Bullying, harassment, abuse and harm policy

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.

We expect all participants involved in Wellcome funding to treat each other with dignity and respect. Participants include:

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

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 standards of behaviour it expects from staff
• their procedure for responding to complaints, 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 relevant. 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:

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

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:

• 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.

5. Contact Wellcome’s Director of Grants again when the investigation has been completed and any final appeal has been heard. This should confirm:

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

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:

• 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 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:

• 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 bullying or harassment 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 GDPR) 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 Grants
  • Head of Grants Operations
  • Grants Policies Officer
  • Legal Counsel.
• 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:
  • grantholders get the support they need from Wellcome
  • the outcomes of Wellcome-funded grant activities are not at risk.

• 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.

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:

• 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.
• bar them from being a PhD supervisor on Wellcome programmes
• temporarily or permanently restrict them from future grant applications (or specific types of grant applications)
• allow future grant applications but require the organisation to monitor the way the person manages staff.

We may apply sanctions against a Wellcome-funded organisation if we find that it has failed to:

• respond to a bullying and/or harassment 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
• restricting applications for specific grant types, for example, not allowing participation in PhD programmes or overseas-based research
• suspending funding to the organisation in extreme cases.

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:

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

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:

• 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 consider that we have a legitimate interest in doing so.

This may be done as part of our organisation audits.

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.

See also our policies on:

• Clinical trials
• Research involving human participants
• Research involving people in low- and middle-income countries

This policy was last updated in June 2020.