Equity, diversity and inclusion policy

We believe that:

• everyone should work in a safe, open and equitable environment free from any unlawful discrimination
• diversity is fundamental to maximising the outcomes of research, enriching perspectives and enabling equality of health outcomes
• access to Wellcome funding should be equitable, and all Wellcome research should be practised in open, inclusive and equitable settings

This policy forms part of our grant conditions and should be considered alongside our policies and guidance on:

• bullying, harassment, abuse and harm
• research misconduct
• research involving human participants
• clinical trials
• responsible conduct of research

Equity is about giving certain groups with protected characteristics the support they need to make opportunities fair. This differs from equality, which is achieved through the principle of equal treatment for everyone regardless of need. Equality is the belief and action that no one is being unfairly advantaged or disadvantaged because of who they are, where they are from or due to any of the protected characteristics, such as sex, race, gender and/or disability. Equity favours treating certain groups differently so that equality of opportunity can be achieved.

Diversity recognises that environments are made up of a range of people with different ages, religions, ethnicities, disabilities and gender, who represent a variety of cultural, religious and socioeconomic principles and perspectives, and acknowledges the value of the differences.

Inclusion aims to foster an environment that allows people with different backgrounds, characteristics and ways of thinking to work effectively together and fulfil their potential. Inclusion ensures each individual is valued for their distinctive skills, experiences and perspectives.

Discrimination refers to a person receiving unfair or unjust treatment because they possess certain characteristics, such as age, race, sexual orientation and/or religion. In the UK, it is against the law (UK Equality Act 2010) to discriminate against anyone because of reasons related to protected characteristics:

• age
• disability
• gender reassignment
• marriage or civil partnership status
• pregnancy and maternity
• race (including colour, nationality and ethnic or national origin)
• religion or belief
• sex
• sexual orientation

We recognise that the protected characteristics are a useful definition. However, they are also limited in scope. We encourage a broader understanding of intersectionality and experiences that are beyond the minimum requirements and local regulatory frameworks, such as socioeconomic backgrounds.

We expect all participants involved in Wellcome funding to commit to equity, diversity and inclusion in their working practices in order to ensure a working environment free of unlawful discrimination. Participants should promote dignity and respect for all, and recognise and value different individual contributions.

Participants include:

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

We expect organisations to follow the UK Equality Act or equivalent local regulations for organisations outside the UK. Organisations are expected to comply with our policy as long as it does not conflict with local regulation, in which case we expect organisations to adhere to local law.

We expect organisations we fund to have a policy in place that prevents and addresses discrimination, sets expectations of their staff on equity, equality, diversity and inclusion, and clearly sets out the standards of behaviour it expects from their employees and all involved with their activities. The policy should be available to all staff and ideally published on the organisation’s intranet. It is the organisation’s responsibility to make sure there is an equivalent policy in place at any sub-awardee organisation.

We want access to our funding to be open and accessible to anyone who is eligible under the terms of our schemes and calls. We do not encourage organisations to have selection processes for applying to our funding. Where organisations choose to do this, they must ensure that the process is fair and transparent and that equity, diversity and inclusion is a consideration when setting up selection panels and choosing reviewers.

We expect research and/or team leaders we fund, and the organisations they are based at, to:

• provide equitable opportunities across all tasks assigned within a research team/group
• when composing research teams, consider people from diverse backgrounds for team members
• consider the diversity of the relevant local, regional and national communities when building a research team
• make training and development opportunities equitably available to all
• train team members and leaders in equity, diversity and inclusion principles and best practices

Wellcome further expects organisations to:

1. Investigate allegations of discrimination 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 organisations’ own policies

2. At the point of applying, confirm that the lead applicant (and sponsor and supervisor, if relevant) has not had an allegation of discrimination upheld against them for which there is either a current formal disciplinary warning or an active sanction.

In such circumstances, we encourage potential applicants to 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 a 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.

3. Ensure any 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. Tell Wellcome’s Director of Research Funding when a formal investigation has been opened into an allegation of discrimination. This should include a brief factual statement about the nature of the allegation. For example, wrongful termination of employment of a staff member because of one or more protected characteristics they identify with.

We reserve the right to ask for the name of the individual whose conduct is being investigated where we consider that we have a legitimate interest in doing so. This applies to any individual at the organisation who is associated with a:

• Wellcome grant application under consideration (either as a lead applicant, sponsor or supervisor)
• Wellcome grant (see our list of participants above)
• Wellcome advisory committee

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.

5. Keep Wellcome informed during the investigation process. Investigations should conclude within one year of receiving the allegation.

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 sanctions are being imposed

We reserve the right to 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

6. Ensure appropriate measures of care are in place for people affected by an investigation into discrimination or otherwise, regardless of its outcome.

7. Have procedures in place for whistleblowing and ensuring appropriate safeguarding.

Wellcome expects all research we fund to be inclusive in a way that is appropriate to the place in which the research is conducted and the aims of the research. While not all research we fund will require co-creation or patient-led involvement, we do expect our partners to take seriously the needs and values of the key beneficiaries of research where relevant.

We expect all our grant participants to be substantively inclusive of the local, regional or national community as appropriate to the research. Our policies on clinical trials and research involving human participants provide further guidance on Wellcome’s expectations of research participants and should be read alongside this policy.

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 the 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 discrimination 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, and
• be aware of the potential impact on Wellcome-funded activities and the steps being taken to manage that impact
• make any necessary onward report required by our regulator (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 outstanding cases. 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 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 them.
  • 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.

Anyone can report a concern or allegation of discrimination related to Wellcome-funded research. Allegations of discrimination should always be reported to the employing organisation of the person against whom the allegation is being made 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 will respect an informant’s anonymity unless we have a legal obligation to reveal their identity (we will tell the informant if we are required to do this)

The employing 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 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 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 processes, should be reported to Wellcome, as outlined in this policy, and within five years of the alleged incident or onset of discrimination having taken place.

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 discrimination 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 discrimination 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

Wellcome strongly encourages our applicants, grantholders, and the organisations we fund to consistently embed equity, diversity and inclusion in their research environments. We wish to work with the organisations we fund to achieve these principles and promote a safe and diverse research community and culture. We encourage the following non-exhaustive practices for organisations to adopt to achieve this.

1. Recruitment and promotion

• Promotions criteria should be published and easily accessible to all employees and be informed by equity, diversity and inclusion.
• When recruiting, organisations should encourage a diverse pool of applicants, ensuring accessibility throughout the process and making all reasonable adjustments such as providing flexibility for virtual interviews.
• Recruitment panels should be encouraged to include a diverse pool of members.

2. Encourage and promote transparency across the sector by externally publishing equity, diversity and inclusion data as organisationally appropriate:

• we also encourage organisations to consider publishing action plans that look to address organisational equity, diversity and inclusion goals, such as anti-racism action plans

3. Apply Positive Action in organisational processes to encourage inclusivity and accessibility, such as:

• widening participation activities
• the use of targeted advertising to encourage underrepresented groups to apply to work at the institution
• taking steps to remove barriers in the outreach or hiring process for underrepresented groups
• providing alternative processes to meet different needs in access services

This policy was last updated in November 2023.