The Wellcome Trust–DBT India Alliance (the 'Alliance') identifies integrity, openness and partnership as key values; this statement has been produced and is intended to be applied in line with those values. The expectation is that the necessity to invoke these procedures will be a rare event but that by following these general principles the process of investigating allegations of research misconduct will be a fair process that protects the interests of all the parties involved.
Throughout this statement:
- 'CEO' means the Chief Executive Officer of the Alliance or any person notified to a institution, from time to time
- 'organisation' means any organisation in receipt of Alliance funds
- 'the Alliance’ means the Wellcome Trust/DBT India Alliance, a public charitable trust established under the laws of India that provides support for high-quality biomedical research and seeks to promote basic and applied research
- 'grantholder’ or ‘grantholders’ means all Alliance-salaried researchers and non-Alliance-salaried researchers in receipt of funds in any form from the Alliance in order to advance their research.
1. Definition of research misconduct
1.1 Research misconduct is defined by the Alliance as:
The fabrication, falsification, plagiarism or deception in proposing, carrying out or reporting results of research or deliberate, dangerous or negligent deviations from accepted practices in carrying out research. It includes failure to follow established protocols if this failure results in unreasonable risk or harm to humans, other vertebrates or the environment and facilitating of misconduct in research by collusion in, or concealment of, such actions by others. It also includes intentional, unauthorised use, disclosure or removal of, or damage to, research-related property of another, including apparatus, materials, writings, data, hardware or software or any other substances or devices used in or produced by the conduct of research.
It does not include honest error or honest differences in the design, execution, interpretation or judgement in evaluating research methods or results or misconduct unrelated to the research process. Similarly it does not include poor research unless this encompasses the intention to deceive.
2. Responsibilities of the organisation
2.1 The Alliance considers that it is the responsibility of the organisation to investigate all allegations of research misconduct made against its staff and students. Findings of research misconduct may be matters for consideration under the organisation's disciplinary procedures.
2.2 Organisations will need to give consideration to the procedures that will apply to visiting researchers while based in the organisation and the organisation’s staff while based in another organisation.
2.3 It is the responsibility of the organisation to inform the CEO, in confidence, at the earliest opportunity, about allegations of serious research misconduct that concern grantholders where it seems that there are reasonable grounds to believe that the allegation may be substantiated on investigation. It is at the discretion of the organisation to determine what constitutes 'serious misconduct'. The organisation is also responsible for informing the CEO of the outcome of any such investigation.
2.4 It is the responsibility of the organisation to inform the CEO, in confidence, of all instances of research misconduct involving grantholders that have resulted in the allegations being substantiated.
2.5 The organisation should have in place a policy statement relating to the treatment of whistleblowers, including a clear statement that research misconduct is taken seriously in the organisation and that any member of staff raising bona fide concerns can do so confidentially, and without fear of suffering any detriment. The statement should include a clear indication of the procedures in which such bona fide concerns by staff may be brought to the attention of a designated individual within the organisation.
Principles for investigation by organisations of allegations of research misconduct
Each organisation must have in place formal written procedures for dealing with allegations of research misconduct against its staff and students. Organisations should, where appropriate, take legal advice on implementing these procedures to ensure that the procedures comply with all legal obligations for the conduct of such investigations from time to time in force.
Organisations should endorse the following principles when implementing these procedures:
- the responsibilities of those dealing with the allegation should be clear and understood by all interested parties
- measures should be in place to ensure an impartial and independent investigation and to ensure that line management obligations or other interests of those dealing with the allegation do not conflict with these procedures
- those undertaking research at the organisation should be contractually obliged to participate in and comply with the procedure
- the organisation should consider the confidential nature of the investigation and how to safeguard the rights to confidentiality of the interested parties
- all interested parties should be informed of the allegation at an appropriate stage in the proceedings
- anyone accused of misconduct should have the right to respond
- a policy should be in place to ensure that no employee shall suffer a detriment who makes an allegation in good faith against another employee, but equally that disciplinary procedures are in place to deal with malicious allegations
- the allegation should be dealt with in a fair and timely manner
- proper records of the proceedings should be kept
- the outcome should be made known as quickly as possible to all interested parties
- anyone found guilty of misconduct should have the right to an appeal
- appropriate sanctions should be in place for cases when the allegation is upheld
- if appropriate, efforts should be made to restore the reputation of the accused party if the allegation is dismissed.
Involvement of the Alliance
Receipt of allegations
The Alliance recognises that there may be instances where an allegation of research misconduct is made directly to a member of the Alliance’s staff or the CEO rather than to an individual within the organisation. In such instances, the CEO will contact an appropriate individual at the organisation and the organisation will then be responsible for taking suitable action in line with its formal written procedures for handling allegations of research misconduct.
Investigations by the Alliance
As stated above, it is the organisation’s responsibility to investigate allegations of research misconduct made against its staff and students and this would be the Alliance’s preferred course of action in most cases. In exceptional cases, however, the Alliance may wish to undertake its own investigation into alleged cases of research misconduct that concern grantholders (for example where the Alliance’s reputation is at risk or where the Alliance is dissatisfied with the investigation undertaken by the organisation). Any investigations by the Alliance would only be undertaken following consultation between the CEO and the appropriate representative(s) of the organisation.
Sanctions
If the organisation or the Alliance determines that the allegation of research misconduct is substantiated, the Alliance may consider appropriate sanctions. These may include, but are not restricted to:
- a letter of reprimand
- the withdrawal of funding
- requiring the withdrawal or correction of pending or published abstracts and papers emanating from the research in question
- changes to the staffing of the particular project
- special monitoring of future work
- barring of the grantholder from applying for Alliance funds for a given period
- repayment of grant plus interest at the Alliance’s discretion
- discussion with the host organisation on the implementation of appropriate disciplinary procedures.
At all times, in line with its grant conditions, the Alliance reserves the right to withdraw funding with immediate effect.
