Political Activities and Lobbying Guidelines

To: The Caltech Community
From: Jennifer Lum, General Counsel; Shayna Chabner, Chief Communications and External Relations Officer

In recent weeks, particularly as Congress discusses pending legislation regarding federal spending policies and federal appropriations for science and university-based research, our offices have received an increase in individual inquiries and questions from the Caltech community for clarity on rules related to political activities and lobbying. 

As a nonprofit, tax-exempt research and education institution, federal, state, and local laws govern political activities and lobbying, including rules on what types of activities are allowable by Caltech and individual Caltech employees acting on behalf of or as a representative of the Institute, and requirements for detailed and timely reporting of any such activity. Violation of these rules could cause the Institute to lose its tax-exempt status or incur excise taxes imposed on political expenses.

In light of the community's interest and in an effort to provide clarity on the distinction between personal activities and engagement and actions by the Institute, we write to share the Institute's Political Activities Guidelines. The guidelines provide specific details on the laws and policies that the Institute is required to comply with as a tax-exempt organization and make clear that only specific individuals are authorized to communicate with government officials on behalf of Caltech to oppose, support, or inform legislation or to solicit others to communicate with government officials on behalf of Caltech. These rules include specific prohibitions on the use of Caltech resources—such as Caltech email, Institute-issued computers or devices, and office materials and letterhead—by individuals engaged in personal political activities or lobbying. 

To be clear, these rules in no way restrict each person's right to express political opinions and engage in political activities solely through personal resources. Discussion of political and policy issues that impact academic and research endeavors are a welcome and important part of Caltech's values and principles fostering robust and inclusive debates. However, we must be certain to maintain a clear distinction on what Caltech employees and students do in their personal capacities and avoid the appearance that Caltech employees and students, who are not otherwise authorized to do so, are speaking or acting on the Institute's behalf.

When engaging in these activities in their personal capacities, Caltech employees and students should comply with the following guidelines:

1. Caltech employees and students should not use Caltech resources for any political activities. Caltech resources include, among other things, email distribution lists, meeting spaces, research tools (including computers, cell phones, and laptops) and databases, copy machines, staff and administrative support time, postage, and contact lists.
   
2. Caltech employees and students should not use their Caltech email for any outreach.
   
3. If Caltech employees and students will be encouraging other members of the Caltech community to contact government officials, they should contact only those Caltech community members they know personally as well as professionally and should not solicit subordinate employees to engage in such outreach.
   
4. Caltech employees should engage in such outreach activities outside of their work hours.
5. Although Caltech employees may state that they work for Caltech, they should not represent themselves as speaking officially on behalf of Caltech.

Thank you for your attention to this matter. We encourage everyone to review Caltech's Political Activities Guidelines. If you have any additional questions, please contact Caltech Chief Communications and External Relations Officer Shayna Chabner (phone: 626-395-6762 or [email protected]) or the Office of the General Counsel (phone: 626-395-3241).