Due diligence

What is due diligence?

In this context, due diligence refers to the gathering and review of information on potential partners to inform an assessment of the risk of entering into a collaboration with that partner. Once a collaboration has been agreed, due diligence involves ensuring compliance with the agreement and associated funder requirements.

For international partnerships, due diligence entails reviewing:

• the regulatory and statutory environment of the country/countries in which the partnership will operate
• the legal, financial and academic circumstances of foreign partners

The scope and scale of due diligence can vary according to the particular collaboration and partner(s) concerned. UCL suggests that Principal Investigators (PIs) should adopt a proportionate approach relative to the stage of the research application process.

UCL due diligence process

UCL’s due diligence process applies to all research partnerships with organisations based in countries on the DAC list, including charity grants and those funded by Wellcome. This guidance operationalises the UCL due diligence policy, and aims to support applications so that due diligence and research are successfully undertaken.

The process outlined below aims to ensure that the potential risks of working with academic, public and non-governmental organisation partners in low- and middle-income countries (LMICs) are identified and mitigated for, prior to initiating the research project.

Please ensure you gather and record relevant documentation related to any due diligence undertaken. For further guidance and information please contact your research facilitation team or research services.

UCL recommended process

Pre-award

Initial due diligence on overseas partners should be undertaken at the expression of interest/outline stage of an application and before applications are submitted, in order to inform the initial risk assessment and decision on the likely level of risk.

All research applications with LMIC partners are required to include confirmation, via Worktribe, that initial due diligence has been carried out. Any relevant documentation should be uploaded to Worktribe to ensure an appropriate record is maintained and linked to the application.

• PIs are asked to complete a short online form for each LMIC Partner.
• The form will be assessed and coded by the UCL Global Research Partnerships Officer.
• UCL Global Research Partnerships Officer will contact the PI via email to inform them of the initial risk assessment score. Please allow up to five business days from the day of your submission for processing.

Projects should be escalated for approval in accordance with the level of risk, as set out below:

• Projects scored as green (low risk) are signed off by Heads of Departments.  
• Projects flagged as amber (medium risk) will be forwarded to Faculty (Dean) for information.
• Projects flagged as red (high risk) will be forwarded to Faculty (Dean) for sign-off.

Post-award

For new awards, full due diligence should be undertaken prior to a collaboration agreement being signed. If a project is classed as high risk, or if it is very large or complex we suggest that due diligence is carried out in pre-award in parallel to the development of a full proposal submission.

If due diligence has been undertaken by UCL in the last 3 years or if the amount of funding which will be transferred to a partner overseas is less than £30k there is no need to follow the second stage of the due diligence process. Please contact UCL Global Research Partnerships Officer for details. However, if medium or high risks are identified, mitigation for each new research project should be undertaken and signed off by Faculty.

All research applications with LMIC partners are required to include confirmation, via Worktribe, that full due diligence has been carried out and signed off by Faculty. Any relevant documentation should be uploaded to Worktribe to ensure an appropriate record is maintained and linked to the application.

• PIs are asked to send a copy of the full UCL due diligence questionnaire to each LMIC partner for completion.
• PIs are asked to send the completed questionnaire for assessment to UCL Global Research Partnerships Officer, who will collaborate with a due diligence working group and will work with the PI on any required risk mitigation and obtaining sign-off as required.

All projects should be escalated to the Faculty Dean for final approval.

Ongoing due diligence

Due diligence should be repeated for an organisation after three years or every twelve months if the organisation undergoes any major changes (i.e., change of director, fraud, poor reputation of research management/ delivery, change of risk classification of the country where the organisation is based etc.).

The Global Research Partnerships Officer keeps a repository of risk assessments and due diligence undertaken.

Useful documents

• UCL due diligence policy (pdf)

  UCL due diligence policy (pdf)

• UCL due diligence questionnaire (docx)

  UCL due diligence questionnaire (docx)

• UCL Barclays restricted countries list (pdf)

  UCL Barclays restricted countries list (pdf)

FAQs

When is UCL required to carry out appropriate due diligence checks on third parties who undertake activities funded by a grant (overseas partners)?
If UCL is the leading institution and will be transferring funds directly to an overseas organisation, then UCL will be responsible for undertaking due diligence checks for this partner. If UCL is not the leading institution or if UCL won’t be sending funds overseas, then due diligence won’t be required on the overseas partner/s. This responsibility is held by the Lead Institution for the project

When do I need to complete the initial risk assessment form (pre-award)?
The initial risk assessment form should be completed for each LMIC partner on a new research project where UCL is the lead institution and only if you plan to make a financial transfer to the overseas partner(s). The form should be completed before the funding application has been submitted.

When do I need to complete the full due diligence questionnaire? (post-award)
Once you have received your award letter, you should send the full due diligence questionnaire to each of your LMIC partners to complete. The due diligence form should be completed and assessed before the collaboration agreement is signed.

If previous due diligence checks have been undertaken on the same partner organisation in the past 3 years, the research partner won’t be required to go through this full process again. Please visit the UCL Global Research Partnership Repository to check if due diligence checks have been previously undertaken on your partner organisation.  Please note that some project specific information might still be required so you should contact the Global Research Partnership Officer for further details.

If the amount of funding to be transferred to an overseas partner is less than £30k and is flagged Green at Pre-Award stage, it will be recommended to be approved absolutely, without the need to complete the full due diligence questionnaire. Such projects would be sent to Dean for confirmation that full due diligence is not required. For projects where additional risks are identified at Pre-Award stage, such as the whole project is flagged Amber or Red, full due diligence checks on each partner would still be required in most cases. Please contact the Global Research Partnership Officer for more information.

My research partner is based in an Upper Middle-Income Country, should they still go through the due diligence process?
Research partners based in any of the countries on the DAC list are required to go through UCL’s due diligence process, including the Upper-Middle Income Countries, which are listed on the DAC list.

Are there any Restricted Countries where it is not possible to transfer funds to any organisation based in these countries? 
Due to Barclays (UCL’s bank) imposed restrictions on financial transfers overseas on the following countries, it won’t be possible to transfer funds to any organisation based in these countries:

• Cuba*
• Crimea
• Iran
• North Korea
• Syria
• Venezuela

*For research organisations based in Cuba, funds could be paid but extra information must be provided by completing the Barclays Pre-Payment Advice Form.

What if my research partner is unable to provide some of the information/documentation requested or that information is only available in their local language?
We ask research partner organisations to provide as much information and documentation as possible. However, we are aware that this might not always be possible depending on the type of the organisation or the political/legal environment in the country where they are based. Therefore, we ask partners to provide a short explanation why this information/documentation is missing and we will work with the PI on any required risk management/mitigation plan, if needed.

Currently, UCL cannot provide financial support for any translation costs. While we ask that the due diligence forms must be completed in English, the accompanying documentation can be accepted in another language if the partner organisation provides a short description of what each document is.

Who do I need to contact for additional support with the due diligence process?       
Please contact Kristina Kertova (k.kertova@ucl.ac.uk), Global Research Partnerships Officer. Kristina undertakes the due diligence checks on all overseas research partners based in LMICs for UCL.   

Contacts

UCL Research Coordination Office for Life and Medical Sciences ODA Support
oda-research@ucl.ac.uk

UCL Global Research Partnerships Officer
Kristina Kertova
k.kertova@ucl.ac.uk

UCL Strategic Research Coordinator (Global Health)
Helen Hopkins
h.hopkins@ucl.ac.uk

Due diligence process diagram

UCL LMIC due diligence process bitesize training