15.05.04.I1 High Risk Global Engagements and High Risk International Collaborations

2.1 On a quarterly basis, the System Research Security Office (RSO) provides member EOs with the list of Countries of Concern.

2.2 TTI employees are required to notify the TTI Ethics and Compliance Office (ECO) of any proposed international collaborations. The activity must be accurately captured by the principle investigator compliance statement within MAESTRO at either the proposal or project establishment stage or if an international engagement cannot be captured within MAESTRO, it is the employee’s responsibility to notify the ECO prior to execution of any instrument or collaborative activity occurs. Employees must provide the ECO with all information necessary to conduct the required review of the proposed activity.

(a) All proposed activities subject to this rule must be submitted to the ECO no later than 20 business days in advance.

2.3 The ECO provides review of proposed activities and will provide mitigation strategies for any potential conflicts of commitment, conflicts of interest, export controls or undue foreign influence that may be identified during review of proposed engagements. If TTI does not approve the proposed activity, a courtesy copy will be provided to RSO.

2.4 Upon the ECO’s review, all TTI approved High Risk Global Engagements or High Risk International Collaborations will be forwarded to the System RSO. The System RSO will coordinate review with the Office of General Counsel and the Vice Chancellor for Research (VCR).

2.5 The System RSO will provide the VCR’s final determination to TTI regarding the High Risk Global Engagement or High Risk International collaboration. Denial from the VCR is final.

2.6 All TTI employees are required to complete export control training via TrainTraq once every two years.

2.7 ECO monitors TTI activities for compliance with this regulation. Disciplinary action for non-compliance with this rule will be conducted by the ECO in accordance with System Regulation 32.02.02.

2.8 Malign Foreign Talent Recruitment Programs—System employees are prohibited from participating in Malign Foreign Talent Recruitment Programs, by or associated with a Country of Concern. Any System employee who receives solicitations to participate in Malign Foreign Talent Recruitment Programs must notify their respective office responsible for managing the member’s High-Risk Global Engagement and High-Risk International Collaboration process. TTI will provide the System RSO courtesy copies of all Malign Foreign Talent Recruitment Program solicitations.

2.9 System employees are prohibited from accepting gifts or traveling to a Country of Concern for professional purposes. Members must report to the TTI ECO any activities where employees are approached by groups representing a Country of Concern that offer gifts or travel. Additionally, all employees must report personal travel to Countries of Concern in Workday.

2.10 System employees are prohibited from entering into High Risk Global Engagements and participating in High Risk International Collaborations with entities on the most recent list developed pursuant to Section 1286 of the National Defense Authorization Act for Fiscal Year 2019 (Public Law 115-232) as amended.

2.11 Confucius Institutes – System members are prohibited from maintaining contracts or agreements with a Confucius Institute.