Dear Vice-Chancellor or Principal
Compliance with the Concordat to support research integrity
1. This letter clarifies the requirement for institutions to comply with the Concordat to support research integrity. It sets out HEFCE’s view of compliance with the Concordat, and provides advice for institutions on finding further information.
2. The guidance set out in this letter has been agreed by the other signatories of the Concordat, listed below, as represented on the Concordat working group. Our expectations are therefore aligned with those of the other research funders and organisations that are signatories to the Concordat.
3. Signatories to the Concordat:
- Department for Employment and Learning
- Higher Education Funding Council for England
- Higher Education Funding Council for Wales
- National Institute for Health Research
- Research Councils UK
- Scottish Funding Council
- Universities UK
- Wellcome Trust.
4. The requirement will be introduced as a condition of HEFCE grant from 2013-14, for institutions eligible to receive HEFCE funding for research. This follows our consultation ‘Research integrity concordat: Consultation on proposed implementation from 2013-14’ (HEFCE 2012/32), the outcomes of which are published on the research integrity section of our web-site). The funding agreements for 2013-14 therefore state:
‘The institution is required to comply with the Concordat to Support Research Integrity published by Universities UK in July 2012 […] Institutions in receipt of research grant from the Council are also required to provide assurance of their compliance with the Concordat through the annual assurance return to the Council and following any guidance that the Council may provide. For 2013-14 only, in recognition that compliance by some institutions may require a period of time to achieve, institutions in receipt of research grant from the Council may provide assurance either of their compliance, or that they are working towards compliance, with the Concordat.’
5. Institutions will be asked to confirm their compliance with the Concordat in the annual assurance statement, which will be subject to routine audit. Institutions will not be required to provide additional evidence in the assurance return. We will additionally monitor the implementation of the concordat through the information shared by other funders at the integrity working group (see paragraph 13).
6. Respondents to the consultation asked for clarity in the definition of key terms. Our definition of the terms ‘research integrity’ and ‘research misconduct’ follow those set out in the Concordat on pages 11 and 17 respectively.
7. The Concordat sets out five commitments for assuring high standards and integrity in research, and outlines the responsibilities of researchers, employers of researchers, funders of research and other organisations in fulfilling each commitment.
8. We understand compliance with the Concordat to mean that institutions, as the employers of researchers, will act in accordance with the commitments and the related responsibilities for employers of researchers as outlined in the Concordat. This includes fulfilment of the expectations held by funders of research for employers of researchers, where these are stated in the Concordat.
9. We recognise and value the autonomy of institutions, and the diversity of organisational and operational structures in the higher education sector. It is not our intention to set out how each commitment and responsibility should be fulfilled, but to recognise that each institution is best placed to develop its own most appropriate approach.
10. Paragraphs 11 and 12 reference the first commitment set out in the Concordat, and the related responsibilities, to illustrate our understanding of compliance as set out in paragraphs 7 to 9.
11. The first commitment states: ‘We are committed to maintaining the highest standards of rigour and integrity in all aspects of research’ (Concordat, p11). To act in accordance with this commitment, institutions will fulfil the related responsibilities for employers of researchers, which are outlined as follows:
‘Employers of researchers are responsible for:
- collaborating to maintain a research environment that develops good research practice and nurtures a culture of research integrity, as described in commitments 2 to 5
- supporting researchers to understand and act according to expected standards, values and behaviours, and defending them when they live up to these expectations in difficult circumstances.’
12. They will also meet the research funders’ expectations for employers of researchers, outlined for this commitment as follows:
‘Funders of research expect:
- employers of researchers to have procedures in place to ensure that research is conducted in accordance with standards of best practice; systems to promote research integrity; and transparent, robust and fair processes to investigate alleged research misconduct’ (Concordat, p12).
13. In addition, the Concordat states that ‘To provide assurance over efforts to strengthen research integrity, Research Councils UK will use its existing assurance mechanisms to garner feedback on activity across the sector. This information will be made available to other funders and provide an evidence base for the annual statement, thereby reducing the need for additional reporting requirements’ (p21). In order to be compliant with the Concordat, institutions are therefore required to provide RCUK with the necessary assurance.
14. We would therefore expect a compliant institution to work in collaboration with any research partners, and develop good working practices within the institution, to maintain a research environment and culture that meets the remaining commitments of the Concordat; to support its researchers; and to have appropriate policies, systems and procedures in place as described above. Each institution should ensure that these responsibilities are fulfilled in the most appropriate way for that institution; institutions are not expected to implement a common approach. This echoes what is stated in the Concordat (p10).
15. It is the Council’s intention to work with the other signatories of the Concordat in developing some examples of good practice for institutions, to provide illustrations and guidance on how the commitments and responsibilities of the Concordat may best be fulfilled. Further information on this work will be provided later in 2013.
16. We recommend that institutions refer to Annex II of the Concordat, which lists useful resources providing further information about research integrity.
17. Any further enquiries relating to the requirement to comply with the Concordat should be directed to complyRI@hefce.ac.uk. HEFCE will be able to provide general advice or clarifications on the requirement; we will not be able to advise on specific cases. Any frequently asked questions will be published in an anonymised format on our web-site for the benefit of all institutions.
18. The dedicated e-mail address we have set up for enquiries is not intended to deal with allegations of research misconduct. As outlined in the Concordat, ‘Employers of researchers have the primary responsibility for investigating allegations of research misconduct’ (p18).
19. HEFCE expects that any serious incidents relating to research misconduct, including allegations of research misconduct under investigation, will be reported to the Council through the existing procedures set out in our accountability framework, and also reported to any additional relevant funder.
Sir Alan Langlands