Award Policies (contd.)

The India Alliance expects its Grantholders to adhere to the highest standards of integrity. To facilitate this, it provides guidelines on good research practice and a statement on the handling of allegations of research misconduct. Organisations are expected to have in place their own published standards of good research practice and formal written procedures for the investigation of allegations of research misconduct.

 

1. Introduction

The India Alliance cannot be prescriptive about individual approaches taken by its Grantholders to solving particular research problems. But it expects organisations to ensure that an adequate structure exists to promote and promulgate good research practice, emphasising integrity and rigour in research, and to create a culture in which the following general principles can be understood and observed.

 

2. Integrity

  • Grantholders should be honest in respect to their own actions in research and in their responses to the actions of other researchers. This applies to the whole range of research work, including experimental design, generating and analysing data, applying for funding, publishing results, and acknowledging the direct and indirect contribution of colleagues, collaborators and others.
  • Plagiarism, deception or the fabrication or falsification of results should be regarded as a serious disciplinary offence.
  • Grantholders are encouraged to report cases of suspected misconduct and to do so in a responsible and appropriate manner.
  • Grantholders should declare and manage any real or potential conflicts of interest.

 

3. Openness

  • While recognising the need for scientists to protect their own research interests, the India Alliance expects its Grantholders to be as open as possible in discussing their work with other scientists and with the public in order to help foster an informed public climate within which biomedical science can flourish.
  • Once results have been published, the India Alliance expects its Grantholders to make available relevant data and materials to other researchers, on request, provided that this is consistent with any ethics approvals and consents that cover the data and materials and any intellectual property rights in them.
  • The India Alliance recognises that publication of the results of research may need to be delayed for a reasonable period pending protection of intellectual property arising from the research. Any such periods of delay in publication should, however, be kept to a minimum.

 

4. Guidance from professional bodies

  • Where available, the India Alliance expects its Grantholders to observe the standards of research practice set out in guidelines published by scientific and learned societies, and other relevant professional bodies.
  • All Grantholders should be aware of the legal requirements that regulate their work.

 

5. Leadership and cooperation

  • Heads of organisations and their senior colleagues should ensure that a research climate of mutual cooperation is created in which all members of a research team are encouraged to develop their skills and in which an open exchange of ideas is fostered.

 

6. Supervision

  • Organisations should ensure that they provide an appropriate direction of research and supervision of researchers. Training in supervisory skills should be provided where appropriate.
  • A code of responsibilities should be available for supervisors indicating, for example, the frequency of contact, responsibilities regarding scrutiny of primary data, and the broader development needs of research trainees.
  • The need should be stressed for supervisors to supervise all stages of the research process, including outlining or drawing up a hypothesis, preparing applications for funding, protocol design, data recording and data analysis.

 

7. Training

  • Organisations should have in place systems that allow students and new researchers to understand and adopt best practice as quickly as possible.
  • All Grantholders should undertake appropriate training, for example in research design, regulatory and ethics approvals and consents, equipment use, confidentiality, data management, record keeping and data protection.

 

8. Primary data/samples

  • At the start of the research programme and where relevant, there should be clarity on the ownership of:
    • - Data and samples used or created in the course of the research
    • The results of the research
  •  Grantholders should keep clear and accurate records of the procedures followed and the approvals granted during the research process, including records of the interim results obtained as well as of the final research outcomes. This is necessary not only as a means of demonstrating proper research practice, but also in case questions are subsequently asked about either the conduct of the research or the results obtained.
  • Data generated in the course of research should be kept securely in paper or electronic format, as appropriate. The India Alliance considers a minimum of ten years to be an appropriate period, but research based on clinical samples or relating to public health might require longer storage to allow for long-term follow-up to occur.
  • Back-up records should always be kept for data stored on a computer.
  • Organisations should have guidelines setting out responsibilities and procedures for the storage, use and disposal of data and samples (including compliance with the requirements of any ethics committee)

 

9. Ethical practice

9.1 Research involving human participants

  • Approval is required from an appropriate ethics committee for all research funded by the India Alliance involving human participants or biological samples. Approval should also be sought from other appropriate regulatory bodies as required by the law of the land.
  • Grantholders should ensure the confidentiality of personal information relating to the participants in research, and that the research fulfils all legal requirements.

 

9.2 Research involving animals

  • Research involving animals should have approval through the appropriate ethical review process and must be fully compliant with all local legislations and rules.
  • Grantholders should consider, at an early stage in the design of any research involving animals, the opportunities for reduction, replacement and refinement of animal involvement (the three Rs).

 

9.3 Risks of research misuse

  • In progressing their scientific investigations, Grantholders should actively consider any risks that their research will generate outcomes that could be misused for harmful purposes. Where such risks exist, they should seek advice and take active steps to minimise them.
  • Organisations should have in place mechanisms to ensure that risks of misuse associated with ongoing research programmes are identified and managed, and to provide advice to the researchers that they employ on these issues.

 

10. Publication practice

  • Results should be published in an appropriate form, usually as papers in refereed journals, with copies being made available Europe PubMed Central (Europe PMC) as soon as possible and within or immediately after six months of the journal publisher’s official date of final publication. For more details please refer to Policy on open and unrestricted access to published research.
  • Anyone listed as an author on a paper should accept responsibility for ensuring that he/she is familiar with the contents of the paper and can identify his/her contribution to it. The practice of honorary authorship is unacceptable.
  • The contributions of formal collaborators and all others who directly assist or indirectly support the research should be properly acknowledged.
  • To assist the India Alliance in tracking the outputs of research to which it has contributed either wholly or in part, the India Alliance’s contributions must be acknowledged in proper format in all publications.

 

India Alliance is committed to keeping highest legal and ethical standards and expects all staff/employees, fellows and other persons representing it or acting on its behalf to uphold this commitment. In accordance with this commitment, it has adopted the following policies, which are applicable to all Trustees, management, staff/employees, grant holders/fellows, representatives and persons authorized to deal in the name of India Alliance (“India Alliance Associates” or “IA Associates”).

The India Alliance identifies integrity, openness and partnership as key values; this statement has been produced and is intended to be applied in line with those values. The expectation is that the necessity to invoke these procedures would be rare but that by following these general principles the process of investigating allegations of research misconduct will be a fair process that protects the interests of all the parties involved.

 

Throughout this statement:

  • 'CEO' means the Chief Executive Officer of the India Alliance
  • ‘COO’ means the Chief Operating Officer of the India Alliance
  • 'Organisation' means any organisation in receipt of India Alliance funds
  • 'The India Alliance’ means the Wellcome Trust/DBT India Alliance, a public charitable trust established under the laws of India that provides support for high-quality biomedical research and seeks to promote basic and applied research.
  • 'Grantholder(s)’ or ‘Fellow(s)’ means recipients of India Alliance funding, including salaried researchers and non-India Alliance-salaried researchers in receipt of funds in any form from the India Alliance in order to advance their research.

 

1. Definitions of research misconduct and other misconduct

1.1 Research misconduct is defined as:

The fabrication, falsification, plagiarism or deception in proposing, carrying out or reporting results of research or deliberate, dangerous or negligent deviations from accepted practices in carrying out research. It includes failure to follow established protocols if this failure results in unreasonable risk or harm to humans, other vertebrates or the environment and facilitating of misconduct in research by collusion in, or concealment of, such actions by others. It also includes intentional, unauthorised use, disclosure or removal of, or damage to, research-related property of another, including apparatus, materials, writings, data, hardware or software or any other substances or devices used in or produced by the conduct of research.

It does not include honest errors or honest differences in the design, execution, interpretation or judgement in evaluating research methods or results or misconduct unrelated to the research process. Similarly, it does not include poor research unless this encompasses the intention to deceive.

 

1.2 Bribery and Money Laundering

IA will not tolerate money laundering, bribery, kickbacks, or corruption of any kind, directly or through third parties, whether or not explicitly prohibited by this policy or by law. IA Associates are not permitted to give or offer anything of value (including gifts, hospitality, or entertainment) to anyone for the purpose of improperly obtaining or retaining a business advantage. Similarly, India Alliance Associates may not solicit or accept such improper payments or involve in money laundering.

Responsibilities

India Alliance Associates must conduct their activities in full compliance with this policy and any applicable anti-corruption and money laundering laws, including but not limited to the Prevention of Corruption Act, 1988 (“PCA”). The policy is to ensure that there is no violation of the PCA or other applicable anti-corruption or money laundering laws and any provision of this policy by the India Alliance Associates.

Under this policy, India Alliance Associates are not permitted to give or offer anything of value, directly or indirectly, to any Public Servant (as defined under the PCA and will have the same meaning through the policy) or any commercial party for the purpose of improperly obtaining or retaining a business advantage, or involve in money laundering.

For purposes of better understanding this policy, “anything of value” shall broadly be interpreted to include cash, gifts to family members, forgiveness of a debt, loans, personal favors, entertainment, meals and travel, political and charitable contributions, business opportunities and medical care, among other items. Simply put, bribes, kickbacks or similar payments are never permitted, whether made to a public servant or to customers, investors, clients or other private parties. Similarly, India Alliance Associates may not solicit or accept such payments.

The policy does not form part of the contract of employment or grant award (except and to the extent that a policy or procedure is implied by law) and can be withdrawn, amended or replaced at any time.

 

1.3 Policy on Harassment and Bullying

The India Alliance is committed to providing a safe and productive working environment, where all India Alliance Associates are treated with dignity and respect.

Accordingly, the India Alliance will not condone any form of harassment. Harassment can include bullying, intimidation or other forms of behaviour that can lead to victimisation, and can be on the grounds of gender, marital status, sexual orientation, race, colour, ethnic origin or nationality, religion or belief, disability or age. Such behaviour may be unlawful and can have long-term effects on the morale and well-being of individuals.

This policy covers all India Alliance Associates. It applies not only to interaction whilst at the Institution office and premises, but also extends to time spent out of the office whilst on business and at social events during the course of their employment or grant award.

The policy does not form part of the contract of employment or grant award (except and to the extent that a policy or procedure is implied by law) and can be withdrawn, amended or replaced at any time.

 

1.4 Policy on Prevention on Sexual Harassment (POSH)

India Alliance is committed to creating a safe and healthy working environment. India Alliance believes that all individuals have the right to be treated with dignity and shall strive to create a workplace which is free of Sexual Harassment. Sexual Harassment at the workplace or any other place if involving an India Alliance Associate is a grave offence and is strictly prohibited and punishable by law.

India Alliance approaches any form of Sexual Harassment with zero tolerance. IA does not in any manner support or condone an India Alliance Associate who sexually harasses any other person.

 

1.5 Whistle Blower Policy

India Alliance has endorsed the provisions set out below to ensure that India Alliance Associates are not disadvantaged if they wish to raise legitimate concerns regarding their workplace.

India Alliance is committed to the highest standards of integrity, openness and probity and this policy provides a mechanism by which India Alliance Associates can voice their concerns in a responsible and effective manner.

The policy does not form part of the contract of employment or grant award (except and to the extent that a policy or procedure is implied by law) and can be withdrawn, amended or replaced at any time.

 

Scope of Policy:

The aim of this policy is to assist India Alliance Associates (“Whistle Blower”) should they believe they have discovered serious malpractice, wrongdoing or impropriety, to disclose this information internally without fear of reprisal.

It is intended to cover the disclosure of concerns, which are in public interest and which may, at least initially, require to be investigated separately but might then lead to action through other procedures (for example, the disciplinary procedure, criminal prosecution, etc). Besides the ones mentioned earlier these disclosures may include:

  • Bribery, corruption and money laundering
  • Financial malpractice or impropriety or fraud
  • Failure to comply with a legal obligation or statutes,
  • Endangering the health and safety of any person or the environment
  • Criminal activity or breaches of civil law
  • Unethical behaviour or improper conduct
  • Deliberate attempts to conceal any of these

 

The policy is not designed to question financial or business decisions taken by the IA nor may it be used to reconsider any matters, which have already been addressed under harassment, grievance, complaint, disciplinary or other relevant procedures.

Safeguards:

This policy is designed to offer protection to the Whistle Blower who discloses concerns, provided the disclosure is made: (a) in good faith; (b) in the reasonable belief that it tends to show malpractice or impropriety; and (c) to the appropriate person detailed in this policy.

Confidentiality:

The IA will treat all disclosures in a confidential and sensitive manner. The identity of the Whistle Blower may be kept confidential if it does not hinder or frustrate any investigation. However, in using the procedure, the Whistle Blower should be aware that the investigation process may, by necessity, reveal the source of the information and the Whistle Blower should be willing to provide a statement as part of the evidence required.

Anonymous Allegations:

The Whistle Blowers are encouraged to put their name to any disclosures they make since concerns expressed anonymously appear much less credible. Anonymous disclosures may be considered at the discretion of the IA. In exercising this discretion, the factors to be taken into account will include: (a) the seriousness of the issues raised; (b) the credibility of the concern; and (c) the likelihood of confirming the allegation from other sources.

Untrue Allegations:

If the Whistle Blower is an IA Associate, who happens to make an allegation in good faith, which is subsequently not confirmed by an investigation, no action will be taken against that person. In making a disclosure, the Whistle Blower is expected to exercise due care in ensuring the accuracy and validity of the information. If an IA Associate makes malicious or vexatious allegations, and particularly if these are persistently made, then further action (including disciplinary action) may be taken, if he is a staff member or appropriate recommendations will be made to the relevant organisation.

 

Procedures for Making a Disclosure:

Details of the disclosure should be forwarded as follows:

  • In the first instance, the disclosure should be forwarded to the [email protected], or to the COO or where the disclosure is in any way related to his/her actions, to the CEO.
  • Should the disclosure relate to the actions of the CEO, it should be forwarded to the Trustees.
  • Where the disclosure relates to the actions of a Trustee or the Board of Trustees, it should be referred to the stakeholders of the IA.

 

2. Responsibilities of the organization

2.1 The India Alliance considers it the responsibility of the organisation to investigate all allegations of misconduct made against its staff and awardees. Findings of misconduct may be matters for consideration under the organisation's disciplinary procedures.

2.2 Organisations will need to give consideration to the procedures that will apply to visiting researchers while based in the organisation and the organisation’s staff while based in another organisation.

2.3 It is the responsibility of the organisation to inform the CEO/COO, in confidence, at the earliest opportunity, about allegations of serious research misconduct/other misconduct that concern Grantholders where it seems that there are reasonable grounds to believe that the allegation may be substantiated on investigation. It is at the discretion of the organisation to determine what constitutes 'serious misconduct'. The organisation is also responsible for informing the CEO/COO of the outcome of any such investigation.

2.4 It is the responsibility of the organisation to inform the CEO/COO, in confidence, of all instances of research misconduct/other misconduct involving Grantholders that have resulted in the allegations being substantiated.

2.5 The organisation should have in place a policy statement relating to the treatment of Whistle Blowers, including a clear statement that research misconduct is taken seriously in the organisation and that any member of staff raising bona fide concerns can do so confidentially, and without fear of suffering any detriment. The statement should include a clear indication of the procedures in which such bona fide concerns by staff may be brought to the attention of a designated individual within the organisation.

 

3. Principles for investigation by organisations of allegations of research or other misconduct

Each organisation must have in place formal written procedures for dealing with allegations of research misconduct against its staff and students. Organisations should, where appropriate, take legal advice on implementing these procedures to ensure that the procedures comply with all legal obligations for the conduct of such investigations from time to time in force.

Organisations should endorse the following principles when implementing these procedures:

  • The responsibilities of those dealing with the allegation should be clear and understood by all interested parties.
  • Measures should be in place to ensure an impartial and independent investigation and to ensure that line management obligation or other interests of those dealing with the allegation do not conflict with these procedures.
  • Those undertaking research at the organisation should be contractually obliged to participate in and comply with the procedure.
  • The organisation should consider the confidential nature of the investigation and how to safeguard the rights to confidentiality of the interested parties.
  • All interested parties should be informed of the allegation at an appropriate stage in the proceedings.
  • Anyone accused of misconduct should have the right to respond.
  • A policy should be in place to ensure that no employee who makes an allegation in good faith against another employee shall suffer a detriment, but equally that disciplinary procedures are in place to deal with malicious allegations.
  • The allegation should be dealt with in a fair and timely manner.
  • Proper records of the proceedings should be kept.
  • The outcome should be made known as quickly as possible to all interested parties.
  • Anyone found guilty of misconduct should have the right to an appeal.
  • Appropriate sanctions and disciplinary procedures should be in place for cases when the allegation is upheld.
  • If appropriate, efforts should be made to restore the reputation of the accused party if the allegation is dismissed.

 

4. Receipt of allegations at the India Alliance

The India Alliance recognises that there may be instances where an allegation of research misconduct or any other misconduct is made directly to a member of the India Alliance’s staff or the CEO/COO rather than to an individual within the organisation. In such instances, the CEO/COO will contact an appropriate individual at the organisation and the

 

5. Investigations by the India Allia

As stated above, it is the organisation’s responsibility to investigate allegations of research misconduct or any other misconduct made against its staff and students and this would be the India Alliance’s preferred course of action in most cases. In exceptional cases, however, the India Alliance may wish to undertake its own investigation into alleged cases of research misconduct that concern Grantholders (for example where the India Alliance’s reputation is at risk or where the India Alliance is dissatisfied with the investigation undertaken by the organisation). Generally, any investigations by the India Alliance would only be undertaken following consultation between the CEO/COO and the appropriate representative(s) of the organisation.

 

6. Sanctions

If the organisation or the India Alliance determines that the allegation of research misconduct is substantiated, the India Alliance may consider appropriate sanctions. These may include, but are not restricted to:

  • A letter of reprimand
  • The withdrawal of funding
  • Requiring the withdrawal or correction of pending or published abstracts and papers emanating from the research in question
  • Changes to the staffing of the particular project
  • Special monitoring of future work
  • Barring the Grantholder from applying for India Alliance funds for a given period
  • Repayment of grant plus interest at the India Alliance’s discretion
  • Discussion with the organisation on the implementation of appropriate disciplinary procedures.

At all times, in line with its Award conditions, the India Alliance reserves the right to withdraw funding with immediate effect.

 

7. Indemnity

The Grantholder and Host Institutions will indemnify, defend and hold harmless India Alliance, its trustees, employees and agents (“Indemnified Parties”) from and against any and all demands, claims, actions, suits, losses, damages (including property damage, bodily injury and wrongful death), arbitration and legal proceedings, judgments, settlement or costs or expenses (including reasonable attorneys’ fees and expenses) (collectively, “Claims”) arising out of or relating to the acts or omissions, actual or alleged, committed by Grantholder and/or Host Institution. The Grantholder and/or Host Institutions agree that any activities by the India Alliance in connection with the Award, such as its review or proposal of suggested modifications to the Fellowship, will not modify or waive the India Alliance’s rights under this paragraph. An Indemnified Party may, at its own expense, employ separate counsel to monitor and participate in the defence of any Claim.