Actions for Non-Compliance
When organisations and researchers accept grant funding from SEA DREAM, they must agree to comply with the terms and conditions of the award which are set out in the award letter, grant conditions and funding policies, and accept that any breach may lead SEA DREAM to take associated actions.
The purpose of our terms and conditions is to ensure that funding is used for the purposes for which it was awarded, and that the research is managed lawfully and ethically.
SEA DREAM conducts organisational audits periodically to ensure that effective controls and processes are in place to manage funding according to our terms and conditions. We expect organisations to implement all recommended actions following an audit.
Circumstances in Which Action May Be Taken
Unless specified, we may apply any action at an individual or organisational level.
SEA DREAM may take actions against a funded researcher, other grant participant or their administering organisation when:
there is non-compliance with any grant condition or funding policy as detailed in your award letter
there is a failure to improve compliance with our terms and conditions when we have requested this.
Additionally, we may take action against an organisation when:
it has received the audit rating of ‘unsatisfactory’ from an SEA DREAM-administered audit
recommended audit actions are overdue or not implemented.
Actions SEA DREAM may take
Breaches of terms and conditions can vary in scale and impact. How we manage breaches is proportional to the type and severity of the breach. SEA DREAM may lessen any actions taken if the researcher and/or administering organisation proactively notify us of any breach and follow robust management in mitigating any breach. Where we can, we will provide a warning of our intention to take action to allow time to correct the breach or consider extenuating circumstances that led to the breach.
The following are examples of actions that SEA DREAM may take based on the nature and impact of non-compliance:
| Sr | Action | Description | Level of Action | Related Policies (if any) |
|---|---|---|---|---|
|
| Letter of warning
| This action may be used to communicate expectations and/or warn of future action. This may be used when we have requested information, and this is not provided. | Organisation
|
|
| 2 | Audit the administering organisation's processes
| This action may be used to raise standards. This may be applied when there are financial irregularities in the management of grant funds by the organisation. | Organisation | |
| 3 | Requiring formal updates on agreed actions
| This action may be used to check if improvements have been effective. This may be used when complaints against a researcher have been resolved through mediation or informal investigation. | Organisation | |
| 4 | Future grant applications are conditional on completion of actions
| This action may be used to improve research conduct or integrity. This may be used when an investigation report into allegations of misconduct recommends training (for example, responsible conduct of research training). | Organisation | |
| Role-Based or Activity Restrictions | ||||
| 5 | Bar from acting as a supervisor on SEA DREAM-funded research Master’s and PhD programmes
| This action may be used to improve the research environment. This may be used when there are upheld allegations of bullying and harassment of a student, co-worker, or research volunteers. | Individual | Bullying, Harassment, Abuse and Harm Policy |
| 6 | Restrict access to specific grant types (for example, PhD programmes)
| This action may be used to protect others and/or improve research culture. This may be applied to organisations where there has been proven poor management of specific awards. | Individual/ Organisation |
|
| 7 | Require the consortium lead to appoint an alternative Principal Investigator (PI), either temporarily or until the end of the grant
| This action may be used to reduce risk to others, protect research and reduce financial risk. This may be applied when:
| Individual | Bullying, Harassment, Abuse and Harm Policy Research Misconduct Policy |
| Funding Controls and Payment Restrictions | ||||
| 8 | Suspend funding
| This action may be used to reduce risk to others, protect research and reduce financial risk. This may be applied when:
| Individual/ Organisation | |
| 9 | Stop grant payments to an administering organisation
| This action may be used to protect non-profit funds. This may be applied when:
| Organisation | |
| Management Changes, Grant Termination and Financial Recovery | ||||
| 10 | Temporary removal of grantholders or sponsors from an active grant
| This action may be used to reduce risk to others and protect the research. This may be applied when:
| Individual | |
| 11 | Permanent removal of grantholders or sponsors from an active grant
| This action may be used to reduce risk to others and protect the research. This may be applied when a grantholder has been dismissed from employment. | Individual | |
| 12 | Terminate funding
| This action may be used to ensure funds are no longer available to spend where we are unwilling to support the completion of the grant. This may be applied when:
| Organisation | |
| 13 | Repayment of funds
| This action may be used to ensure funds are only spent as agreed. This may be applied when there have been ineligible expenses on an award. | Organisation | |
| Exclusion from Future Funding | ||||
| 14 | Bar from applying for funding from SEA DREAM until actions are complete
| This action may be used to communicate and implement expected action/behaviour. This may be applied when:
| Organisation | Bullying, Harassment, Abuse and Harm Policy Research Misconduct Policy Open Access Policy |
| 15 | Bar from applying for SEA DREAM funding for a period of time (usually 2-5 years)
| This action may be used to ensure SEA DREAM funds only those who conduct their research responsibly and to support a positive research environment. This may be applied when:
| Organisation | Research Misconduct Policy Use of Animals in Research Policy |
Breaches of our Research Misconduct, and Bullying, Harassment, Abuse and Harm Policies require specialist management. The way we handle these is set out in each of these policies.
How SEA DREAM manages breaches
If you think that you, your organisation or someone associated with a SEA DREAM grant may be in breach of our terms and conditions, including our funding policies, then contact the Head of Programme of SEA DREAM. We expect organisations to run any investigations that may be required. We will ask for further details if we consider this necessary to protect our legitimate interests.
Information relating to breaches will be handled:
-
at a level of confidentiality appropriate for the type of breach,
-
in line with Thailand’s Personal Data Protection Act (PDPA), and
-
in line with SEA DREAM’s retention policies.
In all cases, information will only be provided to other SEA DREAM and SEAMEO Secretariat staff as well as Wellcome on a need-to-know basis. In addition, we will also work to minimise the impact on any staff working on affected grants.
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