Partner Due Diligence
1) Why are Partner Assessments Necessary?
Risk assessments are necessary when working with new overseas partners on GCRF awards. Some of our main funders, such as Research Councils and the Wellcome Trust, require lead institutions to carry out appropriate due diligence checks on third parties who undertake activities funded by a grant. College responsibilities include cascading terms and conditions to third parties and monitoring compliance. While each institution will determine its own appetite for risk, the College’s main funders expect to see a clearly documented internal process in place for identifying and approving risks. This is good practice for any organisation regardless of funder requirements.
To assist with the early identification of potential risks, a two-page Relationship Review Questionnaire and Guidance [PDF] has been developed to guide Principal Investigators (PIs) and Departments in making these assessments at the start of the third party relationship by asking the right questions.
2) The Relationship Review Questionnaire
Using the College’s Relationship Review and Conflict of Interest policies, as well as external guidance on working overseas, the has been designed to consider a broad spectrum of financial, reputational, ethical and geo-political risks involved in new relationships. The Questionnaire should be completed by PIs and Departments with the input of proposed overseas partners.
We strongly recommend using the Questionnaire as soon as the relationship is established and as part of the pre-award application process. It is important to undertake a detailed due diligence assessment on each partner before a grant is awarded so that any risks identified by the answers in the Questionnaire can be mitigated by the contractual terms of the third party subagreement
3) Completing the Questionnaire and Assessing the Risk
PIs and Departments should work with potential partners to complete the two-page Questionnaire which asks for project details and considers the following risk areas:
- Financial probity of the partner
- Nature of the relationship and ability to deliver
- Partner ethics and integrity
- Political, economic and geographical risk
- Additional information that may affect the project aims.
Comprehensive Imperial Guidance Notes for the Relationship Review Questionnaire [pdf] have been developed to help PIs and Departments complete the Questionnaire. It explains the meaning of each question and includes links to related College policies and tips on what to look for.
In completing the Questionnaire and assessing the information provided, Departments should be mindful of each partner’s suitability and ability to deliver, and the need to protect the College’s reputation when engaging with any third party. Using the information provided relative to the value of the proposed partner’s budget, Departments can assess the overall risk using the Managing Risk guidance within the GCRF Toolkit.
4) What Next?
Completed questionnaires should be forwarded to your Research Services/ Joint Research Office team as part of the application process so copies can be retained on file. Departments should also retain a copy and refer to it as part of their project management activities. All completed Questionnaires should be made available if requested as part of future audit checks.
When a grant is awarded, a copy of the Questionnaire should be shared with the relevant Faculty Research Contracts team to inform the contractual terms of the third part subagreement and mitigate any risks highlighted by the answers. This could include amendments to partner payment terms; alternative approaches to managing milestones; and purchasing goods and services on behalf of partners.
5) What Other Checks Are Carried Out?
To reduce the risk of fraud, the College’s Accounts Payable team will independently verify the bank details provided by all new partners before payments are processed. Research subagreements must be put in place and a Bank and Contact Information Form must be completed by an appropriate finance representative from the third party organisation who will then be independently contacted by AP.
The bank details verification process is detailed on the Finance Knowledge Bank and will be carried out once a grant is awarded. These financial checks are designed to supplement the early assessment of risk supported by the Relationship Review Questionnaire.