Guiding Principles for Ensuring Research Security from Inappropriate Foreign Influence
As a world-leading institution whose mission is the creation, transmission and preservation of knowledge, Princeton University thrives by attracting talent from across the world, and by embracing the free exchange of knowledge and ideas. Princeton is committed to a culture of inclusion and respect towards all members of the scholarly community.
Since 2018, government officials, on both sides of the aisle, have expressed growing concern about security threats posed by inappropriate foreign influence in research. The most serious allegations include instances of academic espionage aimed at illegally acquiring intellectual property and non-disclosure of foreign funding that overlaps with federally-funded research. Princeton takes these concerns seriously.
Princeton has developed a set of principles designed to guide the formulation of policies that mitigate the risks arising from inappropriate foreign influence in research while upholding the University’s core values of openness, respect and inclusion. Those principles are outlined below.
As the national conversation on science and security evolves, we will communicate periodically with the campus community as new security policies are developed and implemented. Our goals are to ensure that the University is meeting its obligations to sponsoring agencies and the government; to support the values that define us as a community and as a research and teaching university; and to develop policies that enable students and faculty to conduct research without risk of civil or criminal penalties.
I. Basic principles
- Princeton University must be open, attracting talent from across the world, and embracing and practicing the free exchange of knowledge and ideas. This ethos underlies the extraordinary success of the U.S. research enterprise, underlying its world primacy and resulting in ideas and inventions that have improved the quality of life and economic well-being of society at large, both in the U.S. and abroad.
- The U.S. government is increasingly concerned about efforts by some foreign governments to influence unduly or benefit inappropriately from federally-funded research, and about the consequences of such efforts for our country’s security, economic wellbeing and scientific and technical leadership. Princeton takes these concerns seriously and must implement policies that ensure full compliance with American law and mitigate the underlying risks effectively, while upholding the principles of openness, respect and inclusion.
II. Funding Sources
- When applying for government funding, Princeton employees and affiliates, in their capacity as Principal Investigators, must disclose all current and pending support, including domestic and foreign contracts, grants, awards, as well as in-kind support, irrespective of whether this support is provided through Princeton or directly to the Principal Investigator¶. This disclosure requirement applies to support from government, private and not-for-profit sources.
- The University will not accept, or will restrict the scope of, funding from companies or foreign governments that pose documented or observable risks to American security interests:
- The University will not accept funding from foreign governments, corporations, other organizations or persons that have been formally designated as security risks by agencies of the United States government§.
- The University may restrict the scope or use of funding from foreign governments, corporations, other organizations or persons when publicly available information suggests that the entity is behaving in ways that threaten American security or the University’s core values.
- The University encourages researchers to consider the ethical implications of funding offered to them by foreign governments, corporations, other organizations or persons, and may at times supply researchers with information relevant to such ethical issues.
- Princeton University maintains an open research environment and seeks to attract talented individuals from all nations and backgrounds. Individuals should not be excluded from University research collaborations solely based on their nationality.
- Individuals funded by foreign governments through programs that represent clear risks to American security or by foreign companies that represent clear risks to American security should not take part in U.S. government-funded University research projects.
- Individuals funded by foreign governments through programs that represent clear risks to American security or by foreign companies that represent clear risks to American security should be given the option of relinquishing that funding so that they may be considered for participation in U.S. government-funded University research projects.
IV. Restricted Areas of Research
- The vast majority of the research conducted at Princeton University is open, and of the kind where all individuals are welcome to participate.
- The University may, now or in the future, conduct some research [defined by existing or modified classification criteria already in place such as Technology Readiness Level (TRL) >3, Department of Defense (DoD) 6.2, 6.3, or U.S. government export control regulations] where both restrictions on funding sources and participant nationality, as well as pre-publication review may be appropriate.
- Restricted areas of technology should be defined narrowly to include those with potential military application or impact on sensitive infrastructure.
V. Policy Development
- Through its participation in organizations such as the Association of American Universities (AAU) and its own Office of Government Affairs, Princeton should advocate that government funding agencies [including the National Science Foundation (NSF), National Institutes of Health (NIH), Department of Energy (DOE), Department of Defense (DoD), National Institute for Standards and Technology (NIST), and others] have clear and, as much as possible, congruent compliance frameworks.
- Implementation of those compliance frameworks should rely on existing University infrastructure (e.g., the Office of Research Integrity and Assurance, the Office of Research and Project Administration, and the Office of Sponsored Research Accounting), rather than creating new University offices.
- The University should advocate for policies that simultaneously respect the legitimate national security interests of the United States and support the free flow of talent that has been essential to innovation, leadership and prosperity throughout our country’s history.
- Guidance on your responsibilities related to federal funding agencies is available on the ORPA website and through consultation with Elizabeth Adams, Director, Office of Research and Project Administration, [email protected] or (609) 258-3090.
- Information about export controls is available within the export controls section of the ORPA website and through consultation with John Jenkins, Assistant Director of Export Controls, [email protected] or (609) 258-3819.
- Guidance on your rights if contacted by a federal agent is available in General Guidance: Contacts with Law Enforcement (.PDF).
Responsible Executive: Dean for Research
Responsible Office: Office of Research and Project Administration
Contact: Elizabeth Adams, Director, Office of Research and Project Administration, [email protected] or (609) 258-3090
Publication Date: 9/26/2019
¶ Princeton’s Office of Research and Project Administration is responsible for providing up-to-date and agency-specific information on these and other disclosure and reporting requirements related to proposals submitted to federal funding agencies.
§ The U.S. government should maintain a list of foreign companies or other entities that should be excluded from funding U.S. research projects.