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Established: September, 2012
Date Last Revised: August 2024
Posted: August 2024
Approved by: Senior Team
Responsible Office: President's Office
Responsible Senior Staff Member: President, Provost and Dean of Faculty, Vice President of Student Life and Dean of Students, Vice President for Finance and Administration and Vice President of College Relations

Scope / Responsibilities

All ������Ƶcommunity members - students, faculty and staff - must comply with the policy on activities related to political campaigns.

• Questions on whether planned activities are consistent with the College's obligations should be addressed to the Provost and Dean of Faculty, the Vice President for Student Life and Dean of Students, and the Vice President for Finance and Administration.
• The above individuals and their designees will interpret and apply these policies and guidelines and may consult with the President, Vice President for College Relations, and/or legal counsel as needed.
• Students, groups of students, and recognized student organizations planning activities related to political campaigns should discuss their plans with the Vice President for Student Life and Dean of Students or their designee. Faculty should discuss with the Provost and Dean of Faculty or their designee. All other employees should discuss with the Vice President for Finance and Administration or their designee.

Policy

Introduction

������ƵCollege is a charitable, tax-exempt entity subject to federal, state and local laws and regulations regarding activities related to political campaigns. By law, “Organizations that are exempt from income tax under section 501(a) of the Internal Revenue Code as organizations described in section 501(c)(3) may not participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of (or in opposition to) any candidate for public office.” (Rev. Rul. 2007-41, 2007-25 I.R.B. June 18, 2007)

Policy Statement

This policy statement, which addresses campaigns for political office and related activities, articulates ways in which the ������ƵCollege community can avoid having their personal opinions appear to be those of the College as an entity. The following specific guidelines are intended to aid all ������ƵCollege community members in acting consistently with the legal requirements placed on the College.

The prohibitions on participating or intervening in a political campaign, including the use of College resources, apply only to the College and its representatives or agents authorized to speak or act on the College’s behalf. Those prohibitions do not apply to ������Ƶstudents, employees, or others when they are speaking or acting in their individual capacities or as the members of associations other than the College. Individuals taking political positions for themselves or groups with which they are associated should clearly indicate, by words and actions, that their positions are not those of the College and are not being taken in an official capacity on the College’s behalf (specific disclaimer language can be found in the policy’s guidelines).

There is no restriction on discussion of political issues or teaching of politics, campaign-related topics or the electoral process. Specific campaign-related statements, such as endorsement of a particular candidate, should not be made in the classroom. Non-partisan voter registration efforts are encouraged as well as the conduction of public opinion polls and debates where all sides and positions are represented.

In addition, all members of the ������ƵCollege community are free to express their individual political opinions and engage in political activities. Students, employees and others may support candidates for office or speak in furtherance of political causes, both on campus and elsewhere, subject to the limitations outlined below. In doing so, it is important that members of the ������Ƶcommunity speak only in their individual capacities and that they avoid even the appearance that they are speaking or acting for the College in political matters.

Procedures

Distribution of Policy

All students receive a copy of this policy electronically from the Vice President for Student Life and Dean of Students' office or designee, via the Student Handbook notification. All recognized student organizations receive a copy of this policy electronically from the office of student involvement, via email.

All employees receive a copy of this policy electronically from the College via email at the start of each academic year.

Reporting

Questions on whether planned activities are consistent with the College's obligations to this policy should be addressed to the Vice President for Student Life and Dean of Students for students, groups of students, and recognized student organizations; to the Provost and Dean of Faculty for faculty; and to the Vice President for Finance and Administration for all staff. Those individuals and their designees will interpret and apply these policies and guidelines in consultation.

Policy Violations (if applicable)

Violations of this policy will be taken seriously, as they could jeopardize the College’s tax-exempt standing. Outcomes of any confirmed violations can include, but are not limited to:

• The loss of the ability for an individual or group to use campus space or other College resources for an extended period of time.
• Student disciplinary action taken by the Vice President for Student Life and Dean of Students office or designee with a record kept on file.
• Employee disciplinary action taken by the Provost and Dean of Faculty or designee (for faculty) and supervisors (for staff), in consultation with Human Resources, with a record kept on file.

Guidelines

Activities Requiring the Use of Facilities or Open Areas on Campus

Members of the ������ƵCollege community may not:

• Hold fundraisers for political candidates or for Political Action Committees (PACs) on College-owned and managed property.
• Post or distribute information about political activities and campaigns in ways that violate the College’s posting policy or vending and solicitation policy.
• Provide a candidate for public office an opportunity to speak on campus or use College-owned facilities unless authorized by the Events Oversight Committee (see below for exceptions for registered student organizations). In most cases, all legally-qualified candidates (at least) for that office must be offered equal access and opportunity to speak on that or a separate occasion.
• Allow a candidate or political party to conduct a rally or other political event on college-owned and managed property unless authorized by the Events Oversight Committee. This includes campaign-related press conferences.
• Post signs or other campaign-related materials on the grounds or external facings of College-owned and managed property, except as permitted in the College’s posting policy. Such materials also may not be posted by anyone in windows, in common spaces of the workplace, as a Zoom background, etc.
• Students living in residential buildings may post such materials in their personal rooms as long as residence halls policies are followed. Students should refer to the Student Handbook for additional information about what is and is not allowed in rooms and or posted on windows inside or outside.

Political Activity and Recognized Student Organizations

Student organizations, including political organizations, officially recognized by the College via the Office of Student Involvement may invite candidates or campaign representatives of their choosing to speak on campus.

• In most cases, all legally-qualified candidates (at least) for that office must be offered equal access and opportunity to speak on that or a separate occasion.
• The date, length, and format of the program and all other aspects of the program should be determined solely by the officially recognized student organization, with no involvement by ������ƵCollege, except that any generally applicable to all events sponsored by officially recognized student organizations would apply. These include the College’s ability to place restrictions on time, place, and manner. Fundraising at such events is prohibited.
• The officially recognized student organization and its planners must state expressly, in writing and orally before an event, that they are not speaking or acting on behalf of the College and that the positions expressed are solely their own and do not reflect the positions of the College or its trustees. If a specific candidate is referenced, then the disclaimer should state expressly that ������Ƶdoes not support or oppose the candidate and takes no position on the candidacy.
• All posters, social media, emails, and websites advertising any such event should include the disclaimer: “This student group is not speaking or acting on behalf of the College and the positions expressed at this event or program will be solely our own and do not reflect the positions of ������ƵCollege or its trustees."
• The ������ƵCollege seal, logo or other brand assets may not be used in any promotional materials, electronic advertising and/or social media advertising the event.
• Finally, facilities must be available to any officially recognized student organization on an equal basis.

Note, any group of individual students that are not an officially recognized student organization and wish to endorse and/or campaign for a specific candidate on campus may do so as long as they follow the guidelines laid out in this policy and in the . Only recognized student organizations are approved to host events on-campus. Particular items that apply:

• When utilizing common spaces in the residence halls, all students must follow the common space policy and procedure.
• Distribution of information about political activities and campaigns by the ������Ƶcommunity must conform to the College’s posting policy.
• On any media (social media, physical materials, etc.) it must be clear that said group is student driven and not endorsed by the College nor is it representing the opinions of the College. The College name may not be used. It must be stated expressly, in writing, that they are not speaking or acting on behalf of the College and that the positions expressed are solely their own and do not reflect the positions of the College or its trustees. If a specific candidate is referenced, then the disclaimer should state expressly that ������Ƶdoes not support or oppose the candidate and takes no position on the candidacy.

Political Activity and Student Publications

Student publications may run editorials expressing the editor’s views on candidates for public office, provided that the publication’s editorial policy is free of editorial control by ������Ƶadministrators or faculty advisors. A statement on the editorial page must indicate that they are not speaking or acting on behalf of the College and that the positions expressed are solely their own and do not reflect the positions of the College or its trustees. If a specific candidate is referenced, then the disclaimer should state expressly that ������Ƶdoes not support or oppose the candidate and takes no position on the candidacy.

Use of the ������ƵName and the Seal

The College’s name, logo, seal (including College or departmental letterhead) may NOT be used on letters or other materials intended for political campaigns or partisan political purposes.

Use of ������ƵResources

Members of the ������ƵCollege community may not use College resources to support candidate endorsements or other similarly-focused political activities. Resources include, but are not limited to:

• Mount Holyoke’s website, social media platforms, or other electronic spaces hosted or maintained by the College.
• College email accounts.
• College electronic services accessed with an MHC login including Zoom and Google G-Suite for Education tools (Gmail, Drive, Calendar, etc.).
• College services, such as interdepartmental mail, e-mail lists and listservs, mailing lists, campus listservs and Google Groups, equipment such as computers, printers, photocopiers, multifunction devices (MFDs) or supplies.
• College-owned telephones.
• Individuals may not request that a College employee, as part of their job, perform tasks in any way related to partisan political purposes.

Lobbying

Distinct from political campaign activities, lobbying consists of activities designed to influence decisions of legislators for or against a particular issue.

The College may at times choose to lobby on a particular issue or topic, in alignment with the College’s mission and values. In these instances, lobbying cannot and will not be conducted on behalf of the College unless authorized by the President or their designee and in consultation with legal counsel.

In accordance, members of the ������ƵCollege community may not:

• Lobby or attempt to influence federal, state, or local legislative action or a legislative or administrative official or staff member on behalf of the College unless authorized by the President or their designee. Any lobbying activity, even when authorized, must be conducted in compliance with applicable law.
• Use federal funds, including contract or grant money, received by the College for lobbying activities.

Note, however, that individuals may individually attempt to influence the legislative process and use their College title for identification so long as such actions or writings are accompanied by a statement that the person is speaking as an individual and not as a representative of the College (e.g., “The positions expressed in this letter are those of the individual(s) signing below and not an official position of ������ƵCollege or its trustees.”). If a specific candidate is referenced, then the disclaimer should state expressly that ������Ƶdoes not support or oppose the candidate and takes no position on the candidacy.

Employee Campaign Participation

Employee participation in campaigns of candidates for public office is permitted when it is outside normal work hours, during work hours but allocated to leave or other non-work time, does not involve College funds or other resources and includes an express disclaimer (see disclaimer above under lobbying).

Related Policies

• Events Management Policy
  The Events Management Policy has been established in order to be sure that events held on campus are properly vetted, approved and resourced (financial and staff) appropriately.
• Manual for the use of campus spaces
  The provides detailed policies and procedures for use of space at ������ƵCollege.
• Media Access Policy
• 
  Includes policies and procedures as they apply to recognized student organizations, including the student event policy and procedures.
• 
  This policy applies to all ������Ƶstudent sponsored events and programs, including those held by recognized student groups, that occur on-campus.

Other Resources

• Student Handbook