Research misconduct

The concordat to support research integrity defines misconduct as:

'behaviour or actions that fall short of the standards of ethics, research and scholarship required to ensure that the integrity of research is upheld.' 

This includes fabrication, falsification, plagiarism or deception in performing or reviewing research, and in reporting research outputs.

We use the concordat’s definition of research misconduct, and we expect the organisations we fund to do the same. Read the concordat to support research integrity on the Universities UK website.

Research misconduct can include:

• omitting relevant data
• manipulating images
• misusing data by deliberately attempting to re-identify people from research data

It does not include:

• honest differences in the design, execution or interpretation in evaluating research methods or results
• research of poor quality, unless this encompasses the intention to deceive
   

We expect all participants involved in Wellcome funding to follow our guidelines on the responsible conduct of research and other Wellcome grant funding policies, such as bullying and harassment.

Participants include:

• grantholders
• co-investigators
• sponsors and supervisors
• research staff
• students
• fieldworkers
• collaborators
• consultants
• sub-awardees
• Wellcome advisory committee members

We expect research organisations in the UK to follow the Universities UK concordat to support research integrity.

Organisations outside the UK should follow appropriate guidelines of a similar standard, such as the Singapore statement on research integrity.

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 research misconduct 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 Research Funding, 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 standards of behaviour it expects from staff
• their procedure for handling allegations, including a first point of contact.

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. Ensure any relevant privacy statement permits the sharing of data in accordance with this policy and that all grant participants have read and are aware of the potential for information sharing. 

4. Investigate allegations of research misconduct in an impartial, fair and timely manner. It must:

• protect the rights of all employees involved
• take appropriate action.

The UK Research Integrity Office’s recommend procedure for investigation provides a detailed model that may be helpful to organisations in and outside the UK.

5. Tell Wellcome’s Director of Research Funding, when a formal investigation has been opened into an allegation of research misconduct. This should include information on the category of research misconduct and the investigation process. 

If there is a full investigation, the organisation must tell Wellcome the name of the respondent, in confidence.

This applies to any employee at the organisation who is associated with:

• a grant application under consideration (either as a lead applicant, sponsor or supervisor)
• a Wellcome grant (see our list of participants above)
• a Wellcome advisory committee

6. Keep Wellcome informed during the investigation process. Investigations should conclude within one year of receiving the allegation.

7. Contact Wellcome’s Director of Research Funding again when the investigation has been completed and any final appeal has been heard, and provide us with the final investigation report. This should confirm:

• if the allegation was upheld
• the findings of the investigation
• if any sanctions are being imposed

Wherever possible, organisations should see an investigation through to its conclusion. This includes:

• applying any disciplinary procedures
• documenting the findings

While we recognise that the requested disclosures under this policy may include personal data, we consider that we have a legitimate interest in receiving and handling this data.

This requires us to undertake a balancing test to ensure that there are no unwarranted adverse effects on the individual. 

UK data protection legislation does not prevent the sharing of this data. Whilst we recognise that often information is confidential in nature due to the employment relationship, Wellcome maintains the quality of confidence where allegations are under investigation and there is no immediate risk of harm to others. 

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:

• reduce risk to the project and/or
• reduce the impact on other people who would be involved in the project, including newly recruited postdoctoral researchers or support staff

After an award has been made, the organisation must tell us when a formal investigation into research misconduct has been opened. This is so that we can:

• monitor that complaints are being dealt with appropriately and in a timely manner
• make sure that grantholders receive the support they need, and
• be aware of the potential impact on Wellcome-funded activities and the steps being taken to manage that impact

The information you send us at any point should not include:

• sensitive personal information (such as special category personal data, as defined in UK Data Protection Law) or information relating to criminal offences or convictions
• personal details about other people, such as the person making the claim

Any information you send to us will be:

• Handled in confidence and in accordance with data protection law requirements.
• Kept in a secure, restricted-access location, with access restricted to the following Wellcome staff who are directly involved in the management of these cases:
  • Director of Research Funding
  • Associate Director, Funding Operations and Governance
  • Funding Policies Manager
  • Funding Policies Adviser.
• Communicated only to other Wellcome staff on a need to know, restricted access basis, where necessary, to pursue our legitimate interests as a funder. This includes making sure that:
  • We can access legal advice.
  • Grantholders get the support they need from Wellcome
  • The outcomes of Wellcome-funded grant activities are not at risk.
  • We are able to monitor the number of outstanding cases. The Board of Governors is responsible for safeguarding and the Audit and Risk Committee review anonymised data relating outstanding cases on a regular basis.
• Not communicated to expert reviewers or panel members.
• Kept by us for no longer than we need it for our legitimate purposes, in line with our retention policy. Where an allegation is not upheld, we will retain the information for no more than five years after the outcome. Where an allegation is upheld, we will retain the information for no more than ten years after the outcome, unless the sanction is still in place.
• Communicated to other organisations only where the grant is co-funded by them.

Allegations of research misconduct 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:

• first discuss the circumstances with the informant
• then tell an appropriate individual at the organisation if the individual is unwilling or unable to report the allegation directly to the organisation

We will respect an informant’s wish to remain anonymous, unless:

• we have a legal obligation to reveal their identity
• it is impossible to maintain anonymity to conduct an investigation

We will tell the informant if we need to reveal their identity.

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 advisors on a need-to-know basis.

If an organisation upholds a research misconduct 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:

• Send a letter of reprimand.
• Remove the grantholder/sponsor from the affected grant(s).
• Withdraw funding from the grantholder/sponsor. We will work with the organisation to minimise the impact on any staff working on the affected grant(s), which may include transferring the grant to another suitable investigator to allow the work to be completed. Where appropriate, this may be for up to 12 months after the funding has been formally withdrawn from the grantholder. This applies to all Wellcome grants.
• Temporarily or permanently restrict them from future grant applications (or specific types of grant applications).
• Require the withdrawal or correction of pending or published abstracts, papers or monographs produced by the research that has been under investigation.
• Require training and/or the monitoring of future work.

Where allegations of research misconduct 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:

• respond to a research misconduct complaint promptly and objectively
• keep Wellcome informed (as outlined in the what we expect from the organisations we fund section above)

Sanctions we apply against organisations may include:

• not accepting new grant applications for a limited period of time
• suspending funding to the organisation in extreme cases

We do not carry out our own investigations, but where we have a legitimate interest to, we may: 

• ask for information about an organisation's processes
• check that an organisation has a policy and is following it
• ask for a copy of the final investigation report

Where we seek 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.

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 change 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 ten years of the alleged misconduct having taken place.

This policy was last updated in November 2023.