Guidance on Political, Campaign and Lobbying Activity
PAFA is committed to the expression and discussion of ideas and opinions and encourages members of the PAFA community to be informed, actively engaged citizens. PAFA, the institution, is a non-profit entity whose activities are regulated by Section 501(c)(3) of the Internal Revenue Code, which imposes restrictions on its support of candidates and how it engages in lobbying activities, which includes limits on the use of PAFA resources. These restrictions necessarily require some definition, described below, of activity by PAFA faculty, staff, and students that could be inconsistent with those restrictions and thus put PAFA at risk of losing its non-profit status.
In conjunction with this Guidance, there are several PAFA policies that should be reviewed, including but not limited to:
- Code of Ethics
- Social Media
- Solicitation and Distribution
- External Communication and Press
- Electronic Communications Systems and Internet Usage
- Academic Freedom
This Guidance has been prepared to provide a quick reference regarding who has authority to speak on behalf of PAFA, the institution, and to note the needed restrictions, if any, on faculty, staff, students and others affiliated to ensure that their activities may not be construed as PAFA, the institution, engaging in political activity that could adversely affect the institution.
Formal statements expressing the position of PAFA as an institution can be taken by the Board Chair and the President and CEO only. Faculty, staff, students, and others affiliated with PAFA are not authorized to take institutional positions on public policy or societal issues. Faculty, staff, (collectively “Employees”), students, and others affiliated with PAFA should take care to clarify when there could be confusion on the point, by noting that any statements they make are not on behalf of the institution. Senior staff, as officers of PAFA, when making public statements should clarify that they are not speaking for the institution.
Employees and students are free to participate in activities to express themselves on political, social issues and concerns, such as at campaign events, editorials, blogs, petitions, and other public media. They should be particularly careful that it is understood they are speaking and acting as individuals that they are not acting on behalf of PAFA, the institution.
Use of PAFA Resources
To comply with applicable law and regulations, PAFA services, resources, or funds cannot be used to engage in unapproved lobbying activities or to suggest in any way PAFA’s endorsement or support of a political candidate, political party, or political action committee. No Employees, students, or groups of the foregoing may use PAFA’s name, letterhead, logo, email, or seal to solicit funds for or otherwise support or oppose any such campaign or cause or engage with a political action committee or engage in communications with respect to public policy or societal issues and concerns.
In addition, consistent with PAFA’s policy for the use of its email system—which limits its use to work matters only—employees should not use PAFA email accounts or PAFA stationery to distribute political communications, campaign messages, statements or petitions with respect to public policy or societal issues and concerns, and similar material.
Running for Political Office
Those Employees and students seeking public office are strongly encouraged to meet with Human Resources to determine the appropriate use of PAFA property and resources. PAFA’s name may not be mentioned in the solicitation of contributions or other commitments, other than to identify PAFA as the Employee’s place of employment or the student’s place of study.
To avoid conflicts of interest, when teaching a PAFA course or otherwise employed at PAFA while seeking an elective office, Employees may not request or solicit campaign assistance, participation, or fundraising from students attending the School, student workers or interns.
Voter Registration and Education
The PAFA community is encouraged to be active and informed participants in the electoral process. Non-partisan voter education activities, including public forums and voter registration, are permitted at PAFA. Careful attention must be paid to ensure that these kinds of activities remain non-partisan in order to comply with the government guidelines for non-profit organizations.
Individual and Group Support of Candidates, Parties or Petitions
PAFA, the institution, may not engage in activities to advocate for the election or defeat of a political candidate or political party or to promote or encourage such advocacy or petitions in support of a party or individual candidate.
PAFA supports student and employee efforts to become involved in the political process and campaign-related activities, both within the PAFA community and off-campus. It is important, however, in order to safeguard PAFA’s non-profit status, that Employees and students, when involved be clear they are speaking as an individual and not on behalf of PAFA, the institution. Questions or issues should be directed to the Vice President of Human Resources.
- Student groups may engage in partisan activity on-campus but must make it clear in their written materials, verbal statements, and at their events that student group members speak as individuals and not on behalf of PAFA.
- In signing petitions or speaking on or writing about public policy or societal issues, students and Employees may identify PAFA as their place of schooling or employment; however, if the context of the petition or the oral or written statement could lead a reader to believe the individual is speaking on behalf of PAFA, the individual should clarify that they are speaking as an individual and not on behalf of PAFA, the institution.
- Senior staff should not identify their position at PAFA when engaged in activities to advocate for the election or defeat of a political candidate or political party or to promote or encourage such advocacy or when signing petitions or similar documents, because their status as officers of the institution heightens the risk of confusion as to whether they are speaking on behalf of the institution. When speaking or writing on matters with respect to public policy or societal issues and concerns, including petitions, senior staff should take the extra step to clarify that that they are not speaking on behalf of PAFA, but as an individual. When speaking, they should confirm that it is the understanding of the person they are speaking to, or in written materials, add a disclaimer, that they are not speaking on behalf of PAFA.
Renting to Government Officials, Campaign Representatives and Other Political Guests
PAFA facilities may be used for events involving government officials and candidates. Rental of PAFA spaces are subject to specific limitations and requirements, such as capacity limits, audio-visual availability and compatibility, photography restrictions, fees, and the serving of food and beverages.
- Using official university stationery, wordmark, seal, email, telephones, computers, printers, and copiers.
- Posting a hyperlink on a PAFA-administered website to a candidate, campaign site, or cause.
- Using PAFA email accounts to share material or information with respect to political parties, political candidates, political action committees or petitions for political activity.
- If an appearance by a declared candidate for public office or a group supporting a public referendum is broadly publicized to nonmembers of the PAFA community or is co-sponsored or paid for by outside organizations, the sponsors must rent the space from PAFA on the same terms that are available to any group wishing to use such space. If space is rented to a candidate in an election, any competing candidate would be able to rent space on the same terms.
- Candidates may be invited to appear on campus in a non-candidate capacity, e.g., to participate in a class, provided that no campaigning or fundraising is done at the event and a non-partisan atmosphere is maintained.
- Candidate forums or debates may be held on campus as part of PAFA’s educational mission, as long as all qualified candidates are invited to participate.