In other words, “the Institutional Voice Principles encourage restraint by all holding administrative or academic leadership positions” (emphasis added). As such, the Institutional Voice Principles encourage particular restraint by those holding such administrative or academic leadership positions. Nothing in the institutional voice principles constrains their academic freedom to do so. What actions constitute statements under the institutional voice principles. Certain actions by University leaders are “necessarily and inherently expressive”: flying a flag, making a salute, signing a petition.