Political Activity - Policies and Policy Governance

1. Policy

Issued: October 2, 2002
Last Reviewed: May 12, 2026
Last Revised: May 12, 2026

Applies to: Faculty (including part-time, adjunct and visiting faculty), postdoctoral scholars, staff (including graduate/undergraduate student workers and graduate assistants) employed by University of Southern California (“USC” or the “University”) and including those working for the University’s health system (“USC Employees”), students and Recognized Student Organizations. This policy continues to apply to individuals who are on sabbatical or other leaves, or who are visiting other institutions.

2. Policy Purpose

The purpose of this policy is to ensure that the University of Southern California (USC) complies with applicable laws related to political activity and tax-exempt organizations under Internal Revenue Code Section 501(c)(3). USC is legally prohibited from endorsing, supporting or opposing candidates for political office or a political party, or making contributions to candidates or political parties, and it is limited in legal lobbying activities. This policy is supplemented by the Political Site Visit and Events Policy.

3. Scope

This policy applies to all individuals and groups affiliated with USC, including faculty, staff, students, and Recognized Student Organizations (RSOs), that wish to participate in the political or legislative process, or otherwise engage with Government Officials or candidates for public office, as well as any other activity that meets the definition of Political Activity, below.

This policy does not limit the rights of faculty, staff, or students, acting as individuals and not on behalf of USC, to participate in the political process. Per the Policy on Prohibited Discrimination, Harassment, and Retaliation, the University prohibits discrimination on the basis of actual or perceived political belief or affiliation.

4. Definitions

Term	Definition
Political Activity	Any activity regulated by any federal, state, local, or foreign law related to participation in the political or legislative process, including but not limited to campaign finance laws, lobbying laws, government ethics laws, and related provisions of any tax code applicable to USC, as well as any other activity that relates to political campaigns, political action committees, influencing legislation or administrative action, or engaging with Government Officials or candidates for public office. Seeking government contracts or grants through formal, established processes, such as submitting grant proposals or responding to RFPs, is not Political Activity. Attempting to influence a government contract or grant via communications with Government Officials outside of formal processes is Political Activity. Discussing ongoing or concluded research or scholarly projects with Government Officials is not Political Activity. Discussing potential future research or scholarly projects is not Political Activity so long as the discussion is limited to possible future areas of research and is not intended as advocacy for funding for USC.
USC or University	Includes departments, schools, other units, and the health system.
Government Official	Elected or appointed public officials (typically including most of their staff members) or government employees empowered to make governmental decisions. Government Officials may also be Political Candidates.
Political Candidate	A person running for elected office in the United States, regardless of whether the election is considered partisan or nonpartisan. Political Candidates may also be Government Officials.
Recognized Student Organization (RSO)	Student organizations that have been approved for recognition in accordance with the USC Student Handbook and who are in good standing as defined by USC Student Life.

5. Policy Details

While Federal, State, and Local laws limit the university’s participation in political activities using facilities or support, they do not forbid faculty, students, or staff (in their individual capacities) from supporting candidates for office, political parties, or issue-based campaigns. All members of the USC community are free to express their political opinions and engage in political activities in their individual capacities. Any political statement made by a member of the USC community, including, but not limited to, any statement taking a position or expressing an opinion in connection with proposed or current legislation, a ballot measure, regulation, law or ruling, is attributable solely to that individual, unless such statement is authorized by this Policy, or was otherwise specifically authorized by the Office of University Relations, to be made on behalf of the university.

Any faculty, staff, or student using a university title or affiliation while making a political statement that could reasonably be understood to be made on behalf of the university, must clarify that they are speaking on their own behalf, unless otherwise permitted by this Policy or the Office of University Relations. An example of such a statement is, “The views I’m sharing today are my own as a(n) [scholar, professor, or individual], and do not represent the views or endorsement of USC,” or for written material ,“Affiliation listed for identification purposes only. The views expressed are solely my own and not those of the University of Southern California.”

While faculty, staff and students are entitled to identify their affiliation with USC, no individual is authorized to expend any university funds in connection with Political Activities on behalf of USC, except as authorized by this Policy or the Office of University Relations. Any unauthorized commitment, contract, statement, or expenditure constituting a Political Activity that implies it is on behalf of USC and is contrary to this Policy shall be void and unenforceable.

Support for Political Candidates, political parties, and political action committees that support candidates or parties
1. USC is a nonpartisan institution and does not support Political Candidates, political parties, or political action committees that support candidates or parties. USC does not make direct financial contributions to such individuals or entities, nor does USC provide indirect or in-kind support.
2. No USC faculty, staff, or student may make any statement or take any action that would create the appearance of an endorsement by USC of a Political Candidate or political party. This prohibition includes the use of websites, social media accounts, or other resources to support or solicit support of Political Candidates or political parties.
  1. RSOs may make statements endorsing Political Candidates or political parties so long as the statements are clearly attributable to the RSO, not the University, and neither the University nor faculty advisors exercise direction or control over the content of the statements.
Support for ballot measures, ballot measure committees, or political action committees that support ballot measures (“issues PACs”)
1. USC may support ballot measure committees or issues PACs to the extent permissible by law.
2. Any support for a ballot measure, ballot measure committee, or issues PAC using USC funds or resources, whether direct or indirect financial support or in-kind support, must be approved in advance by the Senior Vice President, University Relations, who shall consult with the Office of the General Counsel and the Office of Ethics and Compliance.
  1. Regular payments to trade or industry associations of which a portion is a political contribution do not require the advance approval of the SVP, University Relations, but the portion of those payments that are political contributions are subject to the disapproval of the SVP, University Relations at any time. Special payments or assessments that are political contributions require advance approval.
3. No USC faculty, staff, or student may make any statement or take any action that would create the appearance of an endorsement by USC of a ballot measure or issues PAC without advance approval of the Senior Vice President, University Relations.
  1. RSOs may make statements endorsing ballot measures or issues PACs so long as the statements are clearly attributable to the RSO, not the University, and neither the University nor faculty advisors exercise direction or control over the content of the statements.
Lobbying
1. In general, lobbying is an attempt to influence any legislative or administrative action at the Federal, State, or Local level. A number of laws impose registration and reporting requirements on individuals who engage in certain types of communications with government officials, and these lobbying laws and regulations differ depending on the jurisdiction. Tax-exempt entities, such as USC, are permitted to lobby on certain issues. Because governmental decisions have the potential to significantly impact the university, USC frequently participates in the governmental process at the Federal, State, and Local levels. Since many jurisdictions impose registration and reporting requirements, no individual is permitted to lobby on behalf of the university without prior approval from the Office of University Relations. When such authorized communications are made on behalf of the university, the university may be required to register and report.
  
  To ensure that the university and its authorized representatives and employees fully comply with all applicable laws relating to lobbying:
  1. Any faculty/staff member who communicates with a Federal, State, or Local Government Official (elected, appointed, or staff) on behalf of the university, and those who research or prepare materials on behalf of the university for the purpose of communicating with a Federal, State, or Local Government Official (elected, appointed, or staff) in an attempt to influence any legislative or administrative action must notify the Office of Ethics and Compliance. (Communication includes in-person meetings whether on or off campus, telephone calls, emails, letters, or any other means of communication.)
  2. No outside lobbyist or lobbying firm may be engaged by any school, department, or division without the prior approval of the Senior Vice President of University Relations.
  3. This policy does not affect communications as individuals. Any faculty/staff member/student may personally choose to participate in voluntary political activities not sanctioned or endorsed by the university.
Gifts and honoraria to Government Officials and Political Candidates
1. Occasionally, the University provides items of value, such as meals or tickets to events, to Government Officials and Political Candidates. Depending on the jurisdiction of the official or candidate, and the nature of the gift, these gifts may be subject to limits and reporting requirements. To ensure that the University complies with all applicable laws relating to gifts, no costs or expenses may be incurred to provide anything of value to a Government Official or Political Candidate without prior approval of the Office of Ethics and Compliance.
2. USC generally does not pay honoraria to Government Officials or Political Candidates. Exceptions require the approval of the Senior Vice President, University Relations and the Office of Ethics and Compliance.
Faculty and staff as Political Candidates
1. Faculty may become Political Candidates, subject to the restrictions of the Faculty Handbook. See Section 3-G.
2. Staff may become Political Candidates so long as such activity does not create a conflict of interest or commitment. See Conflict of Interest and Commitment Policy.
Faculty and staff as Government Officials
1. Occasionally, a USC faculty or staff member will be asked to join a government board or otherwise serve as a part-time Government Official. When these activities are not part of the employee’s duties to USC, they will be reviewed and analyzed under the Conflict of Interest and Commitment Policy and, for faculty, the conflict-of-interest provisions of the Faculty Handbook. USC may be required by law to publicly report the salaries of, and other payments made to, these employees.
Faculty and staff as former Government Officials
1. USC faculty and staff who have previously served as Government Officials may be subject to certain post-government employment restrictions (commonly known as “revolving door” laws). Any USC employee subject to a post-government employment restriction that would restrict their ability to lawfully perform their duties to USC must disclose this to their supervisor immediately upon hire. The supervisor shall immediately contact the Office of Ethics and Compliance who will work with the supervisor and employee to understand the scope of the restrictions and develop a workplan for the employee that is legally compliant.
2. If a supervisor or USC Human Resources professional becomes aware of possible post-government employment restrictions during the recruiting or hiring process, they must consult with the Office of Ethics and Compliance before an offer is made to ensure that the candidate is legally permitted to perform the functions of the job to which they are applying
Personal Political Contributions by Trustees and Corporate Officers
1. California and local laws occasionally impose restrictions or additional reporting requirements on personal political contributions by USC’s Trustees and Corporate Officers. USC Trustees and Corporate Officers shall not make personal political contributions that are impermissible, or that inhibit the University’s business interests.
2. The Office of the General Counsel will provide specific guidance on this topic to Trustees and Corporate Officers.
Student-run media
1. While supported by USC, the Daily Trojan and Annenberg Media operate with independent, student-run editorial control and act as bona fide news organizations. The Internal Revenue Service has determined that, “The provision of facilities and faculty advisors for a campus newspaper that publishes students’ editorial opinions on political and legislative matters does not constitute an attempt by the university to influence legislation or participate in political campaigns.” See IRS Revenue Ruling 72-513. Similar exemptions from campaign finance and lobbying laws exist for bona fide news organizations. Accordingly, the Daily Trojan and Annenberg Media are exempt from sections A, B, and C of this policy.
USC Name, Logo, Graphic Identity, and Resources
1. To avoid any appearance of prohibited Political Activities, the name, logo, mark, seal, or any other graphic identity of the University or any of its schools, departments, units, institutes, or divisions may not be used to imply the University is taking a position on any political issue, political party, or candidate, without prior approval of the Office of University Relations, which shall consult with the Office of the General Counsel and Office of Ethics and Compliance.
2. No University services, equipment, supplies, or employees may be utilized for unapproved political purposes, and no University location may be used as a return mailing address for unapproved political mailings.

6. Procedures

N/A

7. Forms

Email politicalcompliance@usc.edu for questions related to this policy.

8. Responsibilities

Position or Office	Responsibilities
Office of Ethics and Compliance (Compliance Lead regarding political activities)	Prepare and file reports of Political Activity; provide guidance regarding compliance with laws governing Political Activity.
Office of University Relations	Provide approval for various regulated Political Activity.

9. Related Information

Political Site Visit and Events Policy
Political Activity FAQ
University’s Freedom of Expression website

10. Contacts

Office	Phone	E-mail
Office of Ethics and Compliance	(213) 740-8258	politicalcompliance@usc.edu