Equity, Diversity and Inclusion Policy

1. Purpose

We are committed to encouraging equity, diversity and inclusion among all people working at SEA DREAM or involved in SEA DREAM-funded activities, as well as among research participants.

We believe that:

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

2. Scope and Definition

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. With respect to research subjects and participants, inclusion strengthens the rigor, reproducibility and generalisability of research findings.

Discrimination refers to a person receiving unfair or unjust treatment because they possess certain protected characteristics, which include but not limited to 

• 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 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.

3. What we expect from people involved in SEA DREAM funding

We expect all participants involved in SEA DREAM 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
• SEA DREAM advisory committee members

3.1 Inclusive research 

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.

3.2 Applications

Organisations must tell us in their applications how they will take EDI into account in the planning, development, implementation and dissemination of their research, including sex and gender integration throughout the research process where appropriate. This should be considered in the context of the research proposal and disciplines involved, location of the research and the composition of the team and other participants involved.

3.3 Research Participants

We expect all our grant participants to be substantively inclusive of the local, regional or national community as appropriate to the research.  

3.4 Carrying out 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 stakeholders where relevant, throughout the research lifecycle. 

We expect all applicants to request the resources they need to carry out their project-related work. Where applicants and staff are based in more than one country, administering organisations should distribute funds as indicated in the application.

We expect partnerships developed as part of the research (for example, between institutions, and across geographies, disciplines or sectors) to be structured in ways that take account of the power dynamics between higher and lower resource settings (in one national or regional setting or internationally).  For research conducted in low-and middle-income countries (LMICs), we expect researchers based in the relevant region(s) to have a substantive role in:

• research design
• leadership
• day-to-day management and participation
• study implementation
• authorship 

3.5 Research outputs and benefits

Researchers should ensure that everyone involved in, or impacted by, the research can benefit from it. This could be through career opportunities for those undertaking the research or open sharing of the results with the community the research is undertaken with. Where some stakeholders are more likely to benefit than others, we expect the research design to include a plan for equitably distributing benefits wherever possible and to take stakeholders desired outcomes into consideration. 

4. What we expect from organisations we fund

We expect organisations 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. SEA DREAM will ensure that the selection 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. This might include anti-racism and anti-ableism training

SEA DREAM further expects organisations to:

1. Have prompt and effective processes for reasonable adjustment requests. This should allow access needs across physical and digital work environments to be captured and met for disabled staff on SEA DREAM grants.

2. 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

3. 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 SEA DREAM at whistleblower@sea-dream.org 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 SEA DREAM’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 encourage the organisation to check with the previous employer if possible.

4. 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.

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:

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

6. Keep SEA DREAM informed during the investigation process. Investigations should conclude within one year of receiving the allegation.

• 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

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

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

5. Why we ask to be informed and what we do with the information

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. 

Whilst we recognise that often information is confidential in nature due to the employment relationship, SEA DREAM 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
• be aware of the potential impact on SEA DREAM-funded activities and the steps being taken to manage that impact
• make any necessary onward report required by Wellcome 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) 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 SEA DREAM’s Head of Programme and designed personnel who are directly involved in the management of these cases
• communicated only to other SEA DREAM staff on a need-to-know, restricted access basis, where necessary, to pursue our legitimate interests as a fund management body. This includes making sure that:
  • we can access legal or safeguarding advice
  • grantholders get the support they need from SEA DREAM
  • the outcomes of SEA DREAM-funded grant activities are not at risk
  • SEA DREAM is able to monitor the number of outstanding cases
• 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 an obligation to report significant incidents onward to the Wellcome Trust,  or to comply with a court or regulatory order to pass the information on

6. How SEA DREAM handles allegations

Anyone can report a concern or allegation of discrimination related to SEA DREAM-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 SEA DREAM’s.

If an allegation is made directly to a member of SEA DREAM 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.

7. SEA DREAM's role in any investigation

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, SEA DREAM 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 SEA DREAM, as outlined in this policy, and within five years of the alleged incident or onset of discrimination having taken place.

8. Sanctions

8.1 Against individuals

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 SEA DREAM grants
• bar them from being a Master’s or PhD supervisor on SEA DREAM 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.

8.2 Against organisations

We may apply sanctions against a SEA DREAM-funded organisation if we find that it has failed to:

• respond to a discrimination complaint promptly and objectively
• keep SEA DREAM 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

9. Additional guidance

SEA DREAM 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

10. How SEA DREAM should be contacted

Allegations under this policy should be reported to the employing organisation.

11. Annexes

Annex I. Sex and Gender in SEA DREAM-funded Health Research

SEA DREAM is committed to supporting research that drives equitable health outcomes by advancing inclusive practices in our funded research. Sex and gender can influence whether and how we develop certain health conditions, how well we respond to treatments, and how often we seek health care. Accounting for sex and gender in health research will make the research more rigorous, more reproducible and more applicable to everyone.

We expect researchers we fund to integrate sex and gender throughout the research process where appropriate. This includes considering sex and gender in:

• research design involving human participants and animals, as well as human or animal tissues and cells;
• the recruitment of participants in clinical research or trials
• data collection
• analyses conducted
• research publications and other outputs

Research proposals that do not consider sex and gender dimensions must provide a strong, evidence-based rationale for not doing so. 

This should be considered alongside our policies and guidance on:

• Research involving human participants
• Clinical trials
• Responsible conduct of research
• Use of animals in research

Definitions
We acknowledge that the terms ‘sex’ and ‘gender’ are used in different ways in different contexts. It is important that researchers understand which specific sex characteristics, gender characteristics, or both, are relevant for their research question and the affected populations. We use them as terms with distinct meanings as defined here:

Sex: refers to a set of biological attributes in humans and animals.

When considering sex for the purposes of research, the characteristic(s) to account for may include:

• sex chromosomes
• gene expression
• hormone profile
• secondary sex characteristics
• internal reproductive organs
• external reproductive organs

This can also include variations of what are considered female-typical and male-typical characteristics (sometimes known as ‘variations in sex characteristics’ or ’intersex’). Researchers who do not know the sex of the cells and tissues they will use should plan to determine this as part of their research.

Gender refers to an aspect of a person’s identity and to the socially constructed roles, behaviours, expressions and identities of girls, women, boys, men and gender diverse people.

When considering gender for the purposes of research, the characteristics of participants which researchers may need to account for include, but are not limited to:

• gender identity (the gender with which a person identifies)
• gender expression (how a person outwardly presents themselves in relation to gendered forces)
• gender modality (whether a person’s gender identity is the same as their sex assigned at birth or not, that is whether they are cisgender or transgender)
• perceived or presumed gender (how a person’s gender is typically understood by those around them, which may differ from their gender identity, gender expression, or both)

Specifically, when referring to sex and gender in health research, we use the following additional terminology:

• Subject: refers to any entity on which non- or pre-clinical research is conducted, including cells, tissues, organs and animals.
• Participants: refers to people with whom clinical and population health research is conducted.

Elements to be addressed in the funding applications

In their funding applications, researchers must account for the following as part of their research:

Sex as a biological variable in non- or pre-clinical, clinical, health system and population health studies, where appropriate. The integration of sex as a biological variable may not be applicable in: 

• research involving pathogens grown in vitro in an acellular environment
• some pre- and non-clinical research where justifiable
• application of some biomedical technologies

Gender where their research involves human participants or social determinants of health in either clinical, health system or population health studies where appropriate. The integration of gender as a consideration of health may not be applicable in:

• biomedical research studies that exclusively use cells, tissues and animals
• certain single-sex studies using existing datasets
• secondary data analyses where it is impossible to create a new gender variable

In their funding application and as part of their research, researchers must also:

• specify the sex characteristic(s), gender characteristic(s), or both, that they will account for in their research
• include a sample of sexes, genders or both that represent the affected population in their research design, including in patient and public involvement and engagement activities where appropriate
• include details of sampling strategies, relevant recruitment of research participants, and/or use of animals, tissues and cells
• conduct disaggregated analysis by sex, gender or both
  • if researchers are not planning to perform either a sex- or gender-disaggregated analysis, they must explain why
• where evidence suggests the potential for differential findings by sex, gender or both, studies should be designed and powered to enable appropriate subgroup analyses
• ensure publications and other outputs describe sex and gender dimensions of the study, including sample distribution, analyses and relevant findings
  • if disaggregated analyses have not been conducted or sex and gender differences identified, this must also be reported

There may be studies when focusing on single-sex or single-gender samples in the research design is suitable, and we will accept this where appropriate justification is provided.