International Research Collaborations
Issues, Resources and Definitions
Purdue University values international collaborations with researchers from around the world and welcomes students and scholars to campus from all parts of the globe. These international collaborations and educational opportunities are essential to successful fulfilment of our mission to move the world forward. The federal government is closely scrutinizing all international collaborations and activities and has dramatically enhanced their reporting and disclosure requirements. This has necessitated an expanded set of expectations for researches openness and transparency when engaging with foreign entities.
Below are several links to Purdue University’s policies and guidelines for reporting and disclosure. In addition Links are provided to a January 2021 report from the National Science and Technology Council and the Joint Committee on the Research Environment which includes their definition of the issues facing the research enterprise and their recommendations. In addition, the President of the United States released a memorandum on January 14, 2021 on R&D and strengthening protections of United States Government-supported Research and Development (R&D) against foreign government interference and exploitation. In this memorandum he provides a good definition of foreign government-sponsored talent recruitment program. These resources can help you understand your individual reporting responsibilities related to the enhanced scrutiny around undue foreign influence.
Resources - Purdue University Reporting and Disclosure Responsibilities
Requirements: https://www.purdue.edu/business/sps/data/disclosure.html
Frequently Asked Questions: https://www.purdue.edu/business/sps/pdf/Disclosure_and_Reporting_Requirements_FAQ%20vfinal.pdf
Reportable Outside Activity (ROA)
Guidelines: https://www.purdue.edu/ethics/resources/ROAformguidelines.php
FAQ – Conflict of Commitment and Reportable Outside Activity: https://www.purdue.edu/ethics/resources/faqs/coc-faqs.php
Current and Pending Support (C&P) – Grant and Award Management
Purdue and Agency Guidance: https://www.purdue.edu/business/sps/preaward/menu/2.proposalprepare/basic_elements/othersupport.html
Conflict of Interest (COI), Conflict of Commitment (COC) & Financial Conflict of Interest (FCOI)
Overview: https://www.purdue.edu/research/regulatory-affairs/conflict-of-interest/
Policy COI: III.B.2 - University Policy Office - Purdue University
Policy COC: III.B.1 - University Policy Office - Purdue University
Disclosure Decision Tree: Employee decision tree for disclosure of research related financial interests and entrepreneurship activities - Office of the Executive Vice President for Research and Partnerships (purdue.edu)
Intellectual Property
Policy: I.A.1 - University Policy Office - Purdue University
Disclosure: Planning a Public Disclosure or Sale - Office of Technology Commercialization - Purdue University (prf.org)
FAQ - Outside Activity & IP - Frequently Asked Questions: Outside Activity and Intellectual Property - Office of the Executive Vice President for Research and Partnerships (purdue.edu)
Export Control and Research Information Assurance
International Travel
Report from the National Science and Technology Council and the Joint Committee on the Research Environment
Excerpts: The open and collaborative nature of the U.S. science and technology (S&T) research enterprise, along with the integrity and public trust with which it operates, underpin America’s innovation, S&T leadership, economic vitality, and national security. Maintaining an open research environment is critical to fostering research discoveries and innovations that benefit our Nation and the world. Principled international collaboration and foreign contributions are critical to the success of the U.S. research enterprise. In particular, they enable cutting-edge research that cannot otherwise be achieved, strengthen scientific and diplomatic ties, leverage resources, and support training of a robust S&T workforce capable of solving global problems. At the same time, this open environment must be balanced by mechanisms that protect intellectual capital; discourage misappropriation of research plans, pre-publication data, and outcomes; and ensure responsible management of U.S. taxpayer dollars.
The integrity of the research enterprise rests on foundational principles and values, which are also consistent with American values:
- Openness and transparency enable productive collaboration and help ensure appropriate disclosure of potential conflicts of interest and conflicts of commitment.2
- Accountability and honesty help acknowledge errors and correct behaviors that can hamper progress.
- Impartiality and objectivity protect against improper influence and distortion of scientific knowledge.
- Respect helps create an environment where all can be heard and contribute.
- Freedom of inquiry allows individual curiosity to guide scientific discovery.
- Reciprocity ensures that scientists and institutions exchange materials, knowledge, data, access to facilities and natural sites, and training in a way that benefits all collaborating partners.
- Merit-based competition helps ensure a level playing field where the best ideas and innovations can advance
Some of the foundational principles—like openness, transparency, and accountability—are relevant to all, from individual researchers, to research organizations, to governments. Impartiality, objectivity, honesty, and respect—are at the core of how individuals and organizations should conduct research to ensure rigor and reproducibility. Freedom of inquiry, reciprocity, and merit-based competition—are the responsibility of all, but especially governments, to protect and foster.
Behaviors that violate these foundational principles and values jeopardize the integrity of the research enterprise. Behaviors that threaten the integrity of the research enterprise often also pose risks to the security of the research enterprise, which we term research security.
Unfortunately, the governments of some countries do not demonstrate a reciprocal dedication to these same principles and values. Over the past several years, some individuals and foreign governments have exhibited increasingly sophisticated efforts to exploit, influence, and undermine U.S. research activities and environments.
Over the past several years, some individuals and foreign governments have exhibited increasingly sophisticated efforts to exploit, influence, and undermine U.S. research activities and environments.
Recent breaches of research integrity within America’s research enterprise include failures to disclose the following:
- Funding (research subsidies, salaries, and personal payments)
- Parallel laboratories
- Employment, affiliations, and appointments (including leadership positions in foreign research organizations)
- Conflicting financial interests (including investment in and even ownership of private companies specializing in the same work performed at individuals’ U.S. research organizations)
Inappropriate or exploitive behaviors have included conducting undisclosed research for foreign governments or companies while being funded for that same research effort or time by U.S. agencies; diversion of intellectual property (IP) or other legal rights; and breaches of contract and confidentiality in or surreptitious gaming of the peer-review process.
Many of these behaviors have been associated with undisclosed participation in certain foreign government-sponsored talent recruitment programs.
Presidential Memorandum on United States Government Supported Research and Development National Security Policy
Definition of “foreign government-sponsored talent recruitment program” or “foreign government-sponsored talent recruitment programs” means an effort directly or indirectly organized, managed, or funded by a foreign government or institution to recruit S&T professionals or students (regardless of citizenship or national origin, and whether having a full-time or part-time position).
- Some foreign government-sponsored talent recruitment programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government.
- Many, but not all, programs aim to incentivize the targeted individual to relocate physically to the foreign state for the above purpose. Some programs allow for or encourage continued employment at United States research facilities or receipt of Federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to United States entities.