I. General Policy

Rice University is an international university, with faculty, staff and students from around the world and actively participating in study abroad offerings, international research and collaborations. It is university policy that all Rice related international travel must be registered, and must be carried out safely to protect the health, safety, security and well-being of the Rice community.

This policy applies to all faculty, staff, students, and visitors who are traveling outside of the United States and whose travel is:

1. funded in part or in full by university funds (including research funds);
2. a component of Rice curriculum or earning academic credit toward a Rice degree;
3. part of a university sponsored team, group, club, or organization; or
4. representing the university or is otherwise on behalf of the university.

II. Roles and Responsibilities

The International Operations Committee (IOC) is charged with providing general administrative oversight and support of the University’s international activities. The committee is convened by the Vice President for Digital and Global Strategy and the Vice President for International Operations and Information Technology, and the committee should have representation from administrative and academic units supporting global programs. The IOC determines the criteria for a country or region to be classified as an Elevated Risk for travel, and may prohibit travel to certain countries or regions where the risk cannot be mitigated.

The Crisis Management Team (CMT) is responsible for monitoring relevant international health and safety information, and advising the university on which countries or regions are at an elevated risk or should be prohibited from travel to or from.

The Office of Research Compliance is responsible for overseeing compliance with Export Control requirements, and regulations/policy pertaining to research conducted, utilized, or supported internationally.

The Information Security Office (ISO) has responsibility for data protection. The Campus Information Security Officer (CISO) is the GDPR Data Protection Officer and the HIPAA Security Officer.

Risk Management is responsible for managing a program to assist those on international travel with unexpected health, medical, or security assistance. Currently the provider of these services is International SOS. Generally, registration with International SOS is sufficient to meet the “insurance” requirements of this policy.

III. Elaboration of Policy

The university maintains an international travel registration page at https://travelregistry.rice.edu/. Registration is required for all international travel covered by this policy. The registration process is designed to identify countries that are at an Elevated Risk (which may have additional requirements, as described below). Additionally, Rice international insurance or International SOS is required for all student travel, and for faculty and staff travel to countries at an Elevated Risk due to health and safety concerns (see table below).

A. Travel to Countries with an Elevated Risk

Elevated Risk Countries are countries, or regions within a country, where the University has determined there is an elevated risk to health, safety, or corruption. Generally, status as an Elevated Risk Country is based on:

• advisories from the US State Department (at level 3 or 4 a country/region is presumed to be Elevated Risk);
• country specific warnings from the Center for Disease Control or the World Health Organization;
• corruption rankings by Transparency International, or
• if the country is subject to a US sanction or embargo.

Rice University will not pay for or reimburse travel to a country with an elevated risk unless the appropriate procedures (as outlined below and in the chart) have been followed. Additionally, where the Elevated Risk cannot be appropriately mitigated, a country may be designated as “prohibited” for university-funded or reimbursed travel. If travel costs for Rice business purposes have been incurred in advance of a university or government decision to prohibit travel, such costs will be eligible for reimbursement.

a. Elevated Risk - Health and Safety

Rice University will designate a country or region as an Elevated Risk for Health and Safety based on current warnings about travel to that country issued by the US State Department (at level 3 or 4 a country/region is presumed to be Elevated Risk) or a country specific warning from the Center for Disease Control or the World Health Organization. If a country or region is at an Elevated Risk for Health and Safety, then registration and insurance will be required, and the individuals traveling may be required to review information about the nature of the risk and sign an informed consent and release to travel to that country.

In the case of graduate students, travel to such countries is allowed but generally discouraged and must be approved by the Dean of Graduate Students and Postdoctoral Studies. In the case of undergraduate students, travel to such countries is generally prohibited, and must be approved by the Dean of Undergraduates. Approval for student international travel to countries that are at an elevated risk for health and safety may be given when there are compelling circumstances, or unique facts, that justify the need to take such travel (for example, if a student is from that country).

b. Elevated Risk - Corruption

Rice University uses Transparency International’s Corruption Perceptions Index (available at https://www.transparency.org/), which ranks 180 countries based on their perceived level of corruption. When a country’s score is 60 or below, that country will be designated as Elevated Risk for Corruption.

There are no restrictions or prohibitions on travel to these countries, but travel must be registered and all individuals will be provided with a copy of Rice Policy on Anti-corruption [under development] in advance of travel. Faculty and staff, who travel to these countries must, at least once per year, provide a certificate that they complied with the Anti-corruption policy.

Summary of International Travel Requirements

Failure to follow relevant international travel requirements may result in all expenses being deemed ineligible for reimbursement by Rice University, and could result in additional disciplinary actions.

c. Elevated Risk - Embargos and Sanctions

When a country is listed on one of the sanctions lists maintained by the US Department of Treasury’s Office of Foreign Assets Control (OFAC), that country will be designated as Elevated Risk – Sanctions. This designation generally means that travel is prohibited under US law, but there may be circumstances that allow for certain travel or activities (such as the individual is a citizen of that country, or certain humanitarian missions). Travel to such countries must be registered, at which point the Office of Research Compliance will be notified electronically of export control risk, and will contact the individual prior to travel.

Travel to countries designated as Elevated Risk – Sanctions is prohibited, unless it has been reviewed by The Office of Research Compliance, and approved by the appropriate Dean or Vice President.

2. Fly America Act

If some portion of international travel will be funded by the federal government, then individuals must be aware of and adhere to the Fly America Act, a federal regulation that requires the use of U.S. carriers (or US carriers with a code sharing arrangement with a foreign carrier) for travel that will be reimbursed from federal grants and contracts. Currently, there are international treaties that allow for use of carriers from the European Union, Australia, Switzerland, and Japan.

3. Export Controls

Rice University faculty, staff, and students should be aware of potential export restrictions when they travel to a foreign country. Export control regulations are very complex and often involve special rules being applied to certain items or technology (including laptop computers or other devices).

Any individuals who are traveling with controlled items or information must contact the Office of Research Compliance (See https://compliance.rice.edu/export-control).

IV. Cross References to Related Policies

Rice Policy 105, Emergency Management

Rice Policy 806, Travel, Business Meeting, and Entertainment Policy

Rice Policy __TBD__, Anticorruption (IN DEVELOPMENT)

Data Policy 808, Protection of University Data and Information

V. Responsible Official and Key Offices to Contact Regarding the Policy and its Implementation

Responsible Official: Vice President for International Operations and Information Technology

Other Key Offices: Vice President for Global and Digital Strategy , Study Abroad Office, Risk Management, Sponsored Contracts and Research Compliance, Office of International Students and Scholars, Crisis Management and Finance

VI. Procedures and Forms

Please see https://global.rice.edu/ for additional information and resources. For information on international travel services and insurance, please see https://riskmanagement.rice.edu/traveling-abroad-intl-sos

Signatures

David W. Leebron, President

Policy History

Issued

September 17, 2020