Guide for Responsible International Activities

"Georgia Tech's Progress and Service motto reflects our drive to use our technological expertise to improve the human condition, not only in Georgia and in the United States, but also across the globe. In addition to broad and robust technological training, we will instill values that prepare our students to become tomorrow’s leaders — with the conviction, social courage, and intercultural sensitivity to collaborate across geopolitical, cultural, and linguistic boundaries as they design solutions for the challenges of the 21st century."

- Global Positioning Strategy
  Georgia Tech Office of International Initiatives

Global Positioning Strategy

As one of the leading research universities in the United States and the world, Georgia Tech has a proud history of engaging with like-minded institutions and scholars around the globe to advance our education mission and produce technological solutions that improve the human condition at home and internationally. As outlined in the Institute’s Global Positioning Strategy, global engagement allows us to tap the contributions of some of the world’s brightest minds in our research and helps us prepare our students to effectively collaborate across geopolitical and cultural boundaries.

As we continue to develop and strengthen valuable global partnerships, it is important that we recognize some of the inherent risks involved and be prepared to address them. Georgia Tech has, therefore, developed a set of guidelines, policies, and procedures to help us make decisions and build relationships that will create value while mitigating risk. With proper planning and compliance with these procedures, Georgia Tech’s global relationships will be more likely to deliver important results without jeopardizing safety or violating our commitments to sponsors, state policy, and federal and other applicable regulations — at home and abroad. 

Basic Guidance and Policy Reminders

Lawful and Responsible Conduct


Export Control

Federal export control laws govern how we transfer or transmit certain technology, materials, data, and information to anyone overseas and to foreign nationals on U.S. soil. With almost constantly changing international political, military, and economic environments, the rules are complicated. The export control regulations govern how information, technologies, and commodities can be transmitted overseas to anyone, including U.S. citizens, or to foreign nationals in the United States.

These issues can affect all university offices, and compliance generally rests with the individual. Within the Office of Research Integrity Assurance, our Export Control team is in place to help you recognize and navigate these complex situations.

Contact: 
Mary Beran, Director
Office of Research Integrity Assurance
404-385-2083
 
Office of Research Integrity Assurance - Export Control 

 

Managing Conflicts of Interest

Within the Office of Research Integrity Assurance, and in conjunction with the faculty-led COI Review Committee, the Conflict of Interest Management team is charged with promoting objectivity throughout the Institute’s Research enterprise by effectively managing conflicts of interest, which are a natural outgrowth of successful research, collaboration, and commercialization efforts. 

Potential types of disclosures might include research support or gifts from foreign sources, appointments at other institutions, and participation in talent programs.

Visit the Office of Research Integrity Assurance’s website to access the online disclosure tool (eCOI), schedule training, or review regulations and policies around startup activities and consulting activities, etc. 

Contact: 
Jeff Steltzer, Director
Conflict of Interest Management Office
404-894-6925
 
Office of Research Integrity Assurance - Conflict of Interest Management Office

 

Appointments at Other Institutions

Georgia Tech's Conflict of Interest and Outside Professional Activity policy addresses consulting, dual employment, and moonlighting, and applies to all compensated Institute employees, which may include Emeritus or retired-but-working faculty, visiting faculty and scientists, paid affiliates, and Tech Temps.

All faculty and staff must disclose any potential conflicts of interest and/or outside professional activity each year and are responsible for updating any changes to their situation throughout the year. 

Contact: 
Jeff Steltzer, Director
Conflict of Interest Management Office
404-894-6925
Read Policy 5.6 - Conflict of Interest and Outside Professional Activity Policy

Offfice of the Provost Memo - COI, Consulting, Absence, Dual Employment, and Export Control - April 4, 2018

 

Intellectual Property

Georgia Tech wants to ensure that intellectual property is protected and, when required, reported to sponsors appropriately. Therefore, promptly disclose any potential inventions or other intellectual property to the Georgia Tech's Office of Technology Licensing.

Disclose any partnerships, investments, or sublicenses made with foreign entities to the Georgia Tech Office of Technology Licensing if your startup is based on licensed technology from Georgia Tech.

Contact: 
Terry Bray, Director
Office of Technology Licensing
404-894-6940

Mark Coburn, Senior Associate Director
Office of Industry Engagement
404-894-6940
 
Office of Industry Engagement

 

Materials, Data, and Confidential Information

When sharing data or materials with other collaborators/other institutions, foreign or otherwise, one of the following agreements should be in place: a material transfer agreement (MTA) a data use agreement (DUA) or a nondisclosure agreement (NDA).

Further, accepting or sharing any sensitive or controlled information under a research contract may require heightened cybersecurity requirements. Having such an agreement in place also allows Georgia Tech to complete all required reviews and approvals. The Exchange Agreements team within the Office of Industry Engagement provides guidance on these type of agreements.

Please remember that only those institutional officials with appropriate signature authority can sign such agreements.

International Shipping Checklist

Material Transfer Agreements

Nondisclosure Agreements

Contact: 
Kendall Thompson, Associate Director
Office of Industry Engagement
404-894-6940

 

Foreign Corrupt Practices Act (FCPA)

It is the policy of Georgia Tech that each of our employees, faculty members, staff members, agents, representatives, vendors, and other third parties that work with Georgia Tech, Georgia Tech Research Corporation (GTRC), and Georgia Tech Applied Research Corporation (GTARC) comply with the anti-bribery laws of the United States and of the foreign countries where Georgia Tech does business.

Bribery of any kind in the United States and abroad, regardless of foreign custom or practice, is strictly prohibited. No Georgia Tech employee, faculty members, staff members, agent, representative, vendor or any other third party with which Georgia Tech works shall make any payment or provide anything of value to any person, in order to improperly influence that person to secure any advantage for Georgia Tech, including obtaining or retaining business, or directing business to any person or entity.
 

 

Read Research Policy 8.2.2 — Foreign Corrupt Practices Act (FCPA)

Sponsored Research

International Agreements (sponsored research, master research agreements)

Sponsored research agreements with any foreign entity are executed by the Office of Industry Engagement, regardless of where the work is to be performed.

The Office of Industry Engagement contracting officers and personnel work closely with the Office of Research Integrity Assurance to ensure compliance with export control regulations. 

Questions regarding international research contracting may be sent to industryengagement@gtrc.gatech.edu.

Office of Industry Engagement - International Research

 

 

Disclosing Foreign Relationships (including sponsored funding, gifts, talent programs, and appointments)

Georgia Tech is committed to the lawful conduct of research and is further committed to disclosing all forms of other support and financial interests, including support coming from foreign governments or other foreign entities.

This commitment is in accordance with guidance from the National Institutes of Health (NIH) including:

Georgia Tech researchers are strongly encouraged to leverage the deep expertise available via the applicable compliance offices to ensure that all disclosure procedures are followed. There are dedicated support teams available to assist with outgoing proposal review, incoming awards compliance, conflict of interest management, export control, and intellectual property. 

Office of Research Integrity Assurance - Conflict of Interest Management Office

Office of Research Integrity Assurance - Export Control 

Office of Industry Engagement

Foreign Nationals on Campus

Lab Tours 

Georgia Tech is pleased to showcase our buildings and facilities. However, prior to hosting guests and visitors in our research facilities or labs, hosts should be aware of the following best practices:

Prior to the tour visit:

  • Conduct restricted party screening. The Office of Legal Affairs can assist in this process.

During the tour/visit:

  • Safeguard all confidential/proprietary information and ensure that it is not visible during the tour.
  • Accompany visitors throughout the duration of the tour.
  • Do not allow photography or video of lab equipment or lab set up, unless it has been pre-approved by the Office of Legal Affairs. This includes individual guests or groups, as well as any filming and photography requests from external production companies.
  • Prohibit visitors from inserting flash drives or any other media into Georgia Tech-owned computers or equipment.


Contact:
Pamela Rary, Managing Attorney
Office of Legal Affairs
404-894-4812

 

 

Hosting Foreign Visitors (including scholars, researchers, and collaborators)

The Office of International Education (OIE) administers the J Exchange Visitor Program at Georgia Tech. OIE also supports Georgia Tech students who enroll full-time in a degree program using the F student visa type.

Please contact jscholars@oie.gatech.edu if you have questions regarding Georgia Tech’s J Exchange Visitor Program.

Global Human Resources (HR) supports immigration services for nonimmigrant or immigrant employment sponsorship and individuals with work authorization based on their visa status (including employees in F-1 status with OPT or CPT, J-2s with employment authorization, etc). 

Additionally, Global HR provides assistance to departments that are hosting foreign national visitors (generally in B-1 or VWB status). For additional information, visit the Global HR website or email immigration@ohr.gatech.edu.

All requests to host international scholars at Georgia Tech based upon a J-1, H-1B, B, F/OPT, or O visa must be reviewed for export concerns by the Office of Legal Affairs. To initiate an export review, please return the following documents to the Office of Legal Affairs at asklegal@gatech.edu.

The Office of Legal Affairs will contact you for the following regarding your request:

 

Contact: 
Mary Beran, Director 
Office of Research Integrity Assurance
404-385-2083

Pamela Rary, Managing Attorney
Office of Legal Affairs
404-894-4812
 

Office of Research Integrity Assurance - Hosting Foreign Visitors

 

Travel and Logistics

International Travel 

When traveling outside the United States, everything you take with you is considered an “export,” under U.S. export control regulations. Some of these exports will require an export license from the United States government. Export licenses may be required because:

  • i) there are restrictions on taking the item or data to your destination, and/or
  • (ii) the item or data that you take or the activity that you will perform at your destination is controlled. 

Even if the destination, the item, or data, or your activity may be controlled, a license exception may be available so that we do not need to seek a license. Each export should be evaluated to see what the concerns are, if any, and how best to proceed.

Additional guidance related to international travel is available in the Institute Travel Authorization Procedures as well as in the Office of Research Integrity and Assurance.

Please note that all travel must be authorized via an Institute Travel Authorization request. Those requests should be completed no less than 30 days prior to all international travel. If your destination is subject to U.S. embargoes, if you are taking equipment, or if information or materials are export controlled, then the travel authorization request will be reviewed by the Office of Legal Affairs for export concerns. The Office of Legal Affairs will contact you to discuss if a license is required and provide guidance on export compliance for your travel.  

Because you, as an individual, and Georgia Tech can be held liable for improperly transferring controlled technology, it is important that you review federal regulations. 

Possible export control concerns are highlighted in the international section and routed to asklegal@gatech.edu for further review as necessary.
 

Office of Research Integrity Assurance — International Travel

Additional Resources