Partner Due Diligence
Questions to consider:
- Where your collaborator / funder / partner is based? This may include parent organisations. Resources for this are given below.
- Does the project have any potential applications for military use, harm, repression or surveillance - even if this doesn't seem like something that the collaborator / partner / funder would get involved in?
- Does the collaborator/ partners / funders have any links to the military / defence programmes? Are they (or their state) involved in weapons of mass destruction (WMD) research and development programmes ?
- Are there any security or other concerns / red flags? Examples might include:
- How has the collaborator/ partners / funders approached the University / its researchers (Is the University a leading expert, could they ask anyone else more appropriate, who is the parent company? Do you know of them or is it a cold call?)
- is the precise identity or circumstances of the end user unclear / incomplete? Has the University engaged with them before?
- Does the offer seem more attractive than, for example, UK collaborators/ partners / funders might fund?
- Is the collaborator / partner / funder holding back on key details e.g.
- they are an agent and don't want to reveal their client / source of funds just yet
- They are reluctant to offer information about the end-use of the items?
- Unusual requirements for excessive confidentiality about final destinations, customers, or specifications of items?
- Unusual requests regarding shipping, packaging or labelling?
The following tools can be used to assess collaborator/ partners / funders and their country of origin:
Check United Nations Security Council Consolidated List Search https://scsanctions.un.org/search/ to see if there are sanctions or arms embargos against the country
Check UK Sanctions List https://www.gov.uk/government/publications/the-uk-sanctions-list and also see https://www.gov.uk/government/collections/uk-sanctions-regimes-under-the-sanctions-act
UK Trade Sanctions, arms embargoes, other trade restrictions https://www.gov.uk/guidance/current-arms-embargoes-and-other-restrictions
Web searches to establish if the potential collaborator/ partner / funder (at an individual and organisation level) have been involved in activities of potential concern (e.g. news articles and press releases about involvement in military or defence projects)
ASPI Tracker (Chinese HEIs) https://unitracker.aspi.org.au/ - can give an indication if there may be security concerns (but is no guarantee of UK Government perspective)
Web searches to establish if the potential collaborator /partner / funder (at an individual and organisation level) have been involved in activities of potential concern (e.g. news articles and press releases about involvement in military or defence projects)
USA Export Control Supplement lists https://www.bis.doc.gov/index.php/documents/regulations-docs/2326-supplement-no-4-to-part-744-entity-list-4/file
USA Military End User (MEU) List (companies) https://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/1770 (Check American lists relevant to your sector e.g. AI, genomics)
https://www.bis.doc.gov/index.php/documents/regulations-docs/2714-supplement-no-7-to-part-744-military-end-user-meu-list/file (will be regularly updated so check from landing page above).
The Research Governance and Integrity Team can check if the UK government has end-user concerns about international collaborators/ partners / funders via the end user check service available on the Export Control Joint Unit’s licensing system. Concerns from the government usually mean the issue to the university of a standard "WMD letter” meaning that a licence must be sought for any activity with that collaborator/ partners / funders (irrespective of the project topic).