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International Relationships & Research Activities

Best Practices for Disclosure

Best Practices for Disclosing International Relationships & Research Activities
External Paid Employment
  • William & Mary instructional faculty, executive faculty, and administrative faculty have the privilege to engage in activities beyond the scope of their normal contractual obligations with businesses, organizations, other agencies or entities outside of the W&M. Such engagements often include but are not limited to consultancies, retainers, expert testimony, problem solving, and other such outreach activity that benefits communities while enhancing the skills of the university’s faculty and providing examples of best current practice in applications to improve their teaching.
  • When these engagements are paid, they are governed by guidelines in the William & Mary Policy on External Employment and the Faculty Handbook.
  •  The External and Outside Employment Approval Form should be completed by any member of the Executive/Professional Faculty or Instructional Faculty who is planning to accept employment from an organization outside the College of William and Mary who will be paid directly by the entity. Procedures for completing and submitting the form may be found here. The form must be reviewed and approved by the appropriate Department Chair/Center Director, Dean or Administrative Supervisor, and the Vice Provost for Research and Graduate Professional Studies BEFORE External Paid Employment is undertaken. 


Unpaid Appointments
  • In response to well-publicized cases on other campuses, the University is in the process of developing enhanced guidance for faculty about disclosure of relationships with foreign governments and institutions.  This guidance is intended to limit the risk of enforcement actions against either the university or individual faculty members by facilitating compliance with federal grant and contracting requirements.  In the meantime, we strongly recommend that all faculty list all of their international university affiliations on their CVs and webpages and disclose them as appropriate in grant proposal documents.  Please feel free to contact Vice Provost for International Affairs or Vice Provost for Research and Graduate/Professional Studies if you have any questions or concerns.
Conflicts of Interests 
  • A University researcher who has a personal financial interest that may bias or appear to bias their research, could have a research related financial conflict of interest. Virginia Law, federal research rules, and University policy define and regulate these conflicts. No distinction is made between domestic and international financial interests with regard to these requirements. For more information, visit the Compliance and Equity Office’s Conflict of Interests page. 
  • University employees who are required to complete an annual Statements of Economic Interest should disclose certain personal financial interests as mandated by state law. Employees are advised that if a particular financial or other interest is prohibited by the Conflict of Interests Act or other applicable policy or law, disclosing that interest does not cure the violation. An employee who has a conflict of interest must report the situation to the Conflict of Interest Committee (and the Vice Provost for Research/Office of Sponsored Programs as appropriate) for review and take any other action required by law or policy.   
Sponsored Research Disclosures
  • Applicants for external funding are, as part of the proposal package, typically required to disclose. “Other Support” or “Current & Pending Support” this includes all financial and non-financial resources, international and domestic, available to support an individual’s research endeavors. 
  • Academic appointments conferred at another institution, international or domestic should be disclosed in the researcher's biographical sketch or CV submitted in the proposal package.  Significant changes should be disclosed at the time of award acceptance. 
  • Recently federal sponsors have become particularly concerned about participation in foreign talent programs. While participation in such programs is not illegal, it is a source of support that must be disclosed. Depending on the sponsor and proposed research, key personnel may be advised or required to terminate their affiliation with the foreign talent program in order to receive an award.
  • Other forms of foreign support, e.g., provision of laboratory facilities or support staff at foreign institutions as part of an affiliate or honorary appointment, are also being scrutinized and must be disclosed, typically as part of "Current & Pending Support."
  • See Agency Specific Requirements for more information.


Export Controls
  • Most of the research at W&M is considered fundamental research, where export laws do not apply. However, some items/technologies fall under the reach of these U.S. export control laws. Sponsored programs may have export restrictions on particular items, equipment, technology and data. Additionally, the research may have restrictions on the participation of foreign nationals and/or freedom to publish the results of the research.
  • Export control issues are treated on a case-by-case basis, and resolution of these issues is dependent on the specific facts of the case.  Questions regarding export controls at W&M should be addressed to the W&M Sponsored Programs OfficeVIMS Office of Sponsored Programs, or to the W&M Export Control Officer.
  • Additional information is available on the Export Controls Page of the Technology Transfer Office website.