Trusted Research Due Diligence

Light-touch checks are required on new overseas partners in order to identify any ‘red lights’ that could signal a more detailed assessment is required before the application is submitted to the funder.  

Principal investigators should complete the Stage 1 Light-touch new international research partner v1.0 proforma and uploaded this to Worktribe for review by Research & Innovation. If any major concerns are identified:

• These must be discussed between the principal investigator, Head of School and Research & Innovation to determine if they can be addressed through mitigation, e.g. identifying an alternative partner, changing aspects of the project or downstream contractual management of the partner;
• In some instances, more detailed due diligence on the partner may be initiated before the application is submitted;
• All internal approvers must be made aware of the identified risks and confirm whether they are happy to proceed with approving submission of the application.

Ahead of acceptance of new grant awards, a full due diligence questionnaire should be completed by the University of Aberdeen principal investigator (PI) in conjunction with each new international partner. This is required even when Stage 1 due diligence was completed before the grant application was submitted.

Where the international partner will receive more than £25K the UKRI ARMA proforma should be completed. For partners who will receive less than £25K the low value proforma should be completed - this is available via the Research & Innovation (R&I) Research Development or Technology Transfer contact for the application. 

Once the appropriate proforma(s) have been completed, and any additional information requested by Research & Innovation has been provided, these should be sent to R&I for evaluation. The sole responsibility of R&I is to flag high risk concerns and suggest possible mitigating actions to the PI and the School. Ultimately it will be the Head of School’s decision whether to accept the award.

Research activities requiring Enhanced Due Diligence should be flagged to the appropriate Research Development Executive (RDE) or Impact and Knowledge Exchange (IKE) contact within Research & Innovation.

These activities may be identified through various routes, including:

• • Self-referral by academic staff or students;
  • Identification by Research & Innovation during research development processes;
  • Identification by Research & Innovation following a research contract request;
  • Referral from the internal International Advisory Group;
  • Other route via individuals, Research & Innovation or other sections.

The lead University of Aberdeen researcher will be asked to complete the Enhanced Due Diligence Assessment proforma to enable the activity to be registered and initial key information collected. 

A desk-based open search of publicly available information will be conducted on the entity and any named individuals by Research & Innovation (R&I), supported by other  Professional Services sections.

These checks may include some or all of the following:

• • Basic entity information: name, location, and business registration details;
  • Leadership and key personnel: affiliations of key individuals;
  • Legal compliance: assessment of the technologies against UK and Us controlled lists and NSIA;
  • Sanction and watchlists: searches for the entity or associated individuals on international sanction or watchlists;
  • Ethical considerations: review of any prior involvement in activities that could breach ethical research standards;
  • Collaborations and funding: identification of past and current partnerships and funding sources;
  • Intellectual property (IP): evidence of any prior cases of IP theft;
  • Research integrity: assessment of any publicly available records related to research manipulation, fraud, or misconduct;
  • Public perception: review of any negative media coverage associated with the entity or named individuals.

In cases where limited information is available on the third party the University may request an entity check from the UK Government Export Control Joint Unit.

Following the due diligence assessment in Step 2, Research & Innovation will make an outcome recommendation to senior colleagues with delegated responsibility for Trusted Research oversight. The principal investigator will be involved in this process and following the senior review one of the following outcomes will be confirmed:

• No further action – research activity can proceed, no Export Control licence or NSIA referral required;
• Potential concerns identified –  further information and / or a mitigation plan required before a decision can be made;
• Possibly/probably in scope of Export Control or NSIA legislation – Either: Export Control licence application should be submitted, referral required to NSIA or Export Control Joint Unit (ECJU) advisory service; or external expert advice should be sought.
• Risk deemed too high – activity considered too risky to proceed.

Export Control licence applications: Research & Innovation (R&I) will work with the principal investigator to help prepare and submit the licence application. See Applying for an Export Licence guidance.

6 to 8 weeks should be allocated for completion of the Enhanced Due Diligence process, though timelines may vary depending on complexity. Researchers will be required to work closely with Research & Innovation and their Schools to compile required information and will be kept appraised during the assessment process.

If an Export Control licence is required the process of applying for and receiving an outcome from the Export Control Joint Unit usually takes around 3 months although the University has an example of a licence which took over 6 months to be granted.

Where an Export Control licence is required the export research activity subject to the licence cannot proceed until a licence has been applied for and the outcome received - this applies to funded and unfunded activities. In some cases the University will not be able to accept a grant award until the outcome of an Export Control licence has been received.