The University of Iowa is committed to promoting academic excellence, fostering global collaboration, and ensuring the integrity of research endeavors. In pursuit of these objectives, the University of Iowa recognizes the significance of engaging with Foreign Talent Recruitment Programs (FTRP). Additionally, it is essential to uphold ethical standards and mitigate potential risks with such programs, and to remain compliant with all relevant federal regulations.

This policy establishes guidelines for University of Iowa faculty, staff, postdoctoral fellows, and students participating in FTRPs and safeguarding against involvement in activities associated with Malign Foreign Talent Recruitment Programs (MFTRP) that could compromise research integrity, national security, and/or the University of Iowa’s reputation.

• Foreign Talent Recruitment Programs (FTRP): any program, position, or activity that provides incentives such as cash, research funds, travel, honorific titles or career advancement opportunities, directly from a foreign country or entity to an individual.
• Malign Foreign Talent Recruitment Program (MFTRP)¹: any program or activity where a foreign country or its affiliates offer incentives such as cash, research funds, travel, job opportunities, or other benefits to an individual in exchange for:
  • Sharing with that foreign country confidential or proprietary information, trade secrets, intellectual property, or critical technology belonging to the University of Iowa or developed using federal funds 
  • Recruiting others to join similar programs
  • Taking a job or establishing research facilities in that foreign country in violation of U.S. government funding rules
  • An indefinite or long-term agreement to provide services to the foreign country or entity without the option of voluntary termination
  • Being limited in fulfilling U.S. government-funded research
  • Requiring application for funding from the foreign government
  • Being required not to give appropriate attribution to the University of Iowa and/or federal funding agencies in published work
  • Keeping their participation secret from their U.S. employer and/or government funder
  • Having conflicts of interest or commitment contrary to University of Iowa policies and/or federal funding agency requirements

MFTRPs include foreign talent recruitment programs sponsored by a foreign country or entity of concern (e.g., China, North Korea, Russia, Iran, certain foreign academic institutions, or listed foreign talent recruitment programs).  The full regulatory definition for MFTRP can be found on the University of Iowa Research Security website.

This policy shall apply to all University of Iowa faculty, staff, postdoctoral fellows, students, and any other individuals who contribute in a substantive, meaningful way to the scientific development or execution of research at the University of Iowa.

The Office of the Vice President for Research shall have oversight of this policy.

Participation in foreign talent recruitment programs must align with the University of Iowa’s objectives of integrity, transparency, and academic freedom. Researchers must ensure that their involvement does not compromise the principles of fair competition, protection of intellectual property rights, or ethical conduct.

The University of Iowa and federal funding agencies strictly prohibit researchers from engaging in any activities associated with MFTRPs. This applies to any FTRP, regardless of country of origin, if they are engaging in the attributes that define MFTRPs.

All faculty, staff, postdoctoral fellows, and students engaged in FTRPs must adhere to applicable laws, regulations, and University of Iowa policies. This includes requirements to disclose conflicts of interest and conflicts of commitment to the University of Iowa related to their participation in such programs (see UI Policy Manual – Conflicts of Commitment and Interest Policy for more information on University of Iowa disclosure requirements). Additionally, federal funding agencies require disclosure of engagement in FTRPs and other forms of support. Contact the Division of Sponsored Programs with questions related to funding agency disclosure requirements.

Prior to participating in any FTRP, researchers are required to conduct thorough due diligence and risk assessment to evaluate the legitimacy and integrity of the program.  Researchers should consult with relevant University of Iowa offices (e.g., Research Integrity and Security Office, Division of Sponsored Programs, Export Controls Management Program, Conflict of Interest in Research Office, etc.) as necessary.

Researchers have an obligation to promptly report any suspicions or evidence of malign activities associated with FTRPs, regardless of foreign country identity, to either the University of Iowa’s Research Security Officer or the Vice President for Research.  Failure to report such malign activities may result in disciplinary action, up to and including termination.

Activities that involve international engagement and collaboration that do not meet the definition of an FTRP may include: 

• Presenting or publishing scholarly materials and scientific information that would not fall under controlled or classified designations per current laws
• Attending international conferences
• Research projects or programs that involve open and reciprocal exchange of scientific information
• Advising a foreign student enrolled at an institution of higher education
• Participation in activities partly or otherwise funded by the United States (e.g., government appointee to the board of a joint scientific fund)
• Participation in a Fulbright Commission program
• Involvement in national or international academies or professional societies
• Taking developmental leaves, serving as a visiting scholar, or engaging in continuing education activities provided doing so doesn’t conflict with the interests of a federal research agency
• Receiving awards for research and development which serve to enhance the prestige of the federal research agency (e.g., the Nobel Prize)