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University Political Activities Interim Policy


​Purpose/Background

This Policy addresses the university's obligations to refrain from participating in political campaign activities pursuant to IRS rules governing 501(c)(3) not-for-profit organizations.

Applicability/Responsibility

This Policy applies to all university faculty, staff, and administrators in their capacities as university employees.

Definitions

TermDefinition
Participating or Intervention in Political Campaign ActivityAn organization “participates" or “intervenes" in a political campaign by engaging in an activity that favors or opposes one or more candidates for public office.
Legislative Activity (“Lobbying")

An organization will be regarded as attempting to influence legislation if it contacts, or urges the public to contact, members or employees of a legislative body for the purpose of proposing, supporting, or opposing legislation, or if the organization advocates the adoption or rejection of legislation.  A 501(c)(3) organization may engage in some lobbying, but if a substantial part of its activities constitute lobbying, the organization risks loss of 501(c)(3) status.​

Educational Activity or Issue Advocacy501(c)(3) organizations may involve themselves in issues of public policy, including taking positions on issues of importance to the organization, without the activity being considered lobbying.  For example, organizations may conduct educational meetings, prepare and distribute educational materials, or otherwise consider public policy issues in an educational manner, and as long as such activities do not advocate the adoption of legislation or legislative action, they will not constitute “lobbying activities".

 

Policy Statement

As a 501(c)(3) tax-exempt organization, the University does not participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of (or in opposition to) any candidate for public office.  This prohibition on political campaign activity is applicable to campaigns at the federal, state, and local levels, and is an absolute prohibition applicable to all university faculty, staff, and administrators, such that violating it may result in revocation of tax-exempt status and/or the imposition of certain excise taxes.

The university may, as limited circumstances warrant, engage in Legislative Activity (lobbying) for those concerns of public policy which may directly or indirectly impact the university. The university may also contribute to public discourse through either Educational Activity or Issue Advocacy, by presenting a sufficiently full and fair exposition of the pertinent facts to permit the public to form its own opinion or conclusion independent of that presented by Pacific.

Finally, the university may undertake to host certain political events (such as candidate fora, debates, etc.) so long as each and every candidate for that particular public office is invited to participate, and the university does not implicitly or overtly favor or oppose any individual candidate.

Approval of Political Activity or Event
All political activities or events undertaken at Pacific must be pre-approved by the Division Vice President and/or Dean and in consultation with the Office of General Counsel. Interested parties should submit a proposal in writing, describing the activity or event in detail, prior to any public announcement of the activity or event.

Personal Political Participation
University faculty, staff, and administrators may participate in political activities in their individual capacities as citizens but must refrain from portraying such political participation as representative of the university. Personal political advocacy may not utilize the support or resources of the university.

Violations

Failure to adhere to this policy and its associated procedures by university personnel will result in disciplinary action in accordance with the Disciplinary Action Policy for Compliance Misconduct [LINK].

Contact Information

If you have questions or concerns about your obligations under this Policy, consult the Office of Compliance & Ethics, Chief Compliance Officer at (209) 946-7446.

Related Information

ItemDescription
University LinksDisciplinary Action Policy for Compliance Misconduct
Forms 
Related Links
Procedures   

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About This Policy
Last Updated
9/20/2022
Original Issue Date
11/1/2011

Responsible Department
Finance Operations