Drexel University and its affiliates are required to comply with a variety of legal requirements, including those applicable to organizations that have tax-exempt status under Section 501(c)(3) of the Internal Revenue Code. Among those legal requirements are the laws that prohibit 501(c)(3) tax-exempt organizations from participating in certain political fundraising or campaign activities. These requirements are outlined in standard 1.2 of the Code of Conduct that applies to all of us (http://www.drexel.edu/hr/policies/OGC5.pdf).

Although all members of the Drexel community are encouraged to take part in civic activities, including voting and participation in the electoral process, we must be mindful not to engage in activities that could jeopardize the tax-exempt status of Drexel University or its affiliates. A 501(c)(3) organization is viewed as participating in political fundraising or campaign activities whenever the reasonable consequences of the activity have the potential to influence voter opinion or to provide financial or volunteer aid to a candidate.

Individuals on their own time, and not as representatives of the University, may engage in political fundraising activities and support political candidates. They are not permitted, however, to utilize their University position or title, or the names, logos, symbols, websites, email accounts, letterhead, assets, equipment, personnel, mailing lists or other resources of the University or any of its colleges or schools; to ask others in the University to do so; or to otherwise engage in such activities in a way that might give the impression they are acting as a representative of, or on behalf of, the University.

In determining whether an individual has acted in an individual capacity or as a representative of the institution, the Internal Revenue Service looks at a variety of factors including the use of the institution¹s assets, personnel or resources; whether the political campaign activity occurred on the premises of the institution; whether political views were expressed in the institution¹s publications; and whether political views were expressed at functions sponsored by the institution.

Institutions that are found to have engaged in impermissible political campaign activity are subject to fines, loss of federal grants and loss of their tax-exempt status. Moreover, the institution can be put at risk by the activities of individuals with real or perceived authority to bind the institution, if their activities do not comply with the applicable legal requirements. Therefore, it is extremely important that the guidelines in this memorandum be followed.

Although this memo is not intended to be a comprehensive description of all of the rules applicable to political fundraising, it is intended to highlight some of the key areas that we all must be aware of, insofar as 501(c)(3) tax-exempt organizations such as Drexel University are held to a higher standard with respect to political fundraising, compared to for-profit entities. Accordingly, individuals who violate the guidelines will be subject to disciplinary action, which may include termination of employment.

If you believe there has been a violation of any of the applicable guidelines, you are encouraged to report it to either the Drexel University Compliance Hotline (215-895-1010) or the Drexel University College of Medicine Compliance Hotline (215-762-1010). All calls to the hotlines are confidential, and no information likely to reveal a caller¹s identity will be shared with anyone without the permission of the caller.

In the event you have any questions regarding this memorandum, please contact Drexel University¹s Office of the General Counsel at 215-895-1433 or the Drexel University College of Medicine¹s Office of the General Counsel at 215-762-7885.