Policy on Dignity at Work in Research

At Cancer Research UK, we expect all people involved in our research to treat each other with dignity and respect, and we consider bullying and harassment of any kind, in any context, unacceptable.

Our policy outlines the conditions that anyone involved in our research activities and their Host Institutions must meet when applying for funding and for the duration of their funding. The policy also applies to members of our funding Committees and Panels.

1. Purpose

This policy sets out Cancer Research UK’s (CRUK’s) position and commitment to fostering a culture in research where everyone is treated with dignity. CRUK considers bullying and harassment of any kind, in any context, unacceptable. We believe that all people working at CRUK or involved in CRUK-funded activities should be able to work in an environment where everyone is treated, and treats others, fairly and with respect.

2. Scope

This policy applies to all participants involved in CRUK research as outlined in our policy.

Our commitment to CRUK staff and volunteers is addressed separately in the CRUK Dignity at Work Policy. This document deals specifically with those involved in research activities that we fund and support.

3. Definitions

Bullying is any offensive, intimidating, malicious or insulting verbal or non-verbal communication including physical behaviour. It is an abuse or misuse of power through means intended to undermine, humiliate, denigrate or injure a person.

Harassment is unwanted conduct related to your ‘protected characteristics’ that has the purpose or effect of violating your dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment for you. Harassment is also unwanted conduct of a sexual nature which has that same purpose or effect. Protected characteristics are: age, sex, disability, gender (including gender reassignment), marriage and civil partnership, pregnancy and maternity, race, religion or belief, sexual orientation. (In the UK, harassment is defined by the Equality Act 2010; in other countries, definitions may differ).

CRUK defines bullying and harassment as outlined in this section, however institutions should follow their own institutional policy definitions.

4. Key points

4.1 What CRUK expects from people involved in CRUK research programmes, events and initiatives

CRUK expects all participants involved in CRUK research to treat each other with dignity and respect. ‘Participants’ include:

• Grantholders
• Co-investigators
• Collaborators
• Research staff and consultants
• Supervisors
• Students
• Sub-grantees and sub-contractors
• CRUK funding committee and panel members.

4.2 What CRUK expects from Host Institutions: providing a work environment in which everyone is treated with respect

It is the Host Institution’s responsibility to:

1. Adopt a formal policy that clearly sets out the standards of behaviour and safeguarding responsibilities it expects from staff and the procedure for making and responding to complaints. CRUK expects this may include:
   • a first point of contact (such as an independent, identifiable complaints officer and/or a complaints hotline)
   • routes of informal and formal escalation
   • any whistleblower protection including during investigation phase
   • details of counselling or employee assistance provider support if available
   • any support offered for resolution (such as mediation or training)
   • appropriate sanctions for misconduct.

   The policy should be readily available to all staff and students, form part of induction processes and staff training, and ideally published on the Host Institution’s intranet.

2. Require that any sub-grantee or sub-contractor have an equivalent policy in place.
    
3. Take reasonable steps to ensure the policy is implemented effectively. Reasonable steps may include:
   • appropriate training on workplace conduct for staff and students during inductions and additional training for staff in supervisory roles or for complaints officers appropriate to their role. Training should be refreshed periodically or in response to any changes
   • the establishment of an effective whistleblowing hotline or other mechanism
   • engagement with staff and students on the issue by undertaking awareness raising campaigns and engagement surveys to ensure policies are working effectively and the workplace is free from bullying and harassment.

   CRUK will require Host Institutions to provide evidence of the reasonable steps taken to ensure that their workplace conduct policies and safeguarding policies are implemented effectively as part of our regular grants management audits and at any time requested by CRUK.

4. Investigate allegations of bullying and harassment in an impartial, fair and timely manner and take appropriate action. If the Host Institution is advised by the investigator(s) that a disciplinary procedure is warranted, CRUK expects institutions to complete the disciplinary procedure such that a formal finding can be reached and disciplinary procedures are applied. The disciplinary procedure should still be conducted even if the subject of the investigation resigns.
    
5. Ensure no agreements are entered into which prevent Host Institutions from telling CRUK of investigation findings and complying with our policy.
    
6. Document the findings of the investigation.

4.3 What CRUK expects from Host Institutions: notifying CRUK of findings of misconduct against grant applicants, grantholders and other Participants

1. At application stage: When a Host Institution submits a grant application to CRUK, it must confirm that, other than as notified to CRUK there have been no findings of bullying or harassment upheld against the Lead Applicant(s), nor any of its employees or students who are named on the application as proposed Participants (defined above in section 3), for which there is an active formal disciplinary sanction for bullying or harassment. Where Participants are not based at the Lead Applicant's Host Institution, the Participant's own Host Institution is responsible for reporting upheld findings directly to CRUK. The relevant Host Institution should complete the reporting pro-forma template annexed to this policy and email it to CRUK’s Director of Research Operations and Communications at dignityinresearch@cancer.org.uk, telling CRUK if any of the information provided is confidential. Please also note the information required at application stage in section 4.3(iii) below. If there has been a finding of bullying or harassment, CRUK may reject the application or ask that the relevant individual(s) be removed from it.
    
2. Where a Host Institution is responsible for Participants in CRUK research: (defined above in section 4.1), and a decision is made to formally investigate an allegation of bullying or harassment against one of those Participants, the Host Institution must inform CRUK’s Director of Research Operations and Communications when they decide to investigate via the process in section 4.3(iii) below. Where Participants are not based at the Grantholder's Host Institution, the Participant's own Host Institution is responsible for reporting investigations directly to CRUK. 

   This requirement applies to all current awards and historic awards made prior to October 2018 (when CRUK introduced this policy) where an upheld finding has been reached since that date.

   CRUK reserves the right to ask for the name of the Participant whose conduct is being investigated, where we consider we have a legitimate interest in doing so.

   CRUK will reserve any judgement about an allegation until the investigation is complete. CRUK will only provide information to its staff or its external advisors on a need-to-know basis. The Host Institution must inform CRUK of:
   - a decision to formally investigate an allegation of bullying or harassment against a Participant; and
   - the outcome of the investigation and if any sanctions are being imposed.
    

3. The Host Institution should complete the reporting pro-forma template annexed to this policy and email it to CRUK’s Director of Research Operations and Communications at dignityinresearch@cancer.org.uk, telling CRUK if any of the information provided is confidential.
    
4. When notifying CRUK of a bullying and harassment investigation, the Host Institution should only provide the following information:
   • a formal investigation has commenced against a Participant (notes: as per section 4.3(ii), we do not require the name of the person against whom the investigation has commenced at this point, however we reserve the right to ask for it. This step is not applicable at application stage)
   • where an allegation has been upheld, the name of the person against whom the allegation has been upheld
   • the person’s connection to CRUK (e.g. CRUK grant reference number or CRUK panel/committee membership if relevant) where this does not identify the person
   • a brief factual statement about the nature of the allegation
   • the date the complaint was lodged
   • the start date of the investigation and expected/actual investigation completion date
   • for completed investigations only: a brief factual statement on the outcome of the investigation, including whether the allegation was partially or fully upheld and any sanctions
   • the date of the outcome of the investigation
   • the name and position of the relevant HR contact at the Host Institution (i.e. the person who is providing the information). CRUK cannot act on unverified, anonymous information.

CRUK reserves the right to request a copy of the investigation report, where we consider we have a legitimate interest in doing so.

4.4 Why CRUK asks to be informed and what we do with this information

While CRUK recognises that the requested disclosures under this policy may include personal data, we consider we have a legitimate interest in handling this data.

During the application stage, CRUK needs to be aware of upheld allegations, so that we can make responsible funding decisions. 

After an award has been made, the Host Institution must tell us when a formal investigation into bullying or harassment has been started. This is so that CRUK 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 CRUK-funded activities and the steps being taken to manage that impact.

The information you provide at any point should not include any:

• 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, e.g. the person making the claim.

Any information you send to us will be:

• handled in confidence and in accordance with data protection law requirements
• stored in a secure, restricted-access location, with access restricted to two members of staff involved in the management of these cases
• communicated on a need-to-know, restricted-access basis only, where necessary, to pursue our legitimate interests as a funder. This includes making sure that:
  - grantholders get the support they need from CRUK
  - the outcomes of CRUK-funded grant activities are not at risk.
• kept by CRUK in line with our retention policy, reviewed regularly to assess whether it can be removed, and for no longer than we need it for our legitimate purposes.  Any allegations that are not upheld will be stored for two years after the outcome, the remainder will be stored for six years after the outcome. 

4.5 Sanctions

If a Host Institution upholds a bullying or harassment allegation, CRUK may apply its own sanctions. 

These may be independent of any set by the Host Institution and will be considered on a case-by-case basis. CRUK may:

• send a letter of concern
• where the person remains in post, they may be required to attend workplace behaviour training before continuing on a CRUK grant or applying for further CRUK funding
• remove the person from the affected grant(s), from a CRUK Panel or Committee 
• withdraw funding from the grantholder. CRUK will work with the Host Institution to minimise the impact on staff working on the affected grant(s), which may include transferring the grant to another suitable investigator to allow the work to be completed.
• prohibit that person from acting as a PhD supervisor for CRUK-funded students
• temporarily or permanently restrict them from future grant applications (or specific types of grant applications) or from being invited to be a member of a CRUK Panel or Committee 
• allow future grant applications, but require the Host Institution to monitor the way the person manages staff
• take any further sanctions at its own discretion.

CRUK may apply sanctions against a CRUK-funded Host Institution if CRUK believes:

• the Host Institution has failed to respond to a bullying and/or harassment complaint promptly and objectively;
• there has been institutional-level failure to complete disciplinary procedures;
• there has been a serious Institutional-level failure to effectively ensure appropriate workplace conduct standards are observed.

Sanctions may include:

• ongoing monitoring of the Host Institution’s policies and practices
• not accepting new grant applications from that Host Institution for a period of time
• restricting applications for specific grant types, e.g. not allowing participation in training programmes
• suspending funding to the Host Institution in extreme cases
• taking any further sanctions at its own discretion.

4.6 How CRUK handles allegations

If an allegation of bullying or harassment is made directly to a member of CRUK staff or via email rather than to the Host Institution:

• a senior CRUK staff member will first discuss the circumstances with the complainant
• CRUK will either encourage the complainant to report the allegation at their Host Institution through the appropriate channels or then tell an appropriate individual at the Host Institution.

If a complainant wants to remain anonymous, CRUK will respect this unless there is a legal obligation to reveal their identity. CRUK will tell the complainant before it does this.

The Host Institution is then responsible for following its procedures for handling allegations.

CRUK will reserve any judgement about an allegation until the investigation is complete. CRUK will only provide information to its staff or its external advisors on a need-to-know basis.

4.7 CRUK's role in any investigation

CRUK does not carry out its own investigations, but it may:

• ask for information about a Host Institution’s processes and how they are effectively implemented
• check that a Host Institution and any sub-grantee have a policy and are 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 CRUK’s standard grants management audits or as part of the annual review process in the case of Host Institution’s holding core-funding from CRUK.

5    Support and advice

For any queries about this policy please contact: dignityinresearch@cancer.org.uk

6    Related documents

For more information, please see the following web pages:

Cancer Research UK Grant Conditions
http://main.int.cruk.org/funding-for-researchers/applying-for-funding/conditions-of-your-grant

Code of Practice for Funding Committees and Panels https://main.int.cruk.org/funding-for-researchers/applying-for-funding/funding-committees