Poor behaviour damages people and science By Anne Taylor, Head of Grants Operations, Wellcome Published: 20 November 2018 Early in 2018, Wellcome decided that a specific bullying and harassment policy would be a good idea. Why? Well, our view is that poor behaviour damages people and science. But in our regular review of policies, we realised that although several touched on the area none was specific enough to make our expectations clear or influence such an important issue. Events in the external environment, including high profile reports in the media and the Science and Technology Committee enquiry into Research Integrity, served as a reminder of the importance of the issue. So, the timing felt right and we thought we could influence the sector in a positive way… and we wanted to do it quickly. Looking through a different lens The idea sounded straightforward, but the thinking behind what it would look like was not so simple. We asked ourselves lots of questions, such as: What did we want to achieve? Whose responsibility is it to ensure the behaviour of researchers on our grants? What are our legitimate interests? What can we reasonably expect organisations to do and to tell us? What sanctions would we use and how could we ensure compliance? Would we unintentionally drive issues underground? And, of course, what about GDPR!? To cover all angles, we set up a small working group including grants management, legal, human resources and communications. Each of us was looking through a different lens on the problem which caused some interesting discussions, but the benefits of different views far outweighed any difficulties it caused. Wellcome cannot carry out investigations as we are not the employer. Of course, we do receive complaints ourselves and we pass these to the institution, with the permission of the complainant. Therefore, our policy requires organisations to have a policy and process to handle allegations, make it available, and use it; make sure sub-awardees have a policy; and inform us of upheld allegations and any sanctions. Additionally, we require confirmation when an application is submitted that there are no active sanctions against the principal applicant, sponsor or supervisor. First in the UK Whilst we felt strongly that it was the right thing to do, we were conscious that we would be the first in the UK to publish such a policy and were by no means certain how it would land, but we were pleasantly surprised. There was universal praise for launching a policy on bullying and harassment, from other funders, researchers and organisations, as well as a positive media response. Of course, the real test is in the time after launch and we were under no illusions that it would be perfect straight away. When we designed the policy, we had to consider very carefully potential legal ramifications and GDPR requirements, and so at first requested minimal information and only at the end of an investigation. However, real cases have tested this decision and it is clear that this is inadequate for our needs. For example, early resignations and wide-ranging non-disclosure agreements can prohibit robust decision-making. We are planning to change our policy to cope with these problems and indeed the recently launched Dignity at Work policy from CR-UK requires earlier notification and communication of the findings as well as the sanctions. Some amendments will be for clarity. For example, we did not make it clear that although we may withdraw funding from a principal investigator, we will do what can to make sure the post-docs on the grant are not disadvantaged. When we have had to deal with research misconduct in the past, we have transferred the grant to another PI with the team intact or held the grant open until the post-docs have completed their work and found another job. We have, as we thought, seen an increase in people telling us about problems. Although we cannot investigate ourselves and so pass these on to the organisation, it is a good sign that people feel able to tell us about issues and hopefully fewer cases will be brushed under the carpet as a result. A united stance Lastly, advice for other AMRC members who might be thinking about launching a policy. Don’t reinvent the wheel. If Wellcome or CR-UK’s policy works for you, then use it (and please contact us to discuss if it would help). As mentioned, we are likely to update ours so that there will be little if any material difference between the two. And a united stance from AMRC members is a good thing. Secondly, although we have not been inundated with cases, each one takes a lot of time, and very often legal advice is needed. So, plan your resources and be clear about your internal processes.