University's due diligence procedures
If your research proposal or project involves co-investigators from overseas organisations, we must complete financial and capability due diligence checks. These checks are undertaken to comply with funder requirements and to minimise the University's exposure to risk.
The following countries are subject to UK government sanctions: Afghanistan, Central African Republic, Guinea-Bissau, Iran, Iraq, Libya, Mali, Myanmar, Nicaragua, North Korea, Russia, Somalia, South Sudan, Sudan, Syria, Venezuela, Yemen, Zimbabwe.
If your proposal involves collaborating with institutions in any of these countries, please contact the Due Diligence team to discuss at the earliest opportunity. Email firstname.lastname@example.org.
Proposal development stage
If your proposal involves one or more overseas partners as collaborating investigators (Co-Is), you must alert the due diligence team: Email email@example.com or notify your Pre-Award Development Officer.
You will be invited to complete the pre-award due diligence questionnaire by the University’s Due Diligence and Compliance Officer. This questionnaire asks for basic information about the project and the partners and allows the due diligence team to determine what level of checks must be applied to the partners. You must complete the questionnaire for every new proposal, even if you have already worked with the partner(s) on previous projects.
Partnerships with overseas partners must be formalised before your proposal is submitted. To do this, a non-legally binding Head of Terms (HoT) must be signed by all partners. This lays out the expected key obligations and responsibilities of all partners.
The Head of Terms must be:
- signed by all institutions before submitting your full proposal
- returned by the PI to the due diligence team when signed by the overseas partner
- counter-signed by the University of Bath; as arranged by the due diligence team
The Due Diligence and Compliance Officer will also contact your overseas partner(s) directly, asking them to complete a policy and evidence pre-screening checklist.
This document contains a list of key policies, procedures and evidence the University would like all partners to have. The checklist allows the due diligence team to identify any potential issues and rectify them early in the research proposal process, so as to not impede the development of the proposal, or the implementation and setup of the project if the proposal is funded.
These procedures must be completed prior to the submission of your proposal to the funder. This allows for the smooth and efficient set up of the project if it is funded. All documents received throughout this process are kept on record, meaning future proposals with the same partners can be processed more efficiently.
The PI may receive a request from RIS for their team to complete the training before the proposal is submitted, if not all Bath Co-Is have completed it.
Project implementation stage
When a letter of award is received, the PI should inform their Pre-Award Development Officer and the due diligence team. Depending on the information gathered at the pre-award stage, your overseas partner(s) may be asked to complete the Partner Review Questionnaire. Overseas partner(s) will only be asked to complete this questionnaire if it is determined that key policies are missing which elevate the project to a high-risk status.
At the project implementation stage, the due diligence team will review the information gathered at the pre-award stage, alongside the Partner Review Questionnaire (if required), and will confirm whether an award can be accepted, and a Collaboration Agreement issued.
At this point, overseas partners will have been determined to have passed the due diligence process and will be added to the University’s due diligence register. Partners’ due diligence status remains in place for a period of 36 months. If your project is longer than 36 months, the overseas partners’ may be subject to a due diligence renewal process. Please contact firstname.lastname@example.org to discuss further.
Partnerships must be formalised before the project starts by signing a Collaboration Agreement, issued by the Contracts team: Email email@example.com. This lays out the key obligations and responsibilities of all partners during project implementation.
The Collaboration Agreement must include:
- Partner Review Questionnaire completed and signed if applicable
- terms of payment (this could change depending on perceived risk and practicalities for the receiving organisation)
- documentation required to obtain payment
During project implementation, all costs incurred by the partner organisation must be accompanied by supporting evidence and checked.
If issues of potential corruption practices arise matters should be escalated by the PI, who must follow the process detailed in the Anti-Bribery Policy. The funding body should be immediately informed and consulted on the way forward.
For any advice or to speak to us before starting a project, or during implementation, contact the RIS due diligence team: Email firstname.lastname@example.org.