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Due Diligence for Research Collaborators

From the 1st August 2018 the University of Manchester has introduced due diligence checks for certain research collaborators on all public and/or charity funded research projects.

These due diligence checks do not apply to the following collaborators:

  • Collaborating Universities from the UK, EU, US, Canada and Australia
  • UK public organisations e.g. NHS Trusts, UK Local Authorities and UK Government Departments
  • UK Charities registered with the Charities Commission
  • UK industrial collaborators subject to a collaboration or other contractual agreement

Frequently Asked Questions

What is due diligence?

Due diligence is the process by which the University mitigates some of the risks inherent to the sub-contracting or passing on of research funds to third parties, shares good practice and gains assurance that research collaborators have the capacity and expertise to carry out the research with us and manage the funding associated with the project to the standards set by the funder.

The University has chosen to adopt a risk-based approach. As such, these checks should be applied in a proportionate fashion taking account the nature of the collaboration, the value of the funding and the level of risk associated with the research.

Detailed guidance is provided in the Research Collaborator Due Diligence SOPs.

Why is due diligence being introduced now?

It is a requirement of an increasing number of research funders that due diligence checks are undertaken on all collaborators (or sub-contractors) to whom the university is passing grant funding. This means the University must have a process in place to assure that all sub-recipients of research grant funding are fit to execute the research and manage funding to the standards required by the terms and conditions of the funder.

Is due diligence required on all collaborators?

No – the university has chosen a risk-based approach and as such due diligence only is required when:-

The collaborator is engaged on a public or charity funded research project

AND

The collaborator is not one of the following:

  • Collaborating Universities from the UK, EU, US, Canada and Australia
  • UK public organisations e.g. NHS Trusts, UK Local Authorities and UK Government Departments
  • UK Charities registered with the Charities Commission
  • UK industrial collaborators subject to a collaboration or other contractual agreement

Do these due diligence checks apply to collaborators on an industry funded research project?

No - these due diligence checks are not required for collaborators or sub-contractors on industry funded research projects, as these are subject to the full contracting process.

Does due diligence apply to consultants?

Due diligence applies to external consultants who are engaged on a public or charity funded research project where the University will be passing:-

- £50K or more to the consultant over the lifetime of the project. 

- less than £50K to the consultant over the lifetime of the project AND the consultant is based in or the consultancy will be conducted in a UK government embargoed, sanctioned or restricted country (OR the funder requires it). An abridged questionnaire is available for these collaborations.

These checks do not apply to industry funded consultancies.

I am a reviewer, what should I be looking for?

The purpose of a due diligence review is to build up a picture of a collaboration, and where possible, to identify and militate against any potential risks.  Each contributor is encouraged to record any considerations that may inform the level of risk associated with a collaboration. No one person “signs off” a due diligence review. Where a project is identified as particularly high-risk, it may be forwarded for additional review, so that the case to proceed can be considered and recorded. Additionally, this allows the University to monitor the overall risk portfolio of the University’s research collaborations. Additional guidance is provided in the Research Collaborator Due Diligence Summary Form.

Are there additional considerations for ODA funded projects (eg: GCRF or Newton Fund Grants)?

Official development assistance (ODA) is government aid that promotes and specifically targets the economic development and welfare of developing countries. The UK government has made a commitment to invest 0.7% of GNI on ODA. Research funds such as the Global Challenges Research Fund (GCRF) and the Newton Fund form part of this commitment. This brings with it an increased need for transparency and accountability, which may be reflected in the level and detail of evidence of expenditure that a collaborator is asked to provide.

Why do we record the corruption index of the country?

The corruption perceptions index can indicate the wider fiscal context in which the collaborator is operating. For this reason, it is important that the corruption index is recorded for the country in which the research will be conducted. This may be different to their registered address. A low score indicates that the collaborator may be operating in a country in which the level of corruption in the public sector is perceived to be high. This does not mean that the University wishes to avoid these collaborations, but it may indicate that the project requires additional monitoring.

Corruption Perceptions Index

Who “signs off” a due diligence review?

No one person “signs off” the due diligence review; the purpose of a due-diligence review is to build up a picture of a collaboration, and identify and mitigate against potential risks. In order to facilitate a collaboration, additional financial and/or contractual measures may be recommended.  Where a project is identified as high-risk, it may be forwarded for additional review, so that the case to proceed can be considered and recorded. During the lifetime of the project RS Finance and the PI are responsible for ensuring any mitigating financial or project clauses are adhered to.

What if an organisation fails the checks?

The due diligence process is not intended as a pass/fail exercise. The purpose of pre-award due diligence is to gather information in order to facilitate and reinforce a collaboration. When potential risks are identified early, the University can put measures in place to mitigate against these risks.

If a collaboration is identified as particularly risky, the due diligence process allows the decision to proceed (or not) to be escalated to the appropriate level of seniority. 

What if the questionnaire is returned before funding is confirmed?

As soon as the questionnaire is returned the review can begin. So as to avoid delays to the project set-up, there are a number of checks that can be conducted while the funding decision is still pending. While this may mean that some checks are carried out on projects that are not eventually funded, postponing the checks to after award is likely to cause significant delays to a project.

Once the pre-award checks are complete the RS team should ensure that the completed due diligence questionnaire, summary form and supporting documents are retained with the application record in Pure, in accordance with the University of Manchester Records Retention Schedule.

Once the notification of funding is received, the RS Team can coordinate the remaining due diligence checks.

What if responses are not received before the research starts?

Collaborators should be advised to complete and return the questionnaire within 8 weeks of receipt to ensure that an opinion on the level or risk and mitigating actions are agreed as soon as possible. This process can be lengthy, but must be completed before the research begins and sub-contracts or collaboration agreements are issued.

What happens if the collaborator can’t/doesn’t provide enough information?

The university recognises that there are many reasons a collaborator may not be in a position to provide adequate information and it does not mean that a collaboration will be automatically halted. On the contrary it indicates that the University may need to help the partner to meet the funder’s terms and conditions and provides an opportunity to do so from the start. 

What if there is a change to the budget?

If at any point during the project, a budget uplift, virement or alteration, means that the university will be passing more than £50K to a collaborator over the lifetime of the project, the full due diligence process will be required. In this case the RS Finance and/or the PI will be responsible for alerting the relevant RSO/RSM who will then initiate the process. 

Due diligence was completed for a previous application / grant, do we need to do it again?

In short yes. This is because the collaborator’s situation may have changed since the original due diligence was carried out. The research project and budget may differ too, which will affect how the risk is assessed.

If a search of Pure reveals that the collaborator has already completed and returned the appropriate level of due diligence questionnaire, the RS Team can download the completed questionnaire from Pure, and return it to the collaborator so that they can review, amend and return the updated copy. The updated questionnaire must then be submitted to the full review process.

It is not possible to transfer a completed questionnaire or a due diligence review from one project to another. This is because the collaborators circumstances may have since changed and the new project may present a different risk profile to the University. 

Will there be a central registry of due diligence reviews?

Due diligence reviews should be retained with the application record in Pure in accordance with the Records Retention Schedule.

What help is available?

The central Research Support Team is on hand to answer your queries at researchoperations@manchester.ac.uk