Structural Inequalities in Financial Process and Procedure
Many elements of ethical research practice are dictated by factors outside the control of researchers or the institutions they work for. These factors directly impact the ability to develop equitable and ethical partnerships, both institutionally and on an individual level. Our research community identified the following structural procedural issues that arch over the entire research process and impact ethical practice:
- Due Diligence – Completing a due diligence check prior to signing any collaboration agreements has become standard practice for lead organisations on grants. Such checks are now normally required by funder terms and conditions. Completing the due diligence process and subsequent signing of required agreements can take time and delay the ability of lead partners to send funds to collaborating institutions. This delay can be particularly detrimental to collaborating institutions who are unable to absorb research operating costs up front while completing the required processes. The overall process can often be perceived as being driven by lack of trust on the part of UK organisations in their international partners.
- Per diems - Per diems are normal in many countries, with team members receiving a set amount of money for each day they conduct field work or attend work-related meetings and events. This may be in place of or in addition to expenses being reimbursed upon submission of receipts for travel and subsistence. In some cases, per diems are considered to be a component of salary renumeration for researchers in non-UK countries. In contrast, per diems are ineligible expenditure for several funders (e.g. NIHR) and have implications for UK tax liability for research organizations. As such, several institutions do not allow per diems, either due to funder terms and conditions or due to institutional policies linked to tax liability.
- Evidence of Expenditure – Funders specify the evidence of expenditure that is required to be available upon request, normally asked for in the case of an audit. These requirements are then passed along to all partners in the research. While linked to the per diem issue noted above, in many research environments (particularly in rural areas), receipts may not be available normally (and can create suspicion when requested). As such, the lack of flexibility in acceptable evidence of expenditure can leave researchers out of pocket for research-related expenses.
Navigating Structural Inequalities in Financial Process and Procedure
Structural inequalities in procedure are very difficult to address directly and the capacity of individual researchers to do so are limited. Layered on top of this are the diversity of cultural norms about the appropriateness of discussing money. Research teams should endeavour to have frank but sensitive discussions early in the conceptual stages and throughout the life of the project. While they can be very difficult, these discussions are needed to ensure all those involved understand the implications of these over-arching policies and have the chance to either discontinue their involvement or co-develop team solutions that can work for them within the constraints of the policies. Based on points raised by the UofG research community and knowledge gained through various engagement activities, these discussions should cover (as a minimum):
Due Diligence
- An explanation at the earliest stages of the application process that, if funding is awarded, a due diligence process will be undertaken on all partners by the lead organization before any collaboration agreements are signed (and therefore before any funds can be sent). The reason for this check – that it is a requirement of the funding rather than a choice being made by the lead organisation – should also be made clear.
- A copy of UofG’s due diligence questionnaire is available from our Research Assurance team and can be made available to international partners at any time so they can see exactly what will be asked/requested. Questions and clarifications should be invited and answered honestly.
- It should be emphasized that due diligence is not a “test” and partners cannot pass or fail. Rather, it is a way for organizations that work together to understand the possible risks involved in a collaborative relationship and address any concerns openly.
- Due diligence does not operate in one direction only and it is advisable that all institutions conduct a check on their partners. The University of Glasgow is happy to complete a due diligence questionnaire for any partner that requests it.
Per Diems
- Effort should be made to ensure the nature of per diems in this context is not misunderstood. In some cases, team members may understand per diems to be ineligible in addition to receipted expenses rather than in place of receipted expenses. It is important that time is taken to clarify that everyone is understanding the use of the term “per diem” in the same way. The phrase “sitting allowance” may also be used to refer to payments expected by participants who are attending meetings or project activities. The concept of payment for participation may also need to be considered.
- Teams should determine early if per diems or related payment types are eligible within the policies of the funding scheme and/or lead institution.
- If per diems are not an eligible expense, explanations should be provided – all partners should understand the source of the regulations governing per diems to ensure this matter can be navigated without underlying incorrect assumptions.
- A discussion should take place about the impact of no per diems on the viability of partner engagement in the project. Lack of per diems may limit partners’ ability to attend meetings or conduct field work. This should not be misconstrued as lack of commitment to the project.
- Team members should strive to understand the culture of per diems or related payment types across different cultural contexts and pre-emptively identify potential events and activities where such payments may be expected by attendees who are not part of the project team, such as non-academic stakeholders or research participants. This discussion should also include how to manage expectations surrounding per diems in such circumstances.
- Depending on how comfortable team members are discussing such topics, it may also be helpful to have private or semi-private discussions with impacted team members to understand how per diems factor into their salary renumeration.
- While navigating this issues may not result in a satisfactory resolution for all members of the team, early open discussions ensure no one is caught off guard later on and gives people the opportunity to withdraw.
Evidence of Expenditure
- Teams should expect that some form of evidence of expenditure will be required and determine early in the application process whether all partners will be able to provide such evidence for various circumstances, such as:
- Pay slips or time sheets for salary payments
- Receipts for travel and proof of event attendance where travel is involved
- Receipts for meals and minor research consumable purchases while in the field
- Should any concerns be raised about the workload required to document and maintain such records, teams should resource appropriate support staff in the grant application to ensure these obligations can be met.
- In the event that receipts are not possible to safely or ethically collect (e.g. it may not be appropriate to ask someone who may not be able to read English to sign a receipt you have written), the team should confer with the funder to determine what documentation would be considered acceptable. Normally in such circumstances, all team members must maintain records of any payments they have made, including dates, times, locations, amounts, a note of items purchased and an explanation of why a receipt is not available, but the important thing is to ensure all teams members are aware of and following funder guidance in such matters.