1.0 Policy Purpose
The purpose of this policy is to ensure compliance with Export Controls, to heighten awareness and understanding of export control laws and regulations and their application in a university setting, and to describe University Personnel compliance responsibilities and institutional resources.
2.0 To Whom the Policy Applies
University Personnel must comply with United States (U.S.) Export Controls and with this policy and adhere to Brown University procedures established to maintain institutional compliance with governing laws and regulations.
3.0 Policy Statement
Brown University (“the University”) is committed to full compliance with U.S. export control and sanctions laws and regulations, including, but not limited to, the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), and the Office of Foreign Assets Control’s Sanctions Regulations.
Failure to comply with Export Controls can result in significant institutional sanctions and penalties. Violating Export Controls may also result in individual criminal sanctions. It is therefore incumbent upon University Personnel to become familiar with this policy and the University’s procedures for operationalizing the policy.
3.1 Export Controls at Brown University
Consistent with the University’s mission and its Openness in Research Policy, the University is committed to free inquiry and the open exchange of ideas and information for the public good. As an accredited U.S. institution of higher education that adheres to these principles, the University routinely relies on the Fundamental Research Exclusion (FRE) for research activities performed in the U.S., the Educational Information Exclusion, and the Public Information Exclusion.
3.1.1 Fundamental Research Exclusion
The University relies on the Fundamental Research Exclusion (FRE) to enable all University Personnel to participate in research activities and openly share and discuss research results.
As an institution that conducts Fundamental Research, the following principles apply:
- The University as an entity and all University Personnel must ensure that research results can be openly published and made available to the public.
- The University does not accept classified research.
The University generally does not accept research with publication restrictions or access restrictions based on nationality. In rare cases exceptions may be made as outlined in the Openness in Research Policy.
- University Personnel are permitted to use proprietary information from a research partner, provided such information is adequately protected, is not shared without applicable authorizations, and is not central to the conduct of research.
University Personnel are permitted to use controlled items and Technology in the conduct of research, provided such items and Technology are not exported without appropriate authorizations. The use of ITAR-controlled items (“defense articles”) and Technical Data requires written permission from the Vice President for Research and an approved Technology Control Plan (see section 3.2.1).
3.1.2 Educational Information Exclusion
As an institute of higher education as defined in 20 U.S.C. § 1001, the University takes advantage of the Educational Information Exclusion. This exclusion shields general educational information that is typically taught in schools and universities from Export Controls. The Educational Information Exclusion allows for disclosure of information concerning general scientific, mathematical, or engineering principles commonly taught in schools, colleges, and universities [ITAR 22 CFR §120.10(b)] or disclosure of information released by instructions in catalog courses and associated teaching laboratories of academic institutions [EAR 15 CFR §734.3(b)(3)(iii)].
3.1.3 Public Information Exclusion
Information and data that have been lawfully published and are accessible or available to the public are subject to the Public Information Exclusion and therefore not subject to Export Controls. The terms “Published” or in the “Public Domain” are applied as they are defined in the ITAR and the EAR.
3.2 Prohibited Activities
3.2.1 Purchasing or receiving ITAR-controlled items, materials, software, or Technical Data (collectively, “ITAR technology”) for use at Brown University
The University does not permit the purchase or receipt of items or Technical Data that are listed on the U.S. Munitions List (USML) and subject to the ITAR, unless approved in writing in advance of purchase or receipt [in cases where purchase is unnecessary] by the Vice President for Research (VPR). It is the responsibility of University Personnel to contact the Export Control Officer (ECO) if proposing (e.g., in a grant application) or requesting to purchase or receive items or Technical Data that are controlled under the ITAR to facilitate ECO and VPR review of the proposed purchase or receipt. If the use of ITAR-controlled items or Technical Data is approved, such items or Technical Data will be subject to a Technology Control Plan (TCP).
The purchase of ITAR-controlled items using the University’s Purchasing Card is expressly prohibited by the University’s Purchasing Card Policy.
3.2.2 Shipping or hand-carrying technology to embargoed, sanctioned, or otherwise restricted countries or end-users
Shipping or hand-carrying any item or Technology, including items and Technology listed on the Commerce Control List (CCL) or classified as EAR99, to a comprehensively embargoed or sanctioned country or to a restricted end-user is prohibited, unless written authorization is received from the ECO. University Personnel must contact the ECO as early as possible when proposing to conduct activities, research, travel or collaborations involving comprehensively embargoed countries/regions.
3.2.3 International financial transactions with Restricted Parties, Specially Designated Nationals (SDNs), or individuals in comprehensively embargoed countries/regions
Financial transactions with individuals or entities from comprehensively embargoed countries or regions are prohibited unless approved in writing by the ECO and, if necessary, authorized by the U.S. government. Financial transactions with Restricted Parties or Specially Designated Nationals require review by the ECO and may be prohibited. Before initiating financial transactions with a Foreign Person, you must ensure that the financial transaction is not with a Restricted Party, a Specially Designated National, or an individual in a comprehensively embargoed country. The ECO can aid with making this determination.
3.2.4 Restrictive trade practices and boycotts
The anti-boycott provisions of the EAR prohibit U.S. Persons or businesses from participating in any non-U.S. sanctioned foreign government boycott. University Personnel who receive a request or agreement/contract that supports a restrictive trade practice or boycott imposed by another country, must promptly report the request to the ECO who, in turn, is obligated to report it to the Department of Commerce.
3.3 Activities Requiring Review by the Export Control Officer
3.3.1 Conducting research involving export-controlled items, Technology, or Technical Data
While most research conducted at Brown falls under the Fundamental Research Exclusion (FRE), the FRE does not apply to export-controlled items, Technology, or Technical Data that the University receives from other parties. Certain Foreign Persons may not be able to participate in research involving export-controlled items, Technology, or Technical Data without a license.
University Personnel must contact the ECO if proposing to conduct research involving export-controlled items, Technology, or Technical Data that is:
- Controlled under the ITAR and listed on the USML; or
- Listed on the CCL and controlled under the “600 series” (i.e., carrying Export Control Classification Numbers (ECCNs) in the “xY6zz” format); or
- Listed on the CCL and controlled under the “500 series” (i.e., carrying ECCNs in the “9x515” format).
The ECO will assist in determining license or other requirements and facilitate the acquisition of licenses. University Personnel must comply with any stipulations in an export license and any other related measures implemented by the ECO.
3.3.2 Developing new technology using export-controlled technology or Technical Data
University Personnel who design, develop, or build new items that use export-controlled inputs, including Technology or Technical Data, or refurbish or disassemble items that are export-controlled may need export licenses to share such items, Technology, or Technical Data with a Foreign Person outside or within the U.S.
University Personnel who plan to design, develop, or build new technology for military application must contact the ECO, who will determine if export licenses are required.
3.3.3 Deemed Exports
A license may be required to Release certain information, Technology, or Technical Data to a Foreign Person in the U.S. Examples of Releases to Foreign Persons (known as “Deemed Exports”) include providing access to controlled items, Technology, or Technical Data by visual inspection or use, providing access via tours of facilities, or verbally exchanging information.
University Personnel who have controlled items, Technology, or Technical Data are responsible for preventing Deemed Exports without an appropriate license. University Personnel must contact the ECO if they want to release controlled items, Technology, or Technical Data to a Foreign Person in the U.S. The ECO will determine licensing requirements.
University Personnel hosting visiting scholars or scientists from comprehensively embargoed countries must contact the ECO to assist in evaluating potential Deemed Export risks and comply with any requests of the ECO to assess and mitigate any identified risks.
3.3.4 Collaborating with or hosting visiting scholars from a Restricted Foreign University
University Personnel who are collaborating with or exchanging items and information with any Restricted Foreign University, or hosting visiting scholars or scientists who are employed by, representatives of, or affiliated with any Restricted Foreign University, must contact the ECO to assist in evaluating potential export and Deemed Export risks and comply with any requests of the ECO to assess and mitigate any identified risks.
3.3.5 Shipping or hand-carrying export-controlled technology abroad
Shipping or hand-carrying export-controlled items to a destination outside the U.S. may require an export license. University Personnel who wish to ship or hand-carry items, including materials and software, abroad must ensure that the items do not require an export license. University Personnel can independently ascertain or verify an item’s Export Control Classification Number (ECCN) with the item’s vendor or manufacturer. University Personnel must contact the ECO if the ECCN is anything other than “EAR99.”
When shipping biological, chemical, or other hazardous materials or when shipping items that are encapsulated in or shipped in biological, chemical, or hazardous materials, University Personnel must also follow shipping and handling policies and procedures implemented by the University’s Office of Environmental Health & Safety.
3.3.6 Travel or research outside the U.S.
Traveling outside the U.S. with certain items or equipment may require an export license depending on the travel destination. In some instances, license exceptions may be available. Use of such exceptions must be documented by the ECO. The sharing of personal knowledge or technical expertise in other countries (e.g., as a keynote speaker, visiting lecturer, etc.) may also require a license. University Personnel who travel outside the U.S. with items, materials, and encrypted devices, or who share technical expertise in other countries, assume responsibility for ensuring that the items, materials, devices, or expertise do not require an export license.
The ECO can assist with determining whether a license for provision of such services is required.
3.4 Training and Education
Training and education are the foundation of a successful export control compliance program. Well-informed University Personnel minimize the likelihood that a violation of Export Controls will occur. The following training is mandatory and coordinated through the Office of Research Integrity (ORI):
- University Personnel subject to a Technology Control Plan (TCP) must complete an initial training, followed by annual refresher trainings.
- University Personnel found to be in violation of Export Controls or University policy must complete assigned training.
- Mandatory training may also be assigned to individual departments, groups, or offices on an as-needed or risk basis.
Other training options offered by ORI, including individual one-on-one training by request, are listed on the University’s Export Control website.
3.5 Record Keeping Requirements
The University must retain certain documentation related to Export Controls in accordance with time periods set forth under applicable U.S. laws and regulations. The ECO has primary responsibility for retaining copies of export-related documentation, including, but not limited to, analyses of license requirements and related correspondence, notes, and memoranda, for a minimum of five years from the date of export, re-export and transfer. Departments, programs, and University Personnel are also responsible for retaining export-related records and documentation, such as licenses and shipping documentation, for a minimum of five years from the date of export, re-export, or transfer. Records may be kept as electronic files or hard copies.
For the purpose of this policy, the terms below have the following definitions. When terms have different definitions based on whether they appear in the EAR or the ITAR, the applicable set of regulations has been noted in parentheses. Definitions excerpted from regulations (e.g., EAR, ITAR) are subject to change by the U.S. government. The University provides them here for convenience and will update this policy periodically to reflect any regulatory revisions. Please consult the regulations to ensure you are reviewing the most current definition.
- Deemed Export (EAR):
Releasing or otherwise transferring “technology” or source code (but not object code) to a Foreign Person in the United States. (EAR 15 CFR § 734.13 (2))
- Deemed Export (ITAR):
Releasing or otherwise transferring Technical Data to a Foreign Person in the United States. (ITAR 22 CFR § 120.17 (2))
EAR99 is a designation for items that fall under U.S. Department of Commerce jurisdiction and are subject to the Export Administration Regulations (EAR) but are not listed on the Commerce Control List (CCL).
- Educational Information Exclusion (EAR):
The release of information by instruction in catalog courses and associated teaching laboratories of academic institutions is not subject to EAR. (EAR 15 CFR §734.3(b)(3)(iii))
- Educational Information Exclusion (ITAR):
Under the ITAR, the definition of Technical Information does not include information concerning general scientific, mathematical, or engineering principles commonly taught in schools, colleges, and universities. (ITAR 22 CFR § 120.10(b))
- Export (EAR):
(a) (1) An actual shipment or transmission out of the United States, including the sending or taking of an item out of the United States, in any manner; (2) Releasing or otherwise transferring “technology” or source code (but not object code) to a foreign person in the United States (a “deemed export”); (3) Transferring by a person in the United States of registration, control, or ownership of:
(i) A spacecraft subject to the EAR that is not eligible for export under License Exception STA (i.e., spacecraft that provide space-based logistics, assembly or servicing of any spacecraft) to a person in or a national of any other country; or
(ii) Any other spacecraft subject to the EAR to a person in or a national of a Country Group D:5 country.
(b) Any release in the United States of “technology” or source code to a foreign person is a deemed export to the foreign person's most recent country of citizenship or permanent residency.
(c) The export of an item that will transit through a country or countries to a destination identified in the EAR is deemed to be an export to that destination. (EAR 15 CFR § 734.13)
- Export (ITAR):
(1) An actual shipment or transmission out of the United States, including the sending or taking of a defense article out of the United States in any manner;
(2) Releasing or otherwise transferring technical data to a Foreign Person in the United States (a “deemed export”);
(3) Transferring registration, control, or ownership of any aircraft, vessel, or satellite subject to the ITAR by a U.S. Person to a Foreign Person;
(4) Releasing or otherwise transferring a defense article to an embassy or to any of its agencies or subdivisions, such as a diplomatic mission or consulate, in the United States;
(5) Performing a defense service on behalf of, or for the benefit of, a Foreign Person, whether in the United States or abroad; or
(6) A launch vehicle or payload shall not, by reason of the launching of such vehicle, be considered an export for purposes of this subchapter. However, for certain limited purposes (see §126.1 of this subchapter), the controls of this subchapter may apply to any sale, transfer or proposal to sell or transfer defense articles or defense services. (ITAR 120 CFR § 120.17)
- Export Administration Regulations (EAR):
The EAR (15 CFR §§ 730 – 774) are a set of rules and regulations related to U.S. export control law that govern the exports, re-exports, or transfers of items, technology, and software from the U.S. to a foreign country, foreign entity, or to a Foreign person. The EAR are administered by the Bureau of Industry and Security (BIS) at the Department of Commerce
- Export Control Classification Number (ECCN):
Five-character alpha-numeric designations used on the Commerce Control List (CCL) to identify items, technology, or software for export control purposes. An ECCN categorizes items based on the nature of the product and its respective technical parameters.
- Export Controls:
Refers collectively to the body of U.S. laws and regulations that govern the transfer of certain materials, devices, and technical information related to such materials and devices to foreign nationals or foreign entities. These include but are not limited to the International Traffic in Arms Regulations (ITAR - 22 CFR §§ 120-130), the Export Administration Regulations (EAR - 15 CFR §§ 730 – 774), and the Office of Foreign Assets Control’s Sanctions Regulations (OFAC - 31 CFR §§ 500-599).
- Foreign Person(s):
Any natural person who is not a citizen of the United States, a lawful permanent resident, or a protected individual. It also means any foreign corporation, business association, partnership, trust, society, or any other entity or group that is not incorporated or organized to do business in the United States, as well as international organizations, foreign governments and any agency or subdivision of foreign governments (e.g., diplomatic missions).
- Fundamental Research (EAR):
Research in science, engineering, or mathematics, the results of which ordinarily are published and shared broadly within the research community, and for which the researchers have not accepted restrictions for proprietary or national security reasons. (EAR 15 CFR § 734.8(c))
- Fundamental Research (ITAR):
Basic and applied research in science and engineering where the resulting information is ordinarily published and shared broadly within the scientific community, as distinguished from research the results of which are restricted for proprietary reasons or specific U.S. Government access and dissemination controls. University research will not be considered fundamental research if:
(i) The University or its researchers accept other restrictions on publication of scientific and technical information resulting from the project or activity, or
(ii) The research is funded by the U.S. Government and specific access and dissemination controls protecting information resulting from the research are applicable. (ITAR 22 CFR §120.11(a)(8))
- Fundamental Research Exclusion (FRE):
The FRE provides that Technology, Technical Data, or software that arises during, or results from, Fundamental Research and is intended to be published is excluded from the export control regulations. (ITAR 22 CFR §120.11(8) and EAR 15 CFR §734.8)
- International Traffic in Arms Regulations (ITAR):
The ITAR (22 CFR §§120-130) is a set of the U.S. government regulations that control the export of defense-related articles and services that are listed on the U.S. Munitions List (USML). The ITAR are administered by the Directorate of Defense Trade Controls at the U.S Department of State.
- Office of Foreign Assets Control (OFAC):
The OFAC administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries, regimes, and individuals, who are engaged in activities related to terrorism, narcotics trafficking, the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States.
- Public Information Exclusion:
The Public Information Exclusion provides that information that is Published, in the Public Domain, and generally available to the public, as well as publicly available Technology and Software, is outside the scope of the export control regulations.
- Public Domain (ITAR):
(a) Public domain means information which is published and which is generally accessible or available to the public:
(1) Through sales at newsstands and bookstores;
(2) Through subscriptions which are available without restriction to any individual who desires to obtain or purchase the published information;
(3) Through second class mailing privileges granted by the U.S. Government;
(4) At libraries open to the public or from which the public can obtain documents;
(5) Through patents available at any patent office;
(6) Through unlimited distribution at a conference, meeting, seminar, trade show or exhibition, generally accessible to the public, in the United States;
(7) Through public release (i.e., unlimited distribution) in any form (e.g., not necessarily in published form) after approval by the cognizant U.S. government department or agency (see also § 125.4(b)(13) of this subchapter);
(8) Through fundamental research in science and engineering at accredited institutions of higher learning in the U.S. where the resulting information is ordinarily published and shared broadly in the scientific community. Fundamental research is defined to mean basic and applied research in science and engineering where the resulting information is ordinarily published and shared broadly within the scientific community, as distinguished from research the results of which are restricted for proprietary reasons or specific U.S. Government access and dissemination controls. University research will not be considered fundamental research if:
(i) The University or its researchers accept other restrictions on publication of scientific and technical information resulting from the project or activity, or
(ii) The research is funded by the U.S. Government and specific access and dissemination controls protecting information resulting from the research are applicable. (ITAR 22 CFR §120.11)
- Published (EAR):
(a) Except as set forth in paragraph (b), unclassified “technology” or “software” is “published,” and is thus not “technology” or “software” subject to the EAR, when it has been made available to the public without restrictions upon its further dissemination such as through any of the following:
(1) Subscriptions available without restriction to any individual who desires to obtain or purchase the published information;
(2) Libraries or other public collections that are open and available to the public, and from which the public can obtain tangible or intangible documents;
(3) Unlimited distribution at a conference, meeting, seminar, trade show, or exhibition, generally accessible to the interested public;
(4) Public dissemination (i.e., unlimited distribution) in any form (e.g., not necessarily in published form), including posting on the Internet on sites available to the public; or
(5) Submission of a written composition, manuscript, presentation, computer-readable dataset, formula, imagery, algorithms, or some other representation of knowledge with the intention that such information will be made publicly available if accepted for publication or presentation:
(i) To domestic or foreign co-authors, editors, or reviewers of journals, magazines, newspapers or trade publications;
(ii) To researchers conducting fundamental research; or
(iii) To organizers of open conferences or other open gatherings.
(b) Published encryption software classified under ECCN 5D002 remains subject to the EAR unless it is publicly available encryption object code software classified under ECCN 5D002 and the corresponding source code meets the criteria specified in § 742.15(b) of the EAR. (EAR 15 CFR §734.7)
- Release (EAR):
“Technology” and “Software” are “Released” through (1) visual or other inspection by a Foreign Person of items that reveals “technology” or source code subject to the EAR to a Foreign Person; or (2) oral or written exchanges with a Foreign Person of “technology” or source code in the United States or abroad. (EAR 15 CFR §734.15)
- Release (ITAR):
Technical Data is released through (1) Visual or other inspection by foreign persons of a defense article that reveals technical data to a foreign person; (2) Oral or written exchanges with foreign persons of technical data in the United States or abroad; (3) The use of access information to cause or enable a foreign person, including yourself, to access, view, or possess unencrypted technical data; or (4) The use of access information to cause technical data outside of the United States to be in unencrypted form. (ITAR 22 CFR §120.50)
- Restricted Foreign University:
Degree granting institutions that have been placed on the Department of Commerce Entity List and that are subject to export and transfer restrictions. Research collaborations and the exchange of items or information with any Entity Listed institution, as well as visitors to Brown who are employed by, representatives of, or affiliated with any Entity Listed institution, must be vetted by the ECO. See Brown’s export control website for the current list.
- Restricted Party:
A Restricted Party is an individual, company, organization, or vessel with which US persons/entities (including their subsidiaries and agents in other countries) may not engage without a specific license
- Software (EAR):
A collection of one or more “programs” or “microprograms” fixed in any tangible medium of expression. (EAR 15 CFR §772.1)
- Software (ITAR):
Software under ITAR includes but is not limited to the system functional design, logic flow, algorithms, application programs, operating systems, and support software for design, implementation, test, operation, diagnosis and repair. (ITAR 22 CFR § 120.45)
- Specially Designated Nationals (SDNs):
OFAC maintains a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. This list also includes individuals, groups, and entities, such as terrorists and narcotics traffickers, designated under programs that are not country-specific. Collectively, such individuals and companies are called "Specially Designated Nationals" or "SDNs." Their assets are blocked and U.S. Persons are generally prohibited from dealing with them.
- Technical Data (ITAR):
(a) Technical Data means the following for purposes of ITAR regulations:
(1) Information, other than software as defined in 22 CFR § 120.10(a)(4), which is required for the design, development, production, manufacture, assembly, operation, repair, testing, maintenance, or modification of defense articles. This includes information in the form of blueprints, drawings, photographs, plans, instructions or documentation.
(2) Classified information relating to defense articles and defense services on the U.S. Munitions List and 600-series items controlled by the Commerce Control List;
(3) Information covered by an invention secrecy order; or
(4) Software (see 22 CFR § 120.45(f)) directly related to defense articles.
(b) The definition in paragraph (a) does not include information concerning general scientific, mathematical, or engineering principles commonly taught in schools, colleges, and universities, or information in the public domain as defined in 22 CFR § 120.11 or telemetry data as defined in note 3 to Category XV(f) of 22 CFR Part 121. It also does not include basic marketing information on function or purpose or general system descriptions of defense articles. (ITAR 22 CFR §120.10)
- Technology (EAR):
Information necessary for the “development,” “production,” “use,” operation, installation, maintenance, repair, overhaul, or refurbishing (or other terms specified in ECCNs on the CCL that control “technology”) of an item. (EAR 15 CFR § 772,1)
- Technology Control Plan (TCP):
A plan that formalizes processes and procedures for University Personnel using controlled products or technology. A TCP is implemented to ensure that controlled products and technology are not shared with or accessed by unauthorized personnel or otherwise exported without the necessary U.S. government authorization.
- University Personnel:
Brown University faculty, staff, visiting scientists, postdoctoral fellows, students, and anybody else who is paid by or otherwise engaged by Brown University to conduct research, teach, or provide services at or on behalf of Brown University.
- U.S. Person:
Pursuant to the EAR and the ITAR a U.S. Person includes:
- any individual who is granted U.S. citizenship; or
- any individual who is granted U.S. permanent residence ("Green Card" holder); or
- any individual who is granted status as a "protected person" under 8 U.S.C. 1324b(a)(3); or
- any corporation/business/organization/group incorporated in the United States under U.S. law; or
- any part of U.S. government. (ITAR 22 CFR § 120.16 and EAR 15 CFR § 772.1)
All individuals to whom this policy applies are responsible for becoming familiar with and following this policy and related procedures. University supervisors are responsible for promoting the understanding of this policy and related procedures and for taking appropriate steps to help ensure compliance with it.
- The Vice President for Research (VPR)
is the Delegated Empowered Official for the University’s export control compliance program. The VPR reviews and approves any exceptions to the University’s commitment to open academic exchange, including granting approval for the use of ITAR-controlled technology at the University.
- The Office of Research Integrity (ORI)
is responsible for developing and implementing this policy and the procedures outlined in the University’s Export Control Compliance Manual.
- The Export Control Officer (ECO)
has direct day-to-day responsibility for administering the University’s Export Control Compliance Program. The ECO assists University Personnel in assessing export control requirements on a case-by-case basis. If a license is required for a proposed export related to University responsibilities or to the University’s business, the ECO will facilitate and coordinate the license application process.
- The Office of the General Counsel (OGC)
provides legal counsel to the VPR and ORI on export control related matters.
- The University Export Control Advisory Group
is comprised of cross-institutional representatives from within the University and provides guidance to the VPR and ORI regarding export control compliance at the University, including, but not limited to, developing policies, guidelines, procedures, and education and outreach programs pertaining to export control compliance.
6.0 Consequences for Violating this Policy
Violations of Export Controls carry potential penalties for the institution and the individual, including substantial monetary penalties, potential criminal charges and imprisonment. Violations of Export Controls can also result in denial of export privileges under the EAR or the ITAR. The University is obligated to report any violations to the relevant government agency.
Failure to comply with this and related policies is subject to disciplinary action, up to and including suspension without pay, or termination of employment or association with the University, in accordance with applicable (e.g., staff, faculty, student) disciplinary procedures.
7.0 Related Information
Brown University is a community in which employees are encouraged to share workplace concerns with University leadership. Additionally, Brown’s Anonymous Reporting Hotline allows anonymous and confidential reporting on matters of concern online or by phone (877-318-9184). University Personnel have an obligation to report any violation or suspected violation of Export Controls and related policies. Such reports can be made to the ECO or the VPR, or through Brown’s Anonymous Reporting Hotline.
The following information complements and supplements this document. The information is intended to help explain this policy and is not an all-inclusive list of policies, procedures, laws and requirements.