Research partner due diligence policy
Updated on 22 January 2021
The University is engaged in collaborative research with partners in the UK and overseas. Collaborative research has the potential to enhance the quality and reach of research conducted at the University, and is at the heart of our strategy to transform lives locally and globally through the creation, application and sharing of knowledge.
While collaborative research brings great benefit to the University it also carries some risks. To address the financial, regulatory and reputational risks involved in carrying out collaborative research and transferring funds to partners, funders expect to see a clearly documented internal process in place for carrying out due diligence on research partners. This is good practice for any organization regardless of funder requirements.
It is important when carrying out collaborative research to maintain standards consistent with:
- The University’s values
- The University’s policies and procedures (or equivalent partner institutional policies)
- Applicable law and regulation
- Requirements of funding bodies
However, in collaborative research there is always a chance that things could go wrong from time to time, or of partners unknowingly undertaking research in a way that is inconsistent with the above standards. In order to reduce the chances of such situations occurring, and to be able to address them when they do occur, it is important to understand the legal and regulatory contexts in which our research partners work and their normal working practices for research and research management. This enables known risks to be addressed prior to research projects commencing and appropriate mitigating measures to be put in place.
The University will carry out proportionate due diligence on collaborative research partners in accordance with this policy and the associated guidance and procedures to identify and manage risks associated with working with partners on collaborative research projects.
The aims of this policy are:
- To embed as normal procedure, the requirement to carry out risk-based proportionate due diligence for research partners.
- To highlight the relevant guidance and procedures on how to ensure the appropriate, proportionate due diligence is carried out on research partners.
- To make all staff aware of their individual responsibilities to play a proactive role in identifying and managing risks at application, award and project stage.
- This policy applies to all collaborative research activity in which the University of Dundee is the lead partner.
- This policy applies to all University staff engaged in research or research-related activity with collaborative partners.
- The level of due diligence carried out will be proportionate to the risks associated with an individual partner on a particular project. The same due diligence would not be carried out for a partner receiving £2k as a partner receiving £200k, for example. Nor would a partner in the UK usually require the same level of due diligence as a partner located in a low-income country.
- It is the Principal Investigator’s responsibility to ensure that the due diligence process is followed where required according to the due diligence guidance and process documents. See “Your Responsibilities” below for further details.
- To comply with this policy, Principal Investigators (PIs) should also adhere to other University of Dundee Policies relating to Research as laid out in Research Policies.
4. What is due diligence in the context of collaborative research?
Due diligence in the context of collaborative research is a series of checks carried out to identify potential risks of working with a partner and to put in place any associated mitigating measures necessary to ensure good research practice and compliance with appropriate laws and regulations. Full due diligence takes into account:
- Legal status of the organization
- Organizational and Research Governance
- Ability to deliver
- Financial stability
- Sub-contract management
- Reputation and experience
Due diligence is not, and never should be, a “tick-box exercise”. Rather, it is a way of enabling us to better understand our research partners and their administrative practices, thereby ensuring good research practice and enabling the University of Dundee to comply with relevant regulatory and legal requirements. It enables us to identify risks and work proactively with the partner to manage them to reduce the potential of legal, financial or reputational loss to the University.
Due diligence in this context at the University of Dundee can be broadly broken down into three stages:
- Pre-application due diligence
- Award stage due diligence
- Project stage due diligence.
- Pre-application due diligence
This is an initial assessment, carried out in-house, to determine the potential inherent risks of working with a particular partner on a particular project. This is carried out before a research application is made and serves two purposes:
- To identify any reputational or regulatory red flags associated with the partner
- To inform the level of due diligence that will be required at award stage
Some non-low and middle income country (LMIC) partners are exempt from this process due to the inherently lower risks associated with working with them. See “Your Responsibilities” below for further details.
- Award stage due diligence
Depending on the assessment at application stage, further due diligence may be required at award stage. The relevant information is gathered through a standard Due Diligence Questionnaire which is sent to partner organisations for completion. The type of information asked for is dependent on the nature of the risks identified during the assessment at application stage. Findings from the due diligence review may be used to inform collaboration agreements and working practices with the partner.
- Project stage due diligence
During the lifetime of the project, the academic research team and relevant professional services must ensure that the research is carried out in accordance with the relevant regulations and legal requirements, and taking into account any mitigating measures recommended at award stage.
Circumstances can change during the course of a research project and it is important that due diligence is reviewed based on any material changes in circumstances, for example a changing political situation in the partner’s country, major changes in the project team, changes to project equipment/infrastructure.
5. Your responsibilities
It is the Principal Investigator’s responsibility to ensure that the due diligence process is initiated where required according to the due diligence guidance and process documents. Due diligence needs to be considered for the following partners, and PIs should use the due diligence guidance to identify the first steps they must take depending on the partner and funder:
- Partner organisations based in a country which is on the DAC list of LMICs, regardless of the funder.
- Partner organisations on UKRI applications (except public universities and government departments in the UK and in the EU or European Economic Area, and some low risk non- LMICs which are exempt due to inherently lower risk). These partners will normally require only a streamlined due diligence check at application stage, subject to the nature and location of the partner.
- Partner organisations on applications where the funder guidance specifies that due diligence is required.
- Other partner organisations as updated from time to time and detailed in the due diligence guidance and process.
It is the responsibility of PIs, during the lifetime of the project, to alert the relevant professional services of any material changes in circumstances that may affect the risks associated with the project.
6. Support for Due Diligence
Staff in Research & Innovation Services are the first point of contact for support relating to Research Partner Due Diligence. In the first instance, queries can be sent to firstname.lastname@example.org.
If there is uncertainty around the applicability or interpretation of this policy, the matter must be referred to the Convenor of the University’s Research Governance & Policy Sub-Committee.
PIs, Schools, Research & Innovation Services, Research Finance Services and Academic and Corporate Governance will work together to implement and monitor compliance with this policy.