In April 2015, The Academy of Medical Sciences, the Biotechnology and Biological Sciences Research Council (BBSRC), the Medical Research Council (MRC) and the Wellcome Trust held a symposium entitled ‘Reproducibility and reliability of biomedical research’. It was clear from discussions at the symposium that this is an important issue that must be addressed effectively.
As a result, a document outlining the events and discussions taken place during the symposium was drawn up.
SFI Reviewer Code of Conduct
Science Foundation Ireland (SFI) offers a range of funding schemes which support scientists and engineers to deliver both research excellence and impact. The use of international independent reviewers is an integral part of SFI’s decision making process. The purpose of external review is to gather expert evaluations from appropriate field experts so that SFI can make an informed decision regarding a proposal.
Review panels comprise of reviewers with complementary knowledge who also possess broad knowledge of the science and engineering sub‐fields relevant to the proposals to be reviewed. For the specific evaluation of potential impact, reviewers will be identified with expertise in research translation, commercialisation and with industry experience and/or experience in collaboration with industry.
Reviewers assist in the process and make funding recommendations but do not make funding decisions. The final responsibility for evaluation and award decision lies with SFI.
Reviewers engaged by SFI are required to abide by the following code of conduct:
- Reviewers appointed by SFI are required to operate in a confidential, fair, independent and equitable manner according to the procedures described in this code of conduct, in any programme-related documentation and by any other instruction(s) communicated by SFI.
- Reviewers are appointed as independent experts and are deemed to work in a personal capacity and, in performing the work, do not represent any organisation.
- An essential part of ensuring research integrity is managing conflicts of interest that may bias the review of an application. SFI scientific staff are charged with identifying appropriate reviewers and managing reviewer conflicts of interest. Reviewers must agree to certify to a declaration of absence of conflict of interest before conducting a review. If a reviewer is in some way connected with a proposal, or has any other allegiance which impairs or threatens to impair their impartiality with respect to a proposal, they must declare such facts to the responsible SFI staff member(s) as soon as they become aware of this. If a reviewer is unsure as to whether or not a conflict of interest exists, they should consult with the appropriate SFI staff member(s). If a potential conflict of interest arises during the course of a review process, a reviewer must alert the relevant SFI scientific staff member to this and the situation will be managed appropriately.
- Reviewers must agree to certify to a declaration of confidentiality prior to conducting a review. Reviewers must not copy, quote, or otherwise use or disclose to anyone, including their own graduate students or post-doctoral or research associates, any unpublished material from any programme they are asked to review. If reviewing proposals they must keep confidential the name of the applicant and the evaluation conducted. Reviewers must not disclose their identities, the relative assessments or rankings of proposals by a peer review panel, or other details about the peer review of proposals.
- Reviewers are required to perform all activities undertaken for SFI with reasonable skill and care and to the best of their ability.
- Reviewers must undertake all activities in a personal capacity and must not delegate or sub-contract the performance of any activities or part thereof to graduate students, post-doctoral or research associates or any other third parties.
- Reviewers are required at all times to comply with generally accepted rules of good scientific practice in carrying out their review, including any specific scientific code of practice notified by SFI to reviewers from time to time.
- Reviewers may not communicate with proposal applicants at any stage unless they are required to do so as part of the evaluation process (for example, if an interview or site visit forms part of the evaluation process). In cases where reviewers are required to communicate with applicants as part of the evaluation process, communication must only happen in the presence of SFI staff members.
- Reviewers are required to respect the intellectual property of applicants and may not appropriate and use as their own, or disclose to any third party, ideas, concepts or data contained in any proposals. The intellectual property rights in all materials provided by an applicant shall remain vested in and shall be the absolute property of the applicant or its third party licensors.
- In cases where proposals are to be made available to reviewers, who then work from their own or other suitable premises, the reviewers will be held personally responsible for maintaining the confidentiality of any documents or electronic files sent and returning, erasing or destroying all confidential documents or files upon completing the evaluation. In such instances, reviewers may seek further information (for example through the internet, specialised databases etc.) in order to allow them to complete their examination of the proposals, provided that obtaining such information respects the overall rules for confidentiality and impartiality. Reviewers may not show the contents of proposals or disclose information contained therein to third parties without the express written approval of SFI.
- Where the evaluation takes place in an office or building controlled by SFI, reviewers are not permitted to take outside the evaluation building any parts of proposals, copies or notes relating to the evaluation of proposals.
- Reviewers are required at all times to comply with any rules defined by SFI for ensuring the confidentiality of the evaluation process and its outcomes, including as set out in this SFI Reviewer Code of Conduct and SFI’s Reviewer Conflict of Interest and Confidentiality Statement. Failure to comply with these rules may result in exclusion from the immediate and future evaluation processes, without prejudice to penalties that may derive from other applicable regulations.
- Reviewers must agree that SFI may use SFI’s online Grants and Awards Management System (SESAME, or any other online grants and awards management system as adopted by SFI from time to time) as a means of communication between reviewers and SFI or to deliver materials for review by reviewers. In such case, reviewers will be able to access SFI’s online Grants and Awards Management System from any computer with their email address and password.
- To the extent that membership of a Review panel or the performance of activities as a Reviewer involves the processing of personal data on behalf of SFI, reviewers must agree to process the personal data solely in connection with the review, or as otherwise instructed by SFI, and to comply with data security obligations in respect of the Data Protection Acts 1988 and 2003.
- Reviewers must agree to act justly in conducting a review for SFI. A review must be conducted with integrity, impartiality and confidentiality and without bias on the basis of gender, race, colour, age, disability, national origin, sexual orientation, political or religious affiliation or marital status. Reviewers are requested to review and consider the guidance provided to aid reviewers in the understanding of unconscious bias [Reproduced by kind permission of The Royal Society].
- In order to participate in a review for SFI, individuals are required to agree to SFI’s Reviewer Conflict of Interest and Confidentiality Statement.
View the SFI Reviewer Code of Conduct
SFI Open Access Policy
Where a research publication arises in whole or in part from SFI funded research (i.e. where one or other of the researchers concerned receives SFI funds in support of their endeavours), the SFI Open Access Availability of Published Research Policy will be adhered to with effect from 1 February 2009.
The intellectual effectiveness and progress of the widespread research community will be continually enhanced where the community has access and recourse to as wide a range of shared knowledge and findings as possible. This is particularly the case in the realm of publicly funded research where there is a need to ensure the advancement of scientific research and innovation in the interests of society and the economy, without unnecessary duplication of research effort. This publication policy confirms the freedom of researchers to publish first wherever they feel is the most appropriate.
The costs of publishing or depositing in an Open Access repository are allowable as an Eligible Cost under SFI Awards and should be charged against the Miscellaneous budget line. For more information visit RIAN – Irish Open Access Depository.
SFI Appeals Process
This policy establishes procedures and responsibilities for the appeal of the declination of a proposal by SFI.
In making its decision regarding funding, SFI takes into account the peer review assessments of the scientific and technical merits of a proposal, but also the value to Ireland of the research programme, the budget availability and programmatic priorities of the Foundation. Proposals are evaluated in open competitions via a combination of international peer review and strategic fit with SFI’s mission. In addition to the principles espoused by SFI’s core values, SFI uses the following principles in reaching its funding decisions: value for money, strategic impact, efficient use of the peer review system, internationalisation, critical mass, cohesion with other funding streams, and availability of funding.
The primary aim of the SFI appeals procedure is to ensure that SFI's review process itself has been fair and reasonable and that SFI’s stated review procedures were followed. Although the appeal procedure is not a peer review process itself and will not re-open such a peer review process, it may address procedural errors in the peer review process, or other aspects of proposal review including: unaccounted-for conflicts of interest, inappropriate consideration of rumour / hearsay, or incomplete / inconsistent documentation being made available to the reviewers. SFI would like to emphasise that in all such cases a robust argument must be articulated and that the appeal will subsequently follow the specific procedures outlined in section 2.
It is appreciated that applicants may, from time to time, disagree with the detailed technical perspective of the expert referee, or their position on the overall quality or impact of the proposed research. However, SFI has full confidence in the high quality of experts that it engages in the peer review process and takes the position that this source of expert input allows SFI to make the best and most informed decisions. The judgment, interpretation, or level of understanding of these experts is, therefore, not grounds for appeal.
SFI now has in place a formal process integrated into some of its programmes, whereby applicants are invited to provide a scientific response. In programmes where this response stage does not form part of the SFI review process, an appeal may be accepted where specific factual inaccuracies can be clearly identified. Otherwise, appeals must be limited to clearly identifiable issues of procedure. The process required for invoking the formal process of appeal is outlined in detail in section 2.
Regarding appeals made prior to full technical peer review of a proposal; SFI remains confident that the procedures for submission of EoIs, pre-proposals and full proposals are clearly delineated in the call documentation and that it remains the responsibility of the applicant to ensure that these are followed correctly. For this reason, appeals based on applications that have been deemed administratively ineligible, including, but not restricted to, late applications, applications exceeding page limits or missing documentation, will not be considered unless it can be explicitly demonstrated that this resulted from an oversight by SFI.
Appeals based on funding levels, or award conditions on applications that have been approved for funding, will not be considered.
Award of SFI funding is discretionary and the appeal process is not an adversarial one. A formal hearing, therefore, is not provided. Factors such as programme budgets and priorities will have to be taken into account when making a decision on an appeal.
The appeal process at SFI has three stages:
(A) Explanation by the SFI programme manager or scientific director
An applicant whose proposal has been declined is encouraged to request more information from the cognizant SFI Programme Manager, over and above the explanatory materials received with the declination notice. The Programme Manager will afford the applicant an opportunity to present his/her point of view, will provide additional information if any exists, and will take any further action that seems appropriate in consultation with the relevant SFI Scientific Director.
(B) Review of the appeal by an SFI director not involved in the original review
If dissatisfied with the explanation or action provided under Section (a), the applicant may submit a written request to the Secretary to the SFI Board that SFI reconsider its decision. SFI will consider such a request only if the applicant has first sought and obtained an explanation under the procedures described in Section (a), only if the request is received by SFI within 30 days after the date of the declination notice, and provided that the applicant’s request for an appeal has been sent through the research office of the applicant’s host Research Body and is endorsed by the host Research Body (VP for research or equivalent). In the letter requesting the appeal, the applicant should state whether the appeal is based on a) factual inaccuracy (only applicable to awards that do not already include a rebuttal process) or b) procedural error. The applicant should also provide a concise written statement (no more than 300 words) clearly explaining the grounds for the appeal. The Secretary to the Board will forward the request to a Director at SFI who was not involved in the original review of the proposal. This Director will reconsider the record to determine whether SFI's review of the declined proposal was fair and reasonable. The Director may personally conduct the review or may designate a Programme Manager in his/her Programme area, who had no part in the initial review, to do so.
Within 30 days after the date of the request, the Director will provide the results of the appeal, in writing, to the research office of the host Research Body with a copy to the applicant. If the results cannot be furnished within 30 days, the allocated Director will give the host Research Body and the applicant a written explanation of the need for more time, indicating the date when results can be expected.
(C) Further review by the Director General at the request of the host research body
Within 30 days after the Director has notified the applicant of the results of the appeal, the host Research Body may request further review by the Director General of SFI.
The request need not be in any particular format, but it must be in writing and must be signed by the President/Provost/Chief Executive Officer of the host Research Body and by the PI. The request should explain why the host Research Body still believes that an error may have occurred in the initial evaluation and why it is not satisfied with the review of the original appeal conducted by the Director under the procedures described in Section (b), above.
The Director General is responsible for reviewing the request for a further appeal and the record of earlier SFI actions (including the original review of the proposal and the review conducted under Section (b). The Director General may personally conduct the further review or may designate another SFI official, who had no part in the original review or the review conducted under Section (b), to do so. Additionally, an external third party expert(s) may be asked to examine the case and to present a recommendation. Within 30 days after a request for further appeal is received at SFI, the Director General will furnish the results of the further appeal, in writing, to the host Research Body. If results cannot be furnished within 30 days, the Director General will provide the host Research Body with a written explanation of the need for more time, indicating the date when the results can be expected.
The decision made by the Director General is final. The SFI will review this policy on a regular basis and may update it from time to time. Policy updates will be effective on the date that the update is posted on the SFI website. Please check the SFI website regularly for updates.