Due diligence

EPFL is home to students, professors and staff from over 130 different countries. And one of our core missions – research – is eminently international. This rich diversity and global reach are key values for us at EPFL and one of our main strengths, but they also come with responsibilities.

We need to protect our employees from the risks and consequences of a violation of international sanctions (due diligence) and from any improper use of our resources and the knowledge produced by our researchers. We also need to ensure that our activities comply with Switzerland’s export laws.

The failure to comply with these laws, and with international sanctions, could have major legal ramifications for our School and for the individual behind the proscribed act. By ensuring compliance across our organization, we also protect our professors and other employees, in line with our duties as an employer.

To that end, we will take all measures that experience has shown are necessary, that are realistic and appropriate for the given circumstances, and that can be reasonably expected of our School.

For more information, see Article 328 of the Swiss Code of Obligations.

As a Swiss university, EPFL is subject to compliance requirements in the area of exports as set out in laws on the export of goods and on the implementation of international sanctions (or embargos). These laws govern the cross-border trade of dual-use goods (goods with both a civil and military use) and war materiel.  

“Goods” in the legal sense refers to any product, technology (including information and knowledge), software or technical support that could be used to develop or manufacture weapons or weapons delivery systems.

Switzerland’s Goods Control Act and Embargo Act form the legal basis for export controls. The restrictions cover physical goods as well as intangible items.

Violations of these laws could result in penalties for EPFL or for the individual responsible for the export transaction causing the violation could be prosecuted.

To avoid such situations, we have set up a reliable internal control system that is currently managed by our Technology Transfer Office, Research Office and Legal Affairs Department.

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We’re in the process of rolling out our Defense in Depth initiative, which is designed to improve cybersecurity in general for our entire community.

We have introduced procedures for assessing potential reputational, financial and operational risks associated with our philanthropic partners.

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IT security is particularly important when we travel. Our School carries out a number of awareness campaigns to inform our community of these risks, such as by briefing employees before they take a business trip to an at-risk country.

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We have developed a special procedure for foreign applicants to our Master’s and PhD programs. Their applications are reviewed carefully according to several criteria, none of which taken alone could exclude an applicant.

These criteria include the quality of their application, their educational background and research references, their area of specialization, as well as factors related to compliance with the export-control and embargo legislation. We take into account the international sanctions issued by Switzerland, the United Nations, the European Union, the United Kingdom and the United States.

Our admissions procedure for visiting students and researchers applies to individuals who will spend more than eight days at EPFL or who will be using our research facilities. The dean’s approval is required for any students, researchers or professors who are affiliated with an institution in a country that does not participate in any of the four export control regimes in question and who conduct research on sensitive subjects. The dean may delegate this decision to the provost.

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