We consider bullying and harassment of any kind, in any context, to be unacceptable. We believe that all people working at Wellcome or involved in Wellcome-funded activities should be able to work in an environment where everyone is treated, and treats others, fairly and with respect.
Bullying is any offensive, intimidating, malicious or insulting behaviour. It involves the misuse of power and can make the person being bullied feel vulnerable, upset, humiliated, undermined or threatened.
Harassment is any unwanted physical, verbal or non-verbal conduct that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. It may be persistent or a single incident.
When an organisation submits a grant application to us, they must confirm that the lead applicant (and sponsor and supervisor if relevant), has not had an allegation of bullying or harassment upheld against them for which there is either a current formal disciplinary warning or an active sanction.
If they have, we may reject the application. In such circumstances we encourage potential applicants to contact Wellcome's Director of Grants, in confidence, to discuss their situation before they apply.
We recommend that the organisation’s application submission sign-off process includes someone who would be aware of any such warning or sanction. If the applicant has been at the organisation for less than 12 months, we expect the organisation to check with the previous employer.
It is the organisation’s responsibility to:
1. Have a policy in place that clearly sets out:
The policy should be available to all staff and ideally published on the organisation’s intranet.
2. Make sure there is an equivalent policy in place at any sub-awardee organisation. If this is a problem, contact us for advice.
3. Investigate allegations of bullying and harassment in an impartial, fair and timely manner. It must:
4. Tell Wellcome’s Director of Grants when a formal investigation has been opened into an allegation of bullying or harassment. This should include a brief factual statement about the nature of the allegation. For example, bullying of junior staff members in a research group.
We reserve the right to ask for the name of the employee whose conduct is being investigated, where we consider that we have a legitimate interest in doing so.
This applies to any employee at the organisation who is associated with:
5. Keep Wellcome informed during the investigation process. Investigations should conclude within one year of receiving the allegation.
6. Contact Wellcome’s Director of Grants again when the investigation has been completed and any final appeal has been heard. This should confirm:
We reserve the right to request a copy of the investigation report, where we consider that we have a legitimate interest in doing so.
Wherever possible, organisations should see an investigation through to its conclusion. This includes:
While we recognise that the requested disclosures under this policy may include personal data, we consider that we have a legitimate interest handling this data.
During the application stage, we need to be aware of upheld allegations or those currently under investigation, so that we can make responsible funding decisions. Informing us about an investigation will not affect how we process or review an application, but we may, for example, delay issuing an award until an investigation is completed. This is to:
After an award has been made, the organisation must tell us when a formal investigation into bullying or harassment has been opened. This is so that we can:
The information you send us at any point should not include:
Any information you send to us will be:
If an organisation upholds a bullying or harassment allegation, we may apply our own sanctions. Sanctions may vary in length, depending on the seriousness of the case and any remedial action already in place.
These will be independent of any set by the organisation. We may:
Where allegations of bullying or harassment are upheld, we expect organisations to implement appropriate disciplinary procedures.
We may apply sanctions against a Wellcome-funded organisation if we find that it has failed to:
Sanctions we apply against organisations may include:
Allegations of bullying and harassment should always be reported to the employing organisation of the person against whom the allegation is being made. It is the organisation’s responsibility to investigate, not Wellcome’s.
If an allegation is made directly to a member of Wellcome staff rather than to the employing organisation, we will:
We will respect an informant’s anonymity, unless we have a legal obligation to reveal their identity. We will tell the informant if we are required to do this.
The employing organisation is then responsible for following its own allegation procedures.
We will reserve any judgement about an allegation until the investigation is complete. We will only provide information to our staff or external advisers on a need-to-know basis.
We do not carry out our own investigations, but reserve the right to:
This may be done as part of our organisation audits.
If an investigation has been completed and an individual has concerns about the process, Wellcome will ask the organisation to confirm that it has adhered to its published policy. We are not able to challenge the outcome of the investigation.
Formal allegations, reports of allegations or complaints about process, should be reported to Wellcome, as outlined in this policy, and within five years of the alleged incident or onset of bullying or harassing behaviour.
Where we exercise our right to see the above information, we expect organisations to be able to share it. We strongly discourage the inappropriate use of non-disclosure agreements that might prevent organisations from sharing this information with us.