensure USC complies with the law.
Candidate visits must be approved by University Relations and permitted through the Office of Cultural Relations and University Events. Anyone who is inviting a Government Official or candidate for political office to campus on behalf of the university should inform the Office of University Relations at the early stages of planning.
Furthermore, all approvals for dignitaries, celebrities, elected or appointed officials and candidates should go through the Office of Cultural Relations and University Events for a USC Event Permit. Cultural Relations and University Events will work with University Relations (and other appropriate departments) to ensure university protocol is being followed for student, faculty or staff events.
Complete the Events Permit Application to request an event permit.
Complete the Lobbying Activity Report Form when attempting to influence any legislative or administrative action and when communicating with a Government official or candidate on behalf of the university.
|Position or Office||Responsibilities|
|Office of University Relations (Compliance Lead regarding lobbying/gifts for university)||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 the General Counsel||Provide legal advice and approve policy language.|
9. Related Information
10. Contact Information
Please direct any questions regarding this policy to: