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Research Third Party Due Diligence

Undertaking Research Third Party due diligence Managing risk Overseas Research Toolkit

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 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.

To clarify the operational process, responsibilities and escalation routes at Pre- and Post-Award, the Research Office has developed the Research Third Parties Framework for Managing Due Diligence [PDF]. Applying the Framework will help with the early identification of any risks that may impact the College's reputation, financial position, academic standards and research integrity, and to mitigate these during the lifetime of the research project.

Research Third Parties: Relationship Review Questionnaire

In the first instance, the Principal Investigator (supported by their Department) should complete a ‌Research Third Parties: Relationship Review Questionnaire [Word] 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 considers a broad spectrum of financial, reputational, ethical, safeguarding and geo-political risks involved in research relationships.

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. The completed questionnaire should be sent to rs.compliance@imperial.ac.uk for independent assessment by the Research Office. A summary of the risks identified and any recommended mitigating actions will be provided to the PI, Department, Faculty Reesearch Services and Faculty Contracts.

A comprehensive Overseas Research Toolkit is also available to guide PIs and Departments working with overseas partners at both Pre-Award and Post-Award stages, providing best practice advice, guidance and further recommendations for developing and managing international relationships. International research collaboration has huge benefits but there are also some potential risks. Trusted Research guidance and advice will help researchers make informed decisions.

Exceptions

Third Party due diligence checks will not apply to any of the following:

When the activity undertaken by the Third Party is governed by the College’s standard Terms and Conditions of Business which are managed by the Purchasing Team.
When the Third Party is eligible to receive UKRI funding.
When the Third Party is on the HESA List of UK higher education providers.
When the Third Party is a UK Government Department, agency or public body or Local Authority in England and Wales and Scotland.
When the project is funded by the European Commission (EC) and the Third Party is a proposed “beneficiary” to the EC Grant Agreement, but note that appropriate due diligence checks will still be required on other third parties who are engaged to deliver activities. (NB: The EC conducts its own financial and organisation validation of a beneficiary).