1.0 Policy Purpose
The purpose of this policy is to specify permitted use and restrictions of University facilities and resources for politically-related activity on campus by students and employees. The University supports campus-based activities and programs that enhance the individual capacity of faculty, staff and students to fulfill their rights. However, violation of IRS regulations could have serious ramifications for the University, including loss of its tax-exempt status.
2.0 To Whom the Policy Applies
This policy applies to Brown University faculty, staff, and students.
3.0 Policy Statement
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, political parties and political organizations or ballot initiatives, and is restricted in conducting Lobbying activities. This prohibition extends to faculty, staff and students. This prohibition places limits, described below, on the activity of Brown faculty, staff and students.
The parameters of acceptable and restricted activity at Brown under this policy are outlined in this document. Brown University reserves the right to amend or modify this policy at its discretion or as it deems necessary to comply with the regulations governing political activities of 501(c)(3) entities.
3.1 Students and Student Organizations
University-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 this policy on political activities at Brown), and applicable regulations, including IRS regulations.
Brown Student Organizations created to advocate for the election of a political Candidate (i.e., Students for Candidate X) or ballot initiatives may not receive funding from the University. Other Student Organizations are also prohibited from receiving University funding, such as student activities fees, for restricted activities. These Student Organizations are also not permitted to use University facilities or resources for activities prohibited by this policy or IRS regulations.
Distribution of campaign materials is generally prohibited on campus. However, University-recognized Student Organizations are permitted to reserve information tables for the purposes of distributing information about Candidates, provided they follow Brown’s 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.
3.2 Faculty and Staff
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, faculty, staff may not give the appearance that they are representing the University.
Brown University faculty and staff may not-and must not be asked to-perform tasks related to partisan political activities during working hours.
Faculty, and staff who hold public office are prohibited from using University funds, logos/marks, services, supplies, vehicles, inter-office mail, or a brown.edu email account when conducting political activities. Faculty and staff are prohibited from using any University resources for campaign activities.
For limitations on interacting with elected officials, see Lobbying Rules in section 3.8. For questions on running for office, see Seeking Public Office in section 3.7.
3.3 Use of University Facilities and Resources
All use of University facilities and resources is subject to University policies regulating time, place, and manner of use. The following includes items that may generally not be used by any person or organization for campaign activities restricted by this policy, regardless of 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, logo or marks-specifically, 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/indicia, 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 tool or system, including but not limited to the phone system, University-issued cell phone and other electronic devices, University letterhead, the campus mail system, listservs, 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 faculty, staff or student e-mail addresses;
- 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);
- Film or other image capture (video, livestream and photographs) of classrooms, residential and living spaces, dining areas, campus greens, building interiors or exteriors, and other University property for political campaign purposes; and
- University spaces for posting campaign materials, unless they are posted on public, exterior bulletin boards in accordance with University postering and publicity regulations. The sidewalks next to public streets are city property and not subject to these regulations.
3.4 Nonpartisan Activities
Brown cannot directly or indirectly offer institutional endorsement of political Candidates, but certain nonpartisan political activities as defined below (such as properly organized voter registration activities and voter education programs, Get-Out-The-Vote, or public opinion polling), sponsored by a University department or officially recognized Student Organization may be held on campus.
3.5 On-Campus Appearances by Candidates or Designees
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 Student 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 format is pre-approved by the Office of Government and Community Relations (OGCR), and the publicity is pre-approved by the Office of University Communications;
- No Campaign Activity occurs in connection with the event (see definitions below);
- Any such event will be open first to the entire University community (without preference based on political affiliation) and then, if space permits, may be open to the general public (without preference based on political affiliation); and
- The event meets any additional criteria appropriate for the particular event as determined by the University.
Recognized Student Organizations must initiate requests for an appearance of a Candidate for public office in a non-candidate capacity through the Student Activities Office. Political campaigns and partisan organizations are not allowed to rent or reserve meeting rooms or event spaces on campus.
In addition, the following two options exist for campaign-related appearances of Candidates and their surrogates. In both cases, fundraising is strictly prohibited, and approval must be obtained from the OGCR.
3.5.1 Candidate Debates
Brown will consider requests to host political debates on campus from recognized organizations within the Brown campus community or from non-partisan, non-profit civic organizations or media partners, with a focus on hosting such debates in elections that have Candidates representing multiple political parties (typically general elections). 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 not to favor or endorse any particular Candidate. Arrangements and formats for such debates must be reviewed and approved by OGCR.
3.5.2 Events for Individual Candidates
All Candidates for office or their surrogates may be invited once during a primary election period and once again during the general election period. 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.
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. Arrangements and formats for such appearances must be reviewed and approved by OGCR, and, to ensure no language implying University endorsement, communications must be reviewed and approved by the Office of University Communications.
3.6 Fundraising and Gift Restrictions
Funds or contributions for political Candidates, parties or campaigns may not be solicited in the name of Brown University, and University resources may not be used in soliciting such funds. Political fundraising activities are prohibited on campus; this includes using University-issued electronic devices, materials and facilities to make contributions to political Candidates and organizations. If Brown students, faculty or staff make political contributions, they do so as individuals and not on behalf of Brown.
Faculty, staff, and any person or organization acting on their behalf 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.
3.7 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 policies relating to 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.
Faculty and staff intending to seek public office must inform their supervisor, OGCR and the Office of the Provost (for faculty) or the Vice President for Human Resources (for staff) to develop a plan to avoid conflicts of interest. This notification should be made as soon as the faculty or staff member 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 Division of Campus Life, again as early in the process as possible, but no later than the declaration of candidacy. Campus Life will then work with the student(s) and the appropriate University offices to develop an appropriate plan.
Faculty, staff and students must also comply with federal, state and local statutes.
3.8 Lobbying Rules
Members of the Brown community may lobby government officials regarding particular issues of interest to them on their own time and may not use University resources to do so. They must first consult with OGCR if they wish to lobby government officials in their capacity as a Brown faculty member, staff person or student. 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 OGCR.
Due to federal, state and local Lobbying laws, Brown must report any Lobbying activities on behalf of Brown. Therefore, OGCR must be informed of all such activities conducted by Brown employees. Please see the below information on federal, state and city Lobbying regulations and definitions:
For the purpose of this policy, the terms below have the following definitions:
- Campaign Activity:
Directly or indirectly participating in or intervening in any political campaign on behalf of or in opposition to any Candidate for elective office or the promotion or opposition to a ballot referendum. Examples of Campaign Activity include raising funds or canvassing for a Candidate, recruiting volunteers, distributing a Candidate’s campaign materials or sponsoring the appearance of a Candidate for public office.
A person who has filed a formal declaration of candidacy for an elected, public office or has made a public statement of their candidacy prior to the legal opportunity to declare a candidacy.
Acting directly or soliciting others to act for the purpose of promoting, opposing, amending, or influencing any action or inaction by any member of the executive or legislative branch of government or any public corporation.
- Political Activity:
Activities that are not campaign activities nor involve the promotion or opposition to a ballot referendum, but may include voter education and registration, Candidate forums, public opinion polling, responding to constituents as a public official, and get out the vote events, as long as they are non-partisan and follow the provisions of this policy.
- Student Organization:
University-recognized campus-based Student Organization.
All individuals to whom this policy applies are responsible for becoming familiar with and following this policy. University supervisors are responsible for promoting the understanding of this policy and for taking appropriate steps to help ensure compliance with it.
6.0 Consequences for Violating this Policy
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, the Anonymous Reporting Hotline allows anonymous and confidential reporting on matters of concern online or by phone (877-318-9184).
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.
7.2 Related Procedures:
7.3 Related Forms:
7.4 Frequently Asked Questions: