Integrity & Responsible Conduct Policy

FOUNDATION FOR EDUCATIONAL EXCHANGE BETWEEN CANADA AND THE USA -  INTEGRITY & RESPONSIBLE CONDUCT POLICY

February 2026

1. Purpose

The Foundation is a treaty-based organization that administers the Fulbright Program in Canada and provides other binational academic exchange opportunities and related programming. The Foundation is supported by Global Affairs Canada, the United States Department of State, and numerous nongovernmental partners. The Foundation promotes academic excellence, ethical conduct, and mutual understanding through educational exchange. This policy sets out expectations for integrity and responsible conduct in all activities supported by Fulbright Canada, while respecting academic freedom and institutional autonomy.

2. Scope

This policy applies to:

• Fulbright Scholars, Students, Fellows, and Visiting Research Chairs,
• All Staff, including interns,
• Board members, and
• Anyone conducting research or program-related work funded or administered by Fulbright Canada.

“Research” is defined broadly to include scholarly, scientific, professional, artistic, and creative activity.

3. Governing Standards

Fulbright Canada operates within a binational framework. All participants are required to comply with:

1. The policies and procedures of their host institution (primary authority),
2. Applicable laws and policies in the host country,
3. Relevant policies of their home institution, where applicable, and
4. Applicable requirements of Global Affairs Canada and the U.S. Department of State.
   Where standards differ, participants are expected to adhere to the most rigorous applicable standard. Host institutions bear primary responsibility for research oversight, including ethics review (e.g., REB/IRB), research security, data protection, and misconduct investigations.

4. Principles of Responsible Conduct

Fulbright Canada expects the highest standards of integrity in:

• Applications and proposals,
• Research design and methodology,
• Data collection, analysis, and reporting,
• Publication and dissemination,
• Public representation of research findings, and
• Stewardship of funds.

Participants must:

4.1 Honesty and Accuracy

• Present information truthfully in applications, reports, publications, and public communications, and
• Avoid fabrication, falsification, or misrepresentation of data or credentials.

4.2 Proper Attribution

• Appropriately acknowledge the contributions of collaborators, students, and others,
• Respect intellectual property rights, and
• Use unpublished or confidential materials only with permission and proper citation.

4.3 Authorship and Contribution

• Ensure authorship reflects substantial scholarly contribution, and
• Avoid honorary or inappropriate authorship.

4.4 Confidentiality

• Protect confidential information obtained through peer review, grant applications, or institutional processes.

4.5 Conflict of Interest

• Disclose real, potential, or perceived conflicts of interest to host institutions and, where relevant, to Fulbright Canada, and
• Comply with institutional conflict-of-interest management requirements.

4.6 Compliance with Ethics and Legal Requirements

• Obtain required ethics approvals (e.g., REB/IRB), and
• Adhere to laws and policies relating to research involving human subjects, animals, controlled materials, cultural heritage, data protection, and research security.

4.7 Respectful Conduct

• Maintain professional conduct consistent with host institutional policies on harassment, discrimination, equity, and inclusion.

5. Definition of Misconduct

Consistent with Canadian Tri-Agency and U.S. federal standards, research misconduct includes:

• Fabrication,
• Falsification,
• Plagiarism,
• Misrepresentation in funding applications,
• Failure to disclose conflicts of interest,
• Serious breach of ethical or regulatory requirements, and
• Retaliation against individuals who raise concerns in good faith.

Honest error, differences in interpretation, or academic disagreement do not constitute misconduct.

6. Responsibility for Investigations

6.1 Institutional Jurisdiction

Unless otherwise agreed upon, Fulbright Canada recognizes that host institutions are the primary authorities responsible for:

• Receiving allegations,
• Conducting inquiries and investigations,
• Ensuring procedural fairness,
• Protecting confidentiality,
• Determining findings and sanctions, and
• Reporting outcomes to relevant authorities.

Fulbright Canada will defer to institutional processes wherever they exist.

6.2 Obligation to Inform Fulbright Canada

Participants must promptly inform Fulbright Canada if:

• A host or home institution initiates a formal investigation into misconduct,
• They are found to have committed research misconduct, or
• Their grant or appointment is suspended or terminated for integrity-related reasons.

Host institutions must also notify Fulbright Canada where required by their funding agreements or by legal requirement.

7. Foundation Response

Where an investigation confirms misconduct, Fulbright Canada may take appropriate action, including but not necessarily limited to the following:

• Suspension or termination of a grant or appointment,
• Requirement to repay funds where misuse is established,
• Ineligibility for future Fulbright programs, and
• Notification to relevant funding authorities (Global Affairs Canada or U.S. Department of State), as required.

Any action taken by the Foundation will be proportionate and consistent with the findings of the investigating institution.

8. Situations Without Institutional Affiliation

In rare cases where a participant is not affiliated with an institution capable of investigating, Fulbright Canada may:

• Appoint an independent reviewer or panel,
• Conduct its own internal investigation,
• Follow principles of procedural fairness,
• Provide written notice of allegations,
• Allow the respondent an opportunity to respond, and
• Base decisions on clear and convincing evidence.

The Foundation reserves the right to determine appropriate measures to protect the integrity of its programs, particularly the Fulbright brand.

9. Protection of Complainants and Respondents

Fulbright Canada expects that:

• Allegations made in good faith will not result in retaliation,
• The rights and reputations of all parties will be respected,
• Confidentiality will be maintained to the extent permitted by law, and
• Due process will be afforded in accordance with institutional and legal standards.

10. Academic Freedom

Nothing in this policy is intended in any way, shape, or form to restrict academic freedom or legitimate scholarly debate. The Foundation does not regulate research topics or comment on their findings,

provided they are pursued with integrity and in compliance with applicable laws and institutional standards.

11. Record Keeping and Reporting

Fulbright Canada will:

• Maintain appropriate records relating to integrity matters,
• Report confirmed cases of misconduct to funding authorities where required, and
• Cooperate with Canadian and U.S. governmental oversight requirements.

12. Policy Review

This policy will be reviewed at minimum every three years to ensure alignment with:

• Canadian Tri-Agency Responsible Conduct of Research standards,
• U.S. federal research integrity policies,
• Global Affairs Canada and U.S. Department of State requirements, and
• Fulbright Program policies.