Undertaking Due Diligence
The following guidance outlines when research partner checks are necessary, how to use the Research Third Parties: Relationship Review Questionnaire and Guidance [Word] and what to expect from the Research Office's independent risk assessment process.
Partner Due Diligence
1) Why are partner assessments necessary?
Sselecting the right partners to work with in the UK and overseas is crucial. PIs and Departments should undertake a Relationship Review for each proposed partner and maintain an auditable record of the decision-making process.
These risk assessments are particularly important when working with overseas partners. Many of our main funders, including UKRI and the Wellcome Trust, require lead institutions to carry out appropriate due diligence checks on all third parties undertaking activities funded by a grant. While each institution will determine its own appetite for risk, funders expect to see a clearly documented internal process for identifying, approving and mitigating risks. This is good practice for any organisation regardless of funder specific requirements.
With greater responsibility placed on institutions to manage Third Party relationships, it is recommended that Relationship Reviews are also undertaken for existing partners to ensure complete and up-to-date due diligence procedures have been followed.
To assist with the early identification of potential risks, a two-page Research Third Parties: Relationship Review Questionnaire and Guidance [Word] has been developed to guide Principal Investigators (PIs) and Departments in making these assessments by asking the right questions at the start of the third party relationship.
2) The Research Third Parties: Relationship Review Questionnaire
Drawing on the College’s Relationship Review and Conflict of Interest policies, as well as external guidance on working overseas, the Research Third Parties: Relationship Review Questionnaire and Guidance [Word] has been designed to help PIs to consider a broad spectrum of financial, reputational, ethical and geo-political risks involved in establishing new relationships. It includes comprehensive guidance notes which explain the meaning of each question and includes links to related College policies and tips on what to look for. 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 essential 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 in part by the contractual terms of the third party subagreement
3) Completing the Research Third Parties: Relationship Review Questionnaire
PIs and Departments should work with potential partners to complete the two-page Research Third Parties: Relationship Review Questionnaire and Guidance [Word] 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.
As part of the relationship review assessment and decision-making process you should also consider and record how suitable each partner is to undertake the proposed work. These considerations can also help to strengthen the case for support on the research proposal. It is important to explain:
- How the relationship with the partner was established
- Why they are the most suitable partner to undertake this research
- How you intend to develop the partner relationship and monitor their project deliverables.
When 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.
Completed questionnaires will be independently assessed by the Research Office. Please send them to firstname.lastname@example.org and pass a copy to your Faculty Research Services team it can be retained in the grant file. Departments should also retain a copy and refer to it as part of their project management activities.
4) The Research Office risk assessment process
Questionnaires submitted to the Research Office will follow an established two-stage risk assessment process that:
- Calculates a risk score for each section of the questionnaire leading to an aggregate Low, Medium or High risk rating
- Applies the College’s standard risk criteria to quantify impact and likelihood. Impact is the consequences if the risk occurred and Likelihood is the probability of the risk occurring.
- Proposes a set of actions to mitigate any risks identified
- Assigns responsibility for applying mitigating actions to the PI and Research Team or Faculty Contracts Team
- Shares a copy of the questionnaire and risk assessment with the PI, Department Manager, Faculty Contracts Team and Faculty Research Services team.
In line with the Relationship Review Policy, significant risks should be escalated to the Director of the Research Office, Heads of Department and Faculty Deans.
5) Should we review partners if there is no financial relationship?
Many research projects will include collaborations where no financial transactions take place, e.g. resources or support are given in-kind or voluntarily. In such instances, there is no formal requirements to undertake a detailed Relationship Review, but PIs and departments are still expected to consider the potential risks to the College’s reputation and the research project of accepting non-financial support and working with these collaborators e.g. bribery, fraud, tax evasion, violation of human rights.
6) What happens if Imperial is not leading the project?
The lead institution is responsible for undertaking the relevant due diligence checks. If Imperial is a partner organisation, then we will not be responsible for undertaking checks on all the research partners working on the project.
However, if Imperial engages a third party (UK or overseas) to undertake any part of its work, then we should undertake detailed due diligence checks as outlined above, examining the nature of the relationship and the financial probity of the recipient organisation.
7) Are any further partner checks carried out?
To reduce the risk of fraud, the College’s Accounts Payable (AP) team must independently verify the bank details provided by all new third parties (referred to as ‘suppliers’) before payments can be processed. Research subagreements must be put in place by the relevant Faculty Contracts team 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 Supplier Set-up and Payments process (including a downloadable Bank and Contact Information Form) is detailed on the Finance Knowledge Bank and will be followed once a grant is awarded. These financial checks are designed to supplement the early risk assessment supported by the Research Third Parties: Relationship Review Questionnaire and Guidance [Word].
8) What other guidance is available?
The following external indices and guides can help to highlight potential issues in the countries where you intend to work: