Bullying, harassment, abuse and harm policy

We expect everyone involved in Wellcome funding to treat each other with dignity and respect. We have a parallel policy that applies to Wellcome staff.

This policy is for Wellcome's:

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

Anyone can report a concern about Wellcome-funded research. Organisations must have processes in place to enable reporting. Researchers working with human participants must tell them about the reporting processes, so they know how to report any concerns they have about harm relating to their participation.

Behaviours that cause harm

• Physical: any physical contact that results in discomfort, pain or injury.
• Sexual: coercion or force to take part in sexual acts of any kind. Unwanted verbal, non-verbal or physical conduct of a sexual nature.
• Emotional/psychological: action or inaction that causes mental distress.
• Exploitation: misuse of power or control over another person for financial, social, sexual or other benefit.
• Bullying: 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: 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.
• Organisational: behaviour that allows or enables any of the types of behaviour above to continue. For example, failing to act if someone reports a concern to you.

We expect organisations and researchers to prevent harm and address any concerns that harm or abuse has taken place or that may arise from Wellcome-funded work.

For organisations where we provide core funding, reporting is limited to people linked to specific research projects funded by Wellcome. However, all cases should be included in any organisation-wide reporting.

Organisations must ensure that where there are potential risks of harm to staff, participants or others involved, a risk assessment will be undertaken that will consider and mitigate any such risks. Risk assessments are not required at the time the application is made but must be completed before the research starts.

When an organisation submits an application to us, they must confirm that the lead applicant (and sponsor and supervisor if relevant), has not had an allegation of bullying, harassment, abuse and harm upheld against them for which there is either a current formal disciplinary warning or an active sanction. If they have, potential applicants should contact Wellcome's Director of Research Funding, in confidence, to discuss their situation before they apply. We may reject the application where we feel there is continued risk to other people or to Wellcome's principles.

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 policies in place to prevent and address bullying, harassment, abuse and harm, that clearly state:

• The standards of behaviour it expects from staff.
• Their procedure for handling allegations, including a clear place to submit allegations to. Investigations into allegations should consider the views, rights and safety of the victim/survivor and the person making the allegation (if they are not the same). 

Policies should be available to all employees (ideally published on the organisation’s intranet). They should also be available for other people involved in their operations so they know how to raise a concern about harm (including any research participants). 

2. Make sure there is an equivalent policy in place at any sub-awardee organisation. 

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 bullying, harassment, abuse and harm in an impartial, fair and timely manner. It must:

• protect the rights of all involved
• take appropriate action including ensuring the immediate safety of the people involved and reporting incidents to other bodies as required by law, regulation and the organisation's own policy.

5. Tell Wellcome’s Director of Research Funding when a formal investigation has been opened into an allegation of bullying, harassment, abuse and harm. This should include a brief factual statement about the nature of the allegation. For example, bullying of junior staff members in a research group.

Where we feel it is necessary, and where we have a legitimate interest to do so, we will ask for more specific details about the nature of the concern, including the name of any employee whose conduct is being investigated (if it is an employee).

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)
• Wellcome grant (see our list of participants above)
• 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. This should confirm:

• if the allegation was upheld
• the findings of the investigation
• if any practical improvements have been made to policies or processes as a result of the investigation
• if any sanctions are being imposed.

We may 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 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, support staff and research participants.

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
• be aware of the potential impact on Wellcome-funded activities and the steps being taken to manage that impact, and
• make any necessary onward report required by our regulator (the Charity Commission for England and Wales) and other relevant bodies as required by law. 

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 or safeguarding advice.
  • Grantholders get the support they need from Wellcome.
  • The outcomes of Wellcome-funded grant activities are not at risk.
  • Wellcome is able to monitor the number of cases outstanding. The Board of Governors is responsible for safeguarding and the Audit and Risk Committee review anonymised data relating to outstanding cases on a regular basis.
• Not be 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 another organisation(s). We may share details of the allegations and its result when known.
  • We have a statutory obligation to report significant incidents to the Charity Commission for England and Wales or to comply with a court or regulatory order to pass the information on. 

After reviewing the investigation and disciplinary procedure outcomes 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.
• Require training and/or the monitoring of future work.

Where allegations of bullying, harassment abuse or harm 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 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.

Anyone can report a concern or allegation of bullying, harassment, abuse and harm related to Wellcome-funded research. Concerns and allegations should always be reported to the employing organisation, or if this is not known, the organisation that is running the research project. 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 may also pass the allegation to the organisation where there is a risk to the safety of others. When this is the case, we do not need to consent of the informant to do so. 

We will respect an informant’s anonymity. In exceptionally rare circumstances, we will share their information if required to do so under a court order, if requested by the police or other regulatory or government authority or if otherwise required to do so by law.

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

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 five years of the alleged incident or onset of bullying, harassing, abusive or harmful behaviour.

This policy was last updated in April 2023.

See also our policies on:

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