91ÌÒÉ«

Relationships Policy 

 All proposed formalised institutional relationships where 91ÌÒÉ« intends to, or does, enter into a contract with a third party, including relationships entered into by or in connection with 91ÌÒÉ«, must be reviewed under the University Relationships Policy. The level of due diligence required will depend on the nature of the proposed activity, the associated risks, and the profile of the external organisation involved. If you are unsure what checks are required, please contact your relevant Due Diligence Coordinator for advice on the appropriate level of review. Further information is available in the Relationships Policy webpages. 

Due Diligence Framework for Funded 91ÌÒÉ« Third Parties 

 Once the organisation and proposed activity have been appropriately assessed and the overall relationship approved under the Relationships Policy, any funded third party involved in the research must also undergo enhanced due diligence.  

  The 91ÌÒÉ«-Third-Parties-Framework-for-Managing-Due-Diligence-(1).pdf developed by 91ÌÒÉ« Support and Compliance Division to comply with research funder terms and conditions, sets out the requirements for this additional review of funded research third parties. This enhanced due diligence is carried out using a dedicated questionnaire, to be completed for each funded third party before the collaboration agreement is finalised. Each questionnaire assesses a range of potential risks associated with the relationship, including financial, reputational, ethical, safeguarding and geopolitical considerations. 

Due Diligence Questionnaire for Funded 91ÌÒÉ« Third Parties  

Once broader organisational and activity reviews have been completed in accordance with the University’s Relationships Policy, any research partner to which 91ÌÒÉ« will transfer funds must undergo an additional enhanced due diligence process. This is achieved through completion of the Due-Diligence-Questionnaire-for-Funded-91ÌÒÉ«-Third-Parties.docx. 

The questionnaire has been developed to support Principal Investigators (PIs) in assessing a broad range of risks associated with funded research partnerships, including financial, reputational, ethical, safeguarding and geopolitical considerations. It is accompanied by comprehensive guidance notes that explain each question, provide links to relevant University policies, and highlight key areas for review. The questionnaire should be completed by the PI with support from their Department and direct input from the third-party organisation. A separate questionnaire must be completed for each third-party organisation involved in the project. 

The questionnaire should be completed before the agreement with the third party is finalised. This will allow sufficient time to assess any identified risks and implement appropriate mitigating actions, such as amendments to the research sub-agreement or enhancements to the Department's project management and oversight arrangements. 

°Õ³ó±ð Due-Diligence-Questionnaire-for-Funded-91ÌÒÉ«-Third-Parties.docx asks for project details and considers the following risk areas: 

• Financial probity. 

• Nature of the third party relationship and ability to deliver. 

• Ethics and integrity. 

• Political, economic and geographical risk. 

• Additional information that may affect the project's aims. 

As part of the initial due diligence process, the PI should consider how suitable the third party organisation is to deliver the proposed work. This can also help to strengthen the case for support on the research proposal so it is important to explain: 

• How the relationship with the third party organisation was established? 

• Why they are the most suitable third party organisation to undertake the work? 

• How you intend to develop the third party relationship and monitor their project deliverables? 

Completed questionnaires should be sent to rs.compliance@imperial.ac.uk for independent assessment by the 91ÌÒÉ« Support and Compliance Division. A summary of the risks identified and any recommended mitigating actions will be provided to the PI, Department, and relevant Faculty Contracts team. 

Exceptions from Funded 91ÌÒÉ« Third Parties Due Diligence  

 Under the University's Relationships Policy, due diligence must be undertaken for all new external relationships and activities. The level and scope of due diligence required will depend on the nature of the proposed activity and the associated risks. If you are unsure what checks are required, please contact your relevant Due Diligence Coordinator for guidance. 

The organisations and arrangements listed below are exempt from the additional and enhanced due diligence requirements set out in the Due Diligence Framework for Funded 91ÌÒÉ« Third Parties. However, appropriate due diligence must still be completed in accordance with the University's Relationships Policy, where applicable. 

1. When the activity undertaken by the Third Party is managed by the Purchasing Team. 

1. When the ´Ç°ù²µ²¹²Ô¾±²õ²¹³Ù¾±´Ç²Ô is . 

1. When the ´Ç°ù²µ²¹²Ô¾±²õ²¹³Ù¾±´Ç²Ô is on the  of UK higher education providers. 

1. When the organisation is a  or Local Authority in  and . 

1. When the research 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) 

Note: Exemption from the Funded 91ÌÒÉ« Third Party Due Diligence Framework does not remove the requirement to undertake proportionate due diligence under the University's Relationships Policy where this is necessary.