Political Participation

Policy Statement

Adelphi University, as a tax-exempt organization under Section 501(c)(3) of the Internal Revenue Code, is prohibited from participating or intervening in any political campaign on behalf of or in opposition to any candidate for public office.

Reason for Policy

Members of the Adelphi community are encouraged to exercise their individual right to support a particular candidate or participate in political campaigns as long as they do so without overtly or implicitly involving the University. The University must not endorse or make financial contributions to political candidates or political campaigns. This policy encourages freedom of expression of ideas of the individuals of the community but must be in compliance with the Federal Laws and University Policies. This policy defines political intervention and outlines the University’s requirements when involved in partisan activities.

Who Is Governed by this Policy

Faculty, Staff and Students

Policy

Political campaign intervention includes not only making financial contributions but also the publication or distribution of written or oral statements on behalf of or in opposition to a particular candidate. There are no exceptions to this prohibition. Even an insubstantial violation may lead to monetary fines and exposes the University to the possibility of revocation of its tax-exempt status. Nonetheless, the University is dedicated to the free expression of ideas. It encourages students, faculty, and other employees, in their individual capacities, to participate fully in the political process during campaigns by candidates for public office as long as they do not-either overtly or implicitly-involve the University.

In order to permit the most robust political discourse during partisan political campaigns for public office, while at the same time ensuring Adelphi’s compliance with the restrictions placed on the University as a tax-exempt organization, the University issued a policy that prohibits all individuals and groups within the University community from using University resources or the University’s name in connection with partisan political campaign activities. Thus, in accordance with both the law and stated University policy, everyone connected with the University must observe the following rules with respect to his or her participation in national, state, or local partisan political campaign activities:

1. When endorsing or opposing a candidate for political office or taking a position on an issue for the purpose of assisting or opposing a candidate, individuals and groups within Adelphi University should undertake to make it clear that they are speaking only for themselves and that they are not stating a University position. This is particularly important for those who in their official capacity frequently speak for the University.
2. Faculty and other employees may take part in partisan political activities freely on their own time, but they must not do so at the expense of their regular responsibilities to the University and its students.
3. Adelphi University’s name or insignia cannot be used on stationery or other documents intended for political purposes, including soliciting funds for political support or carrying on a political campaign.
4. Funds or other contributions may not be solicited in the name of Adelphi University for political support or carrying on a political campaign.
5. Adelphi employees may not-and should not be asked to-perform tasks related to partisan political activities during working hours.
6. The following may not under any circumstances be used for political campaign purposes:
   1. The University’s bulk-mailing privilege;
   2. University mailing lists-including the addresses and e-mail addresses of departmental offices or the offices of faculty or other employees;
   3. University-provided office supplies, telephones, facsimile machines, copiers, etc.;
   4. The University’s sales tax exemption for purchases of goods and services.
7. Any communication disseminated through the Adelphi e-mail system that could be construed as relating to political activity must include a clear statement that such communication represents the personal position of the author.
8. University-related organizations composed solely of members of the corporate University community and its educational affiliates may utilize available University building space (University facilities regularly reserved for student use and other University space such as lecture halls and meeting rooms) to engage in partisan political campaign activities within the University community,* provided that such organizations (i) pay for the costs of such activities (typically, telephones, duplicating, electricity, etc.) and (ii) pay full rental fees for the use of such facilities that they would otherwise be charged. A disclaimer should be made at the beginning of any such event (and in any printed materials or advertising) that the University does not support or oppose candidates for political office, that the opinions expressed are not those of the University, and that the University-related organization has sponsored the event. All plans, publicity, and other information relating to such activities must be approved in advance by the appropriate student affairs office and Counsel. The University’s outdoor grounds may not be used for partisan political events.
9. Organizations that are composed of non-University members, participants or employees, in whole or in part, are ineligible for use of University space to engage in partisan political campaign activities.
10. Certain nonpartisan political activities (such as properly organized voter registration activities, voter education programs, and candidate debates) may be permissible if they do not evidence a preference for or opposition to a political party or to candidates who have taken a particular position. In order to ensure that all legal and University requirements are followed, advance approval for these events must be obtained from (and all materials must be reviewed by) both the appropriate student affairs office and University Counsel, which will, if necessary, provide further guidance to the organizer. In addition, an announcement should be made at the beginning of each such event and in any written materials setting forth the disclaimer.

As noted above, these policies are not intended to infringe in any way on individual right to support a particular candidate or participate in a political campaign’s. Individuals remain entirely free to become involved in the election process as you choose, so long as you do so in a way that does not either overtly or impliedly involve the University.

Definitions

Political Campaign Activity (Political Intervention): Directly or indirectly participating in, or intervening in, any political campaign on behalf of (or in opposition to) any candidate for public office. Political campaign activity may include, but is not limited to, making financial contributions to a campaign; soliciting campaign contributions, distributing information or creating web links that favor or oppose certain candidates; sponsoring events to promote certain candidates; disparate treatment of candidates invited to participate at a University event; and establishing political action committees.

Candidate: An individual who is a legally qualified candidate for public office, as defined in the Communications Act of 1934 (see Related Resources).

Partisan Political Activity: Any activity directed toward the success or failure of a partisan candidate, political party, or partisan political group.

Nonpartisan Political Activities: Any activity supporting or relating to candidates not representing, or issues not specifically identified with, national or State political parties and associated or ancillary organizations. Issues relating to constitutional amendments, referendums, approval of municipal ordinances, and others of similar character are not considered as specifically being identified with national or State political parties. (DOD)

Internal Revenue Code: Under the Internal Revenue Code, all section 501(c)(3) organizations are absolutely prohibited from directly or indirectly participating in or intervening in, any political campaign on behalf of (or in opposition of) any candidate for elective public office. The prohibition applies to all campaigns including campaigns at the federal, state and local level. (IRS Fact Sheet 2006-17, February 2006 – see Related Resources).

Forms

This policy does not have forms associated with it at this time. Upon periodic policy review this area will be evaluated to determine if additional information is needed to supplement the policy.

Related Information

Code of Ethics

Code of Conduct

Logo Usage Policy

IRS Fact Sheet – February 2006 – Prohibition on Political Campaign Intervention for Section 501 (c)(3) Organizations

Communications Act of 1934 – Definition of Candidate

Document History

• Last Reviewed Date: January 30, 2018
• Last Revised Date: December 2017
• Policy Origination Date: 2009

Who Approved This Policy

Assistant Vice President of Student Affairs and Dean of Students