Reflecting the growing international reach and complexity of the research and related knowledge exchange activities conducted at Oxford Brookes, as well as the ever evolving set of statutory requirements for, and good practice on, conducting research we are revisiting our approach to assessing the risks and frameworks within which we undertake this range of activities.
As well as this wide range of activities, Oxford Brookes encourages national and international collaborations. In order to ensure that these partnerships run as smoothly as possible, Due Diligence needs to take place, as early as possible, to ensure compliance with statutory, contractual and funder requirements. It is fundamental to good governance and ethical decision-making, to provide guidance for agreements, contracts, employment, visiting academics, sharing of intellectual property, associations, or monetary exchanges.
Process and procedure for staff
This updated Due Diligence process relates to all internally and externally funded research and related activities by Brookes staff, which may involve areas of potential national security risk, any contracted staff, and/or external collaborators. It forms a mandatory part of the pre- and post-award processes we conduct via Worktribe, but also includes activities funded internally by Oxford Brookes.
Why is this necessary?
The process allows the University to initiate a conversation as early as possible to discuss any potential issues. The information provided on funders and partners can be reviewed to form a risk assessment of the ethical, legal, financial, and national security considerations at the development stage.
What categories of activities are included:
The Due Diligence Assessment Form should be completed for:
- Research
- Consultancy
- Contract Research
- Knowledge Transfer Partnerships
- Continuing Professional Development/Training Services
- Facilities and Equipment
Doctoral process and procedure
In the last few years, Due Diligence requirements have expanded to manage the increasing complexity of funder and statutory requirements. Reflecting the growing international reach and depth of the research conducted at Oxford Brookes, by both staff and our research students, a risk-based approach to Due Diligence Assessment of doctoral students is being put in place. The University aims to ensure that the process runs as smoothly as possible, while ensuring that there are appropriate protections in place for students, supervisors and research projects.
The Assessment is not designed to be restrictive, but allow for early conversations to support and enhance any research and protect research students. A light touch process involves a brief evaluation as early in the application process as possible, as a starting point for identifying potential issues. *The process reviews visa requirements, research collaborators, thesis subject, and funding sources, aiming to ensure that all the necessary statutory elements are highlighted before committing to a partnership, ensuring the academic integrity, ethical standards, and overall suitability of the collaboration at the admission phase. A simple traffic light assessment identifies the level of risk, based on the information provided; this can be updated as the project progresses. The Research Culture & Practice Team will liaise with the PGRTs and Faculty Admin Teams to establish and elaborate mitigating measures.
The key areas for review are:
- Collaborators - This includes: Secondary supervisors at other institutions, translators, data analysis, research assistants, any person or company employed by the student to assist in the completion of their research project/thesis, etc.
- Funders – Any person or company providing funding or in-kind support to the student, research project or thesis.
- Location – Risk is determined by review of visa requirements, government sanctions, national security, export controls, etc.
- Research Topic – Risk is determined by government restrictions, legislative requirements, ethics, etc.
For doctoral students/research, completion of the Due Diligence Assessment is the responsibility of the Faculties and, ideally, should be completed as early as possible in the offer process. The aim is to ensure that there is consistency across departments and any potential issues are addressed as quickly as possible to mitigate any potential risk.
The below checklist form is to be completed by the PGRTs, who hold responsibility for admitting students to the Research Degrees Programme. It should be completed as part of the initial checks on eligibility that are undertaken at the point of interview selection. Once completed, the form would be reviewed by the Research Support & Governance Team. Any queries could then be followed up directly with the PGRTs, Faculty Research Administrators and the Research Degrees Team. The completed form should be uploaded to CRM Faculty Research Administrators along with the other admissions documentation. RDT, who send out the Offer letter, could check that the Due Diligence has been completed prior to sending out the letter.
Due Diligence Risk Assessment Process
Stage One: Completion of Due Diligence Assessment Form
The first stage aims to initiate the necessary conversation to support academics on any potential issues. The Due Diligence Assessment Form is a Yes/No Assessment Form submitted via Google Forms to the Research Culture and Practice Team (RC&P). The RC&P Team will review this, triage the responses and contact the researcher to discuss the next steps.
For all research and related activities, the form should be completed as early as possible. This should, ideally, be undertaken at the admission (pre-offer) stage. It is important to remember that this is only the initiation of the conversation. Changes to planned research and details of the supervisors/collaborators, etc. may change and this can be reviewed at a later stage. In addition, for Professional Doctorate Students, it may be necessary to complete the form at registration when more detail is known of the research project specifics.
Stage two: Liaise with the RC&P Team
The RC&P Team will act as the hub to ensure that any issues raised are directed to the most appropriate area within the University. It will work with academics, relevant Faculties and Professional Services to establish and elaborate mitigating measures if necessary. The team acts as the central point of contact for colleagues, monitoring and communicating any potential risk and identifying any areas that require more additional statutory compliance, such as ATAS certification, Government Sanctions list or country specific approvals.
Foreign Influence Registration Scheme (FIRS)
FIRS is a government registration scheme designed to increase transparency of foreign government influence within the UK. Its aim is to provide clarity and understanding of arrangements made by a UK individual or organisation with and specifically directed by a foreign power to carry out activities specifically designed to influence UK political policy.
For more information please read the Brookes Guidance or contact the Research, Innovation and Enterprise Directorate.