Due Diligence

At Aston, we highly value research that is conducted with collaborators in the UK and abroad, including industrial or business partners, other universities, local government, the health sector, and the charities sector. The importance of this approach is articulated in the University’s Mission, in our Research Strategy, and in the way that we generate impact with and for our beneficiaries.

Working with any partner involves risk, which could be reputational, financial or operational. All colleagues are responsible for ensuring that relationships with external partners are properly considered and (where appropriate) authorised. Our approach is in line with the requirements of public sector and charitable funders of research who require universities to undertake due diligence checks on all collaborators, or sub-contractors to whom we pass on grant funding, with particular emphasis on international collaborators.

Due Diligence is the investigation, or exercise of care, that a reasonable business or person is expected to take place before entering into an agreement or contract with another party. It takes into account ethical, legal, financial and national security issues, as well as academic circumstances, associated with a collaboration. It support good decision-making understanding costs, benefits and risks.

Aston’s approach is set out in full in our Outside Party Due Diligence Procedures June 2022 (download below)

These web pages provide specific guidance for research collaborations with overseas organisations. We want to support and enhance research projects, whilst mitigating risks - our Due Diligence process is not intended as a pass/fail exercise. For new projects that are under development, the starting point is to identify potential risks early in the pre-award phase, so that the University can consider ways to mitigate those risks, and projects can go ahead successfully wherever possible. If a partnership is identified as needing further input from senior colleagues, then it can be appropriately escalated before the bid is submitted.

For bids that are successfully funded, there is then a second stage of Due Diligence checks to be undertaken before contracts are signed. Once the projects is up and running, ongoing Due Diligence helps to ensure compliance with funder requirements, and with the collaboration agreement.

Due Diligence for Researchers - the basics

Why do we do Due Diligence on overseas research collaborators?

Carrying out due diligence checks prior to working with an overseas partner is a way to mitigate risks, share good practice and have assurance that any organisation that we partner with has the capacity and expertise to carry out the proposed research. This aligns with the UKRI requirement that UK research organisations have policies and process in place to manage risk-based due diligence with overseas organisations.

When you are discussing a new collaboration with potential overseas partners, please keep a record of your discussions and decisions. These will be required as part of the evidence trail to demonstrate that we have followed due process, and may be required as part of external audit processes.

Please contact your Strategic Funding Manager or Business Development Manager* as soon as possible to discuss the due diligence that may be required with respect to your collaborations with overseas partners.

*please see 'I'm not an expert in Due Diligence, who can help me?' tab below. 

Is Due Diligence required on all international collaborators?

Aston University takes a proportional, risk-based approach to Due Diligence.Checks on overseas collaborators on research and innovation projects will be limited to the following:

The project that you will be collaborating on IS publicly funded, or charity funded, AND if your collaborator is NOT one of the following:

• A university located in the UK, EU, US, Canada, Australia or New Zealand
• A UK public organisation, for example, an NHS Trust, UK Local Authority or UK Government Department
• A UK Charity registered with the Charities Commission
• A UK industrial collaborator, subject to a collaboration or other contractual agreement

Even if your collaboration is not within scope of the due diligence policy, we would encourage you to still think carefully about who you are working with and ask questions if there is anything you are unsure of. Due diligence is about identifying and mitigating against any potential risks, which is something we all have responsibility for.

I'm not an expert in Due Diligence, who can help me?

The Research Governance inbox is monitored daily by the University’s Research Integrity team who will liaise with Authorised Officers and key stakeholders as necessary.

The University’s Strategic Funding Managers play a key part in helping researchers complete Due Diligence processes as part of the research bid development and approval. Please contact the relevant person as early as possible in the bid development process, so that you have time to complete stage 1 of the Due Diligence process before the bid is submitted:

• College of Business and Social Sciences - SFM
• College of Engineering and Physical Sciences - SFM
• College of Health and Life Sciences - SFM
• Collaborations where the bid will be to Horizon Europe (regardless of College)

The University’s Business Development Managers will also be able to help researchers complete Due Diligence process as part of their bids for direct industry funding, Innovate UK, or KTPs. Please contact the relevant person as early as possible in the bid development process, so that you have time to complete stage 1 of the Due Diligence process before the bid is submitted:

• College of Business and Social Sciences – BDM
• College of Engineering and Physical Sciences – BDM
• College of Health and Life Sciences – BDM
• Technology Transfer Manager
• KTP Manager

Does Aston offer any Due Diligence training?

Yes, training is available on Blackboard. It will take 20-30 minutes to complete.

What are the risks of not conducting Due Diligence in respect of my international research collaborations? 

• Depending on the funder, withdrawal of funding and preventing from applying for future funding
• Reputational risk for the individual and/or institutional damage
• At institutional level, we make the distinction between colleagues who in good faith attempt to comply with the DD procedures, and those who deliberately bypass our DD procedures or deliberately mislead a senior member of management authorised to approve a relationship. 

Now I know I need to engage with the process, what do I do?

What do I need to do if I am Pl on a proposal which includes an overseas collaborator?

In line with our guidance on preparing a funding bid, please contact your Strategic Funding Manager or Business Development Manager as soon as possible, and at ideally at least eight weeks before the deadline for submission. . They will steward you through the process, including ensuring that the following stages are completed for each in scope partner:

• checks against open source databases of risk, 
• the Stage 1 (pre-award) questionnaire , 
• there is an audit trail of discussions and decisions regarding the partnership, and 
• institutional sign-off. 
   

Due diligence discussions can be complex and these stages must be completed before your bid can be submitted.

What do I do if I am a partner on a bid which includes overseas collaborators, but is being led from another institution?

If the bid is being led by a UK University, they will have similar processes in place to those at Aston. Please check that this is the case and that the PI is conducting due diligence through their institution. Please forward any paperwork to your SFM for inclusion on ARCP prior to the bid being submitted.

How will I know if Due Diligence checks have been completed and approved, and my bid can be submitted?

The SFM/BDM/GCO will keep you updated on different stages of the review process. 

If you are notified of a red the RAG rating is red youat any stage, you must not proceed with any further discussions with the partner unless a member of the University’s Executive gives written permission.

You will receive an email to confirm that the review process is complete, any mitigations that are required and when you can submit your bid. 

Stage 1 of the Due Diligence process needs to be completed for each relevant partner at least five working days before submitting your bid for approval/sign-off. You will receive an email to confirm that you can submit your bid.

Please be aware that failure to complete the due diligence process in good time could delay the submission of your bid. The RKE funding team will check that relevant documentation is in place as part of that process.

I have completed Due Diligence processes before for a research project with the same international partner. Do I need to do it again for a new project with the same partner? 

Yes: a collaborator’s situation may have changed since the previous Due Diligence checks were carried out. The nature of the research project will be different and may carry a different level of risk, and the value of the bid may be significantly larger or smaller. 

If you have completed the Stage 1 and Stage 2 Due Diligence Questionnaires previously, we will return these to you to review and edit with your partner. The updated Stage 1 Questionnaire must then be submitted to the full review process. 

My proposal was successful. what next?

I completed Stage 1 Due Diligence processes when I applied for funding, do I need to do anything else if the funding is awarded?

As soon as you have been notified of your award please notify the Awards and Contracts Specialist in RKE. Before you sign an agreement or contract you will need to complete the Stage 2 Due Diligence Questionnaire with each relevant partner.

You may wish to start preparing the Stage 2 questionnaire with your overseas partner(s) once the bid is submitted, which will save time if the bid is awarded. The Awards and Contracts Specialist, and GCOs will be able to help with this process.

I am conducting research with an overseas partner and went through Aston's Due Diligence processes at the beginning of the project. How frequently does this need revisiting? 

Due diligence must be carried out on existing arrangements as part of the renewal process of any agreement. In addition to regular reviews, due diligence on existing arrangements should be carried out when there is:

• A change in ownership of the outside party
• A merger with another organisation
• An incident which raises concerns about the financial status of the organisation
• A partner which has a collaborative arrangement with the University which then enters into another partnership which might impact the collaboration with the University
• Significant change in the nature of the arrangement with the outside party
• Relocation to a new country, or the activities with the University are to be managed from a different country
• A report from an external body which raises significant concerns about the standard of the work of the partner

I'm PI on an existing research award that includes international partners and I didn't go through the DD procedures at the point of application. What do I need to do?

Please get in touch with Research Governance as soon as possible. We will then direct your query to the right people with the expertise to help you.

Oversight and further information

At Aston, who has accountability and responsibility for International Due Diligence?

Accountability for due diligence processes as they relate to research and innovation lies with the University’s Authorised Officers:

• Research:
  • Authorised Officer – Director of Research Strategy, Funding and Impact
  • Executive Member responsible for scrutiny – PVC Research
• Innovation:
  • Authorised Officer – Director of Knowledge Exchange
  • Executive Member responsible for scrutiny – Executive Director, Business Engagement

Executive Deans and Associate Deans Research will also play an important part in reviewing proposed research and innovation collaborations.

All researchers have a personal responsibility to: 

• Review the Aston Due Diligence Procedures and understand the importance of undertaking Due Diligence on research collaborators, particularly overseas collaborators;
• Participate in the training that has been developed;
• Access the available guidance, and engage with your Strategic Funding Manager as early as possible when you are developing any bid that includes an overseas partner;
• Complete stage 1 of the Due Diligence process at least 5 days before submitting your bid for approval/sign-off;

Please get in touch and ask if you are unsure of anything – we want to make sure this process is as simple and easy as possible for you.

The Partnership Relations Committee is responsible for oversight of all due diligence decisions made at Aston University. The Committee meets monthly and its purpose is to ensure that there is an audit trail of Due Diligence decisions made and identify trends in due diligence decision-making both at Aston and in the Higher education Sector. 

Will there be a central record of due diligence reviews and their outcomes?

All Due Diligence paperwork conducted for a particular project will be saved with the application record in ARCP.

The University’s Partnership Relations Committee has responsibility for maintaining a central record of all applications and decisions relating to the Due Diligence process. It will also keep a log of approved partnerships. This will give University Executive oversight of the decisions that have been made and identify trends of approvals and rejections.

The Partnership Relations Committee will be able to provide advice about whether prior approvals have been sought with a particular entity, and what decisions were made. In addition to logging approved activities the log will contain a record of activities that have not been approved and the reasons for the rejection.

Where can I find additional resources, information about Due Diligence as it applies to research?

Aston University Outside Party Due Diligence Procedures

Aston University online Due Diligence Training

Aston Policies and Principles repository

ARMA - Updated UKRI-Approved Due Diligence Questionnaire And Guidance

National Protective Security Authority - Trusted Research Guidance for Academia

Companies House - Find company information etc

List of proscribed terror groups or organisations

Current list of persons and entities to whom financial sanctions have been applied due to their assessed involvement in terrorist activity. 

The Higher Education Export Controls Association (HEECA)

Page last updated on: 10/11/2023 (DH)