Undertaking Due Diligence
The following guidance outlines when due diligence checks on third parties are necessary, how to use the Research Third Parties: Relationship Review Questionnaire [Word] and what to expect from the Research Office's independent risk assessment process.
Partner Due Diligence
1) Why are third party assessments necessary?
When working with third parties (UK and overseas), it is important that a risk assessment is undertaken before an award is accepted. Many of the College's main funders require lead institutions to carry out due diligence checks on all third parties who undertake activities funded by a research grant or contract. If Imperial is a research partner and is planning to transfer funding to other third parties, there is still a requirement to conduct due diligence checks on each third party associated with Imperial’s part of the project. While each institution will determine its own appetite for risk, funders expect to see a clearly documented internal process for identifying, assessing and mitigating risks. This is good practice for any organisation regardless of funder specific requirements.
It is recommended that relationship reviews are also undertaken for existing as well as new third party organisations.
2) Research Third Parties: Relationship Review Questionnaire
Drawing on the College’s Relationship Review and Conflict of Interest policies, as well as external funder guidance, the Research Third Parties: Relationship Review Questionnaire has been designed to help PIs to consider a broad spectrum of financial, reputational, ethical, safeguarding and geo-political risks involved in establishing research relationships. It includes comprehensive guidance notes which explain the meaning of each question and includes links to related College policies and advice on what to look for. The questionnaire should be completed by the Principal Investigator (supported by their Department) with the direct input of the third party organisation. A separate questionnaire should be completed for each third party associated with the project.
The questionnaire should be completed as soon as the relationship is established and before an award is accepted so any mitigating actions can be taken, such as making appropriate changes to the research sub-agreement and the Department’s project management plan.
3) Completing the Research Third Parties: Relationship Review Questionnaire
PIs and Departments should work with the third party organisation to complete the Research Third Parties: Relationship Review Questionnaire which asks for project details and considers the following risk areas:
- Financial probity
- Nature of the third party relationship and ability to deliver
- Ethics and integrity
- Political, economic and geographical risk
- Additional information that may affect the project's aims.
As part of the relationship review process, you should consider how suitable the third party organisation is to deliver the proposed work. This can also help to strengthen the case for support on the research proposal so it is important to explain:
- How the relationship with the third party organisation was established
- Why they are the most suitable third party organisation to undertake the work
- How you intend to develop the third party relationship and monitor their project deliverables.
Completed questionnaires should be sent to firstname.lastname@example.org for independent assessment by the Research Office.
4) Research Office risk assessment process
The Research Office risk assessment process is summarised as follows:
- A risk score is calculated for each section of the questionnaire leading to an overall Low, Medium or High risk rating
- The College’s standard risk assessment criteria is used to determine an approproate score for impact and likelihood. Impact refers to the consequences if the risk occurs and Likelihood is the probability of the risk occurring
- A summary of the risks identified and any recommended mitigating actions will be provided to the PI, Department, Faculty Research Services and Faculty Contracts
If a third party is considered very high-risk, the matter will be escalated to the Director of the Research Office, Faculty Operating Officer and Faculty Dean. If the issue(s) cannot be resolved, the matter will be referred to the Vice-Provost (Research and Enterprise) for a decision.
5) Should we review a third party organisation 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. In such instances, there is no formal requirement 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, corruption, violation of human rights.
6) What happens if Imperial is not leading the project?
The lead institution is responsible for undertaking the appropriate due diligence checks on third parties who undertake activities funded by a research grant or contract. If another institution is leading the project, it means that Imperial is a research partner and will not be responsible for undertaking checks on the third parties working on the project.
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 contacted directly 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 will supplement the third party risk assessment undertaken by the Research Office.
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: