The University of Aberdeen Trusted Research due diligence process (set out below) is continually reviewed in response to evolving risks and as we and gain experience of the UK Government's Export Licence requirements.
Due diligence should be completed for each international partner (including universities, research institutes, commercial enterprises, charities or other entities) involved in any research activity that meets the criteria below:
- In a field, or close to a field, in any of the 17 sensitive notifiable acquisition sectors identified in the National Security and Investment Act (NSIA); or,
- Could have military, dual or end use(s) which may be in scope of UK Export Controls; or
- Falls under US export regulation – this is extraterritorial and applies to controlled items which may be imported to the UK for research purposes.
Due diligence is required on both formal collaborations such as those funded by external grants and governed by research agreements as well as informal activities including invited seminars, talks or exploratory discussions.
Responsibility for compliance with Export Control and NSIA regulations rests with both the institution and individual. Within a research projects, individual responsibility ultimately rests with the Principal Investigator (PI). PIs are responsible for considering and identifying any Trusted Research implications of their research and for raising any implications with R&I or their School.
Trusted Research Due Diligence
- Step 1. Register for Trusted Research review
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Research activities requiring Trusted Research due diligence should be flagged to the appropriate Research Development Executive (RDE) or Impact and Knowledge Exchange (IKE) contact within Research & Innovation. These activities may be identified through various routes, including:
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- Self-referral by academic staff or students;
- Identification by Research & Innovation during research development processes;
- Identification by Research & Innovation following a research contract request;
- Referral from the internal International Advisory Group;
- Other route via individuals, Research & Innovation or other sections.
The lead University of Aberdeen researcher will be asked to complete the Trusted Research Assessment proforma to enable the activity to be registered and initial key information collected.
Any queries can be sent to trustedresearch@abdn.ac.uk
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- Step 2. Open source due diligence
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A desk-based open search of publicly available information will be conducted on the entity and any named individuals by Research & Innovation (R&I) or External Relations. These checks may include some or all of the following:
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- Basic entity information: name, location, and business registration details;
- Leadership and key personnel: affiliations of key individuals;
- Sanction and watchlists: searches for the entity or associated individuals on international sanction or watchlists;
- Ethical considerations: review of any prior involvement in activities that could breach ethical research standards;
- Collaborations and funding: identification of past and current partnerships and funding sources;
- Intellectual property (IP): evidence of any prior cases of IP theft;
- Research integrity: assessment of any publicly available records related to research manipulation, fraud, or misconduct;
- Public perception: review of any negative media coverage associated with the entity or named individuals.
In cases where limited information is available on the third party the University may request an entity check from the UK Government Export Control Joint Unit.
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- Step 3. Referral for senior review
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Following the due diligence assessment in Step 2, Research & Innovation will make an outcome recommendation to senior colleagues with delegated responsibility for Trusted Research oversight. The principal investigator will be involved in this process and following the senior review one of the following outcomes will be confirmed:
- No further action – research activity can proceed, no Export Control licence or NSIA referral required;
- Potential concerns identified – further information and / or a mitigation plan required before a decision can be made;
- Possibly/probably in scope of Export Control or NSIA legislation – Either: Export Control licence application should be initiated, referral required to NSIA or Export Control Joint Unit (ECJU) advisory service, or external expert advice should be sought;
- Risk deemed too high – activity considered too risky to proceed.
- Step 4. Export Control licence application (where required)
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Where it is determined that the research activity may require an Export Control licence, Research & Innovation (R&I) or External Relations, and your School will work with the principal investigator to prepare and submit the licence application to the UK Government Export Control Joint Unit (ECJU).
Export Control licence applications should be submitted in the name of the University of Aberdeen and researchers are requested to not apply for a licence without first consulting Research & Innovation.
For further information please visit our Applying for an Export Licence guidance.
Timelines
Researchers should allocate 6 to 8 weeks in their schedule for the completion of the due diligence process, though timelines may vary depending on the complexity of each case.
If an Export Control licence is required, researchers should anticipate an additional processing time of at least 3 months, which should be factored into the overall project timeline.