Due diligence is not one process. There are several functions across the University that carry out checks, review, or validate information about the organisations with which we work. The Policy on Responsible International Research Activities and Collaborations and the Research Risk Profiler can help researchers to navigate these requirements.

Research Collaborator Due Diligence is the process by which the University mitigates some of the risks inherent to the sub-contracting or passing on of research funds to third parties, shares good practice and gains assurance that research collaborators have the capacity and expertise to carry out the research with us and manage the funding associated with the project to the standards set by the funder.

The University has chosen to adopt a risk-based approach. As such, these checks should be applied in a proportionate fashion taking account the nature of the collaboration, the value of the funding and the level of risk associated with the research.

Detailed guidance is provided in the Research Collaborator Due Diligence SOPs.

It is a requirement of an increasing number of public and charity research funders that due diligence checks are undertaken on all collaborators or sub-contractors to whom the University is passing on grant funding.

This means that the University must have a documented process in place to mitigate some of the risks inherent to the sub-contracting or passing on of research funds to third parties and assure itself that all sub-recipients of research grant funding have the capacity and expertise to conduct the research and manage the funding to the standards required by the terms and conditions of the funder.

The purpose of this process is to help ensure that potential risks are identified, understood, and mitigated prior to the research commencing, and to record the case to proceed with a collaboration, at a level of seniority within the University that is appropriate to the level of risk. It is not designed to prevent appropriate research partnerships being formed.

No – the university has chosen a risk-based approach and as such due diligence only is required when:-

The collaborator is engaged on a public or charity funded research project

AND

The collaborator is not one of the following:

• Collaborating universities from the UK, EU, EEA and Switzerland, Australia, Canada, Japan, New Zealand, Singapore, South Korea, and the United States
• UK public organisations e.g. NHS Trusts, UK Local Authorities and UK Government Departments
• UK Charities registered with the Charities Commission
• UK industrial collaborators subject to a collaboration or other contractual agreement

No - the Research Collaborator Due Diligence checks are not required for collaborators or sub-contractors on industry funded research projects, as these are subject to the full contracting process.

However, due diligence is not one process. There are several functions across the University that carry out checks, review, or validate information about the organisations with which we work. The Policy on Responsible International Research Activities and Collaborations and the Research Risk Profiler can help researchers to navigate these requirements.

Due diligence applies to external consultants who are engaged on a public or charity funded research project where the University will be passing:-

- £50K or more to the consultant over the lifetime of the project. 

- less than £50K (but more than £10K) to the consultant over the lifetime of the project AND the consultant is based in or the consultancy will be conducted in a UK government embargoed, sanctioned or restricted country (OR the funder requires it). An abridged questionnaire is available for these collaborations.

These checks do not apply to industry funded consultancies.

The purpose of a due diligence review is to build up a picture of a collaboration, and where possible, to identify and militate against any potential risks.  Each contributor is encouraged to record any considerations that may inform the level of risk associated with a collaboration. No one person “signs off” a due diligence review. Where a project is identified as particularly high-risk, it may be forwarded for additional review, so that the case to proceed can be considered and recorded. Additionally, this allows the University to monitor the overall risk portfolio of the University’s research collaborations. Additional guidance is provided in the Research Collaborator Due Diligence Summary Form.

Official development assistance (ODA) is government aid that promotes and specifically targets the economic development and welfare of developing countries. For research funds that include Official Development Assistance (ODA), including the Global Challenges Research Fund (GCRF) and Newton Fund, there is an increased need for assurance, transparency, and accountability, as this expenditure forms part of the UK’s overseas aid budget and is reported as part of its official statistics.

The corruption perceptions index can indicate the wider fiscal context in which the collaborator is operating. For this reason, it is important that the corruption index is recorded for the country in which the research will be conducted. This may be different to their registered address. A low score indicates that the collaborator may be operating in a country in which the level of corruption in the public sector is perceived to be high. This does not mean that the University wishes to avoid these collaborations, but it may indicate that the project requires additional monitoring.

No one person “signs off” the due diligence review; the purpose of a due-diligence review is to build up a picture of a collaboration, and identify and mitigate against potential risks. In order to facilitate a collaboration, additional financial and/or contractual measures may be recommended.  Where a project is identified as high-risk, it may be forwarded for additional review, so that the case to proceed can be considered and recorded. During the lifetime of the project RS Finance and the PI are responsible for ensuring any mitigating financial or project clauses are adhered to.

The Research Collaborator Due Diligence process is not intended as a pass/fail exercise. The purpose of pre-award checks is to gather information in order to facilitate and reinforce a collaboration. When potential risks are identified early, the University can put measures in place to mitigate against these risks.

If a collaboration is identified as particularly risky, the Research Collaborator Due Diligence process allows the decision to proceed (or not) to be escalated to the appropriate level of seniority. 

As soon as the questionnaire is returned the review can begin. So as to avoid delays to the project set-up, there are a number of checks that can be conducted while the funding decision is still pending. While this may mean that some checks are carried out on projects that are not eventually funded, postponing the checks to after award is likely to cause significant delays to a project.

Once the pre-award checks are complete the coordinating RS (or PS) Team should ensure that the completed due diligence questionnaire, summary form and supporting documents are retained with the application record in Pure, in accordance with the University of Manchester Records Retention Schedule.

Once the notification of funding is received, the coordinating RS (or PS) Team can coordinate the remaining due diligence checks.

Collaborators should be advised to complete and return the questionnaire within 8 weeks of receipt to ensure that an opinion on the level or risk and mitigating actions are agreed as soon as possible. This process can be lengthy, but must be completed before the research begins and sub-contracts or collaboration agreements are issued.

The University recognises that there are many reasons a collaborator may not be in a position to provide adequate information and it does not mean that a collaboration will be automatically halted. On the contrary it indicates that the University may need to help the partner to meet the funder’s terms and conditions and provides an opportunity to do so from the start. 

If at any point during the project, a budget uplift, virement or alteration, means that the university will be passing more than £50K to a collaborator over the lifetime of the project, the full due diligence process will be required. In this case the RS Finance and/or the PI will be responsible for alerting the relevant RSO/RSM who will then initiate the process. 

In short yes. This is because the collaborator’s situation may have changed since the original due diligence was carried out. The research project and budget may differ too, which will affect how the risk is assessed.

If a search of Pure reveals that the collaborator has already completed and returned the appropriate level of due diligence questionnaire, the RS Team can download the completed questionnaire from Pure, and return it to the collaborator so that they can review, amend and return the updated copy. The updated questionnaire must then be submitted to the full review process.

It is not possible to transfer a completed questionnaire or a due diligence review from one project to another. This is because the collaborators circumstances may have since changed and the new project may present a different risk profile to the University. 

The coordinating RS (or PS) Team should ensure that the completed due diligence questionnaire, summary form and supporting documents are retained with the award record in Pure, in accordance with the University of Manchester Records Retention Schedule.

In addition, a copy of the completed summary form should be sent to the RBE Research Services Team (via researchoperations@manchester.ac.uk), so that a copy can be stored against the organisation’s record in Pure. 

The central Research Support Team is on hand to answer your queries at researchoperations@manchester.ac.uk