Foreign Engagement Guidelines

Guidelines for Foreign Entity Relationships

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Recent communications from federal agencies have made it clear that there is increased scrutiny from our research sponsors regarding our relationships with foreign entities. As a result, a number of investigators, here and at other universities, have asked for guidelines in this area.

Below is guidance that we hope will help clarify UM’s position on various activities relating to foreign entities. Further information may be obtained from the Office of Research Administration, the Office of the Vice Provost for Research, the Office of Faculty Affairs, and the Office of Technology Transfer.

Restricted Party Screening (RPS) is recommended prior to any related business interchange or interaction.

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  • Activities that are permitted, and which require disclosure

    • UM will receive an award/subaward from a foreign university or company.
    • A foreign entity (university, government, industry, or foundations) will reimburse investigator travel costs or pay an honorarium to an investigator to participate in a conference or deliver a lecture.
    • An investigator will engage in unpaid research activities with a foreign research laboratory-- typically at a university. Additionally, review and approval may be required because of intellectual property considerations, or if an investigator’s affiliation on research products (such as proposals and publications) will not solely be that of UM.
    • An investigator participates in research in a foreign country. This must be disclosed as current or pending support in funding applications. This includes grants, gifts, or any other financial support for research. In addition, if a faculty member is a named investigator at another institution, the project should be disclosed even if compensation is not provided. Any resulting publications or presentations must include the investigator’s affiliation with UM as a primary affiliation.

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