Policy Title: Research Integriry Policy

Policy Area: Research Policy

Owner: Policy Office

Approved by: UM6P President

Effective Date: December 22, 2023

RELATED DOCUMENTS

Review of Alleged Research Misconduct Procedure; Conflict of Interest in Research Policy; Research Data Management Policy; UM6P Conflict of Interest; Authorship and Publication of Results Policy.

SECTION 1   POLICY STATEMENT

1.1. University Mohammed VI Polytechnic (UM6P) fosters an environment that promotes responsible research conduct, provides training, and establishes and maintains an infrastructure and governance that promotes good training and research practice.

1.2. All persons engaged in research at UM6P adhere to the highest standards of research integrity to protect the accuracy and reliability of the research record and published results. UM6P promotes the highest level of integrity in research and scholarly activity conducted by its faculty, students, and research staff through established and clearly communicated provisions, guidelines, and procedures. Failure to comply with these principles and rules is considered a serious misconduct.

1.3. UM6P inquiries into and, if necessary, investigates and resolves in a timely and fair manner, all instances of alleged research misconduct in accordance with the adversarial principle, Individuals accused of research misconduct are presumed innocent of any allegations until the contrary has been established and provided that the misconduct is proved by a final decision reached under this policy document and the related Review of Alleged Research Misconduct

SECTION 2   SCOPE AND APPLICABILITY

2.1. This policy applies to all research and scholarship activities conducted within UM6P, irrespective of the funding source.

2.2. This policy does not address, and specifically excludes, sexual harassment or discrimination and other general matters not within the definition of research misconduct, and criminal matters.

2.3. Because of the inherent unfairness and the difficulties presented by any attempt to assess stale evidence, allegations of research misconduct based on events that occurred five or more years will not be subject to review under this policy.

SECTION 3   PURPOSE

3.3. The purpose of this policy document is to promote the university’s compliance with best practices for conducting research.

3.4. The policy is intended to protect the integrity and reputation of the university and its scholars from false or unproven allegations of research misconduct.

3.5. This policy document aims to explain the expected conduct of individuals associated with UM6P who are engaged in research activities for the purpose of ensuring proper conduct and deterring research misconduct through awareness of basic principles.

SECTION 4   DEFINITIONS

The following definition(s) apply to this policy document:

4.1. Allegation refers to any evidence found by, or a written or oral statement of possible research misconduct made to, any UM6P leader or the Research Integrity Officer (RIO), including heads of departments and deans.

4.2. Complainant refers to an individual who, in good faith, submits an allegation of research misconduct.

4.3. Conflict of Interest refers to a divergence between a faculty member’s interests and such faculty member’s professional obligations to UM6P, such that an independent observer might reasonably question whether the individual’s professional actions or decisions are determined by considerations other than the best interest of UM6P.  Conflict of Interest is a circumstance in which a researcher’s financial, or non-financial, interest or obligation may have the potential to bias research or negatively impact the research and decisions.

4.4. Deciding Official (“DO”) is the person who makes final determinations on reports of scientific misconduct and any responsive institutional actions. The President (or designee) is the Deciding Official for UM6P.

4.5. Faculty member refers to professors, associate professors, assistant professors, and instructors, including individuals designated as “visiting” or “adjunct,” within the departments, colleges, heads, laboratories, and research centers operating as part of UM6P.

4.6. Good faith allegation refers to an allegation made with the honest belief that research misconduct may have occurred. An allegation is not in good faith if it is made with knowing or reckless disregard for information that would negate the allegation or testimony or willful ignorance of facts that would disprove the allegation.

4.7. Inquiry refers to the initial process and preliminary information gathering activities for determining whether an allegation or apparent instance of research misconduct warrants an investigation.

4.8. Intent and Recklessness in research misconduct implies intentional or reckless behavior or a repeated pattern.

4.9. Investigation refers to the formal examination and evaluation of all available relevant facts to determine if research misconduct has occurred in respect with the adversarial principle, if so, to determine the responsible person(s) and the seriousness of the research misconduct.

4.10. Preponderance of the evidence means proof by information that, compared with that opposing it, leads to the conclusion that the fact at issue is more probably true than not.

4.11. Research refers to any systematic investigation, including research development, testing, reporting, study, evaluation, demonstration, or survey designed to develop or contribute to generalizable knowledge or specific knowledge by establishing, discovering, developing, elucidating, or confirming information about, or the underlying mechanism relating to the matters to be studied. The term encompasses basic research, applied research, and research training activities.

4.12. Research Activities is proposing, conducting, reviewing, or reporting the results of research or other scholarly inquiry.

4.13. Research Integrity Officer (“RIO”) refers to the UM6P official appointed by the President to have primary responsibility for implementing and adhering to these procedures. The Research Integrity Officer has primary institutional responsibility for assessing all reports of research misconduct and determining when such reports warrant inquiries and for overseeing inquiries and investigations. The Policy Office Lead is the Research Integrity Officer for UM6P.

4.14. Research misconduct refers to behaviors that deliberately or recklessly fall short of the expected standards in research, from conception to reporting. It encompasses fabrication, falsification, or plagiarism in proposing, performing, reviewing, or reporting research. For detailed descriptions of what is included, please see the Review of Alleged Research Misconduct procedure document.

4.15. Research misconduct at UM6P is Research Misconduct pertaining to Research Activities conducted at UM6P or by UM6P academics, fellows, students, and others with UM6P appointments elsewhere as part of their UM6P-related research duties or activities.

4.16. Research staff include, but are not limited to, administrators who support research activities, clinical research coordinators, individuals specifically granted Principal Investigator status, visiting scholars and other individuals conducting research including post-doc.

4.17. Research record means any data, document, computer file, computer diskette, or any other written or non-written account or object that reasonably may be expected to provide evidence or information regarding the proposed, conducted, and/or reported research that constitutes the subject of an allegation of scientific misconduct. A research record includes, but is not limited to, grant or contract applications, whether funded or unfunded; grant or contract progress and other reports; laboratory notebooks; notes; correspondence; videos; photographs; x-ray film; slides; biological materials; computer files and printouts; manuscripts and publications; equipment use logs; laboratory procurement records; animal facility records; human and animal subject protocols; consent forms; medical charts; and patient research files.

4.18. Respondent means the person against whom an allegation of research misconduct is directed or who is the subject of a research misconduct proceeding.

4.19. Retaliation means an adverse action taken against a complainant, witness, or committee member by UM6P or one of its employees in response to a good faith allegation of research misconduct or of inadequate response there to, or good faith cooperation with a research misconduct proceeding.

4.20. Sequestration refers to the collection and segregation of research records, equipment, and other tangible or intangible information for the specific purpose of assessing allegations as part of the research misconduct process. The Office of Research Governance, under the direction of the Research Integrity Officer, has the authority and responsibility for sequestration of research records relative to research misconduct allegations. All appropriate rights are accorded to the respondent in the act of sequestrating research records, as outlined in the Role and Responsibilities of the Respondent section of this procedure.

4.21. Sponsored Programs refers to research, training and instructional projects involving funds, materials, gifts, or other compensation from external governmental or non-governmental organizations under agreements with UM6P.

4.22. Students refer to those individuals enrolled or participating in an academic program within UM6P.

4.23. Trainee refers to an individual who is enhancing their research skills through actual involvement in research and who works under the formal supervision of a researcher including, but not limited to, pre-doctoral and post-doctoral trainees and fellows.

SECTION 5   PROVISIONS AND GUIDELINES

General Provisions

5.1. University Mohammed VI Polytechnic (UM6P) strives to provide an open and stimulating environment for creativity and individual thought where faculty and staff members develop independently and productively. It is intended that this climate will promote high ethical standards and enhance the research process.

5.2. UM6P researchers maintain the highest ethical standards of intellectual honesty and integrity in research. The university develops and disseminates a clear research UM6P Code of honor and research core values that are aligned with international standards. The published policies and guidelines cover, at a minimum, the following topics: collaborative research, conflict of interest in research, human subjects research, animal research, research data management, avoiding plagiarism, authorship, peer review participation, and research misconduct.

5.3. Open publication of research results (see Authorship and Publication of Results), emphasis on quality of research, maintenance of accurate and detailed research procedures and data (see Research Data Management), and proper assignment of credit for research and publications are essential for creating an environment for intellectual honesty and integrity in research. Those engaging in research and scholarship at UM6P will always, and without exception, adhere to the following basic principles:

5.3.1. The highest professional standards in designing, scoping, conducting, and communicating research and investigations;

5.3.2. A critical, honest, and open-minded approach in conducting research and in analyzing data;

5.3.3. Honesty and fairness with regard to the contribution of colleagues, whether collaborators or competitors;

5.3.4. Efficient use of UM6P resources;

5.3.5. Absolute honesty at all stages of inquiry is preserved, in particular, by avoiding:

5.3.5.1. Any form of fraud, such as fabricating or falsifying data;

5.3.5.2. Piracy or plagiarism;

5.3.5.3. Sabotaging the work, records or protocols of other researchers;

5.3.5.4. Breach of expected confidentiality as a researcher, as a reviewer, as a meeting attendee, or as a supervisor;

5.3.5.5. Misrepresentation of authorship;

5.3.5.6. Unreasonable delay of review or publication for personal gain.

5.3.5.7. Complicity in any such actions as described under 5.3.5.1 to 5.3.5.6 above.

5.4. Integrity Training The university provides training to faculty, staff and other individuals involved in research to promote the responsible and ethical conduct of research.

5.4.1. UM6P publishes and distributes guidelines for ethical research. The guidelines shall present a comprehensive approach covering all aspects of research, applicable across the whole disciplinary spectrum.

5.4.2. Everyone involved in research at UM6P commits to adhere to and respect the published guidelines. Failure to do so may result in disciplinary action.

5.5. Data Management, Storage and Retention UM6P faculty and staff abide by published UM6P policies, guidelines and procedures related to data management storage and retention (see Research Data Management policy).

5.6. Confidentiality in Conducting Research

5.6.1. Researchers are required to abide by UM6P policies related to confidentiality of information. When accessing the work of others, researchers must seek permission from the originator of the research work regarding the extent of confidentiality that is required before details or ideas can be discussed with others.

5.6.2. In collaborative research, confidentiality agreements/non-disclosure agreements are a possibility. UM6P researchers may be required to sign a confidentiality agreement before commencing work on the project and are required to abide by the terms of any such agreement.

5.6.3. When research is undertaken in accordance with a contractual agreement or under commercial sponsorship, the ownership of and responsibilities for research data and records shall be determined prior to commencement of the research contract and must be specified in the research contract. It is the responsibility of the Principal Investigator to review the research contract before initiation of work to ensure that all forms of confidentiality are understood.

5.7. Authorship UM6P upholds and supports the principle that publication of research results and other scholarly work is an intrinsic part of any research endeavor. Publication and authorship must be approached in a responsible manner, adhering to ethical principles and internationally accepted standards (see Authorship and Publication of Results).

5.7.1. Disputes over Authorship: The Principal Investigator or lead author, in collegial consultation with the other authors, shall resolve disagreements over authorship. If the authors themselves cannot resolve authorship disputes, the relevant head of department should be consulted to achieve resolution (see Authorship and Publication of Results for more details).

5.8. Publication When publishing results of research or making any public statement about one’s research, all reasonable steps must be taken to ensure that published reports, statistics and public statements about research activities and performance are accurate.

5.8.1. Inclusion of inaccurate or misleading information relating to research activity in curriculum vitae, grant applications, job applications or other such materials is unethical and prohibited. Such action may result in disciplinary action.

5.8.2. Academic affiliations must be accurately represented in publications. Indication of a current affiliation with a university where the researcher does not have a formal, current appointment, whether paid or unpaid, is prohibited. In the case of reporting on research that was performed during a time where a previous appointment was in place and under the auspices of that prior affiliation, that prior affiliation should be noted in the acknowledgements.

5.8.3. Publication of multiple papers reporting the same research results is not acceptable, except where the papers fully acknowledge the respective other publications. An author who submits substantially similar work to more than one publisher must disclose this to the publishers at the time of submission.

5.9. Conflict of Interest in Sponsored Research University and external research sponsors promote objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct and reporting of research will be free from bias or the perception of bias resulting from financial interests. As such, UM6P faculty and staff are required to abide by all university policies and procedures related to conflict of interest (see, for example, Conflict of Interest in Research).

Research Misconduct

5.10. Research Misconduct Breaches of good practice are considered to be research misconduct incidents. UM6P defines research misconduct to include, but not be limited to, fabrication, falsification, or plagiarism in proposing, performing, reviewing, or reporting research:

5.10.1. Fabrication involves creating and reporting false data or results.

5.10.2. Falsification includes manipulating research materials, equipment or data, leading to misrepresented research in records.

5.10.3. Plagiarism refers to using someone else’s ideas, processes, results, or words without proper credit.

5.10.4.Failure to meet legal, ethical and professional obligations, for example:

5.10.4.1. Misuse of personal data, including inappropriate disclosures of the identity of research participants and other breaches of confidentiality;

5.10.4.2. Improper conduct in peer review of research proposals, results or manuscripts submitted for publication. This includes failure to disclose: conflicts of interest; inadequate disclosure of clearly limited competence; misappropriation of the content of material; and breach of confidentiality or abuse of material provided in confidence for the purposes of peer review.

5.10.5. Research misconduct also includes misrepresentation of:

5.10.5.1. data, including suppression of relevant results/data or knowingly, recklessly or by gross negligence presenting a flawed interpretation of data;

5.10.5.2. involvement, including inappropriate claims to authorship or attribution of work and denial of authorship/attribution to persons who have made an appropriate contribution;

5.10.5.3. qualifications, experience and/or credentials;

5.10.5.4. publication history, through undisclosed duplication of publication, including undisclosed duplicate submission of manuscripts for publication.

5.10.6. Conducting research without required ethical approvals (see Human Subjects Research policy and Animal Use and Care policy), permits, or licenses,

5.10.7. Failing to conduct research as approved by the ethics review body;

5.10.8. Misuse of research funds;

5.10.9.Breaches of confidentiality and privacy where human subjects are concerned and not avoiding unreasonable harm or risk; and

5.10.10. Failing to meet legal, ethical or professional requirements.

5.11. Research misconduct excludes honest errors or differences of opinion.

5.12. Responsibility to Report Research Misconduct Allegations of research misconduct may be filed by anyone, whether or not associated with UM6P. All persons associated with the university are expected to report any concerns regarding possible research misconduct (see the Procedures for the Review of Allegations of Research Misconduct for details on how to report). If an individual is uncertain about whether the concern qualifies as research misconduct, they may contact the Research Integrity Officer (RIO) to discuss the concern informally and confidentially. If the circumstances described by the individual do not meet the definition of research misconduct, the RIO may refer the individual or allegation to other offices (e.g., Human Capital office) with responsibility for resolving the concern as necessary and appropriate.

5.13. Requirements for Findings of Research Misconduct A finding of research misconduct requires that:

a. There be a significant departure from accepted practices of the relevant research community; and

b. The research misconduct be committed intentionally, knowingly, or recklessly; and

c. The allegation be substantiated by a preponderance of evidence.

5.14. Cooperation with Inquiries and Investigations Individuals covered under this policy must cooperate with the RIO and other UM6P officials in the review of allegations and during inquiries and investigations. Such individuals also have an obligation to provide relevant information to the RIO or other university officials about research misconduct allegations. Failure to cooperate is a violation of this policy document and may result in disciplinary action.

5.15. Protection and Restoration of Reputations

5.15.1. Respondents Inquiries and investigations are conducted in a manner that ensures fair treatment to the respondent and confidentiality to the extent possible, without compromising public health and safety or thoroughly carrying out the needs of an inquiry and/or investigation.

5.15.1.1. In proceedings where the respondent is not found to have committed research misconduct, the university may, to the extent possible, work with the respondent to rectify any injury done to the reputation of respondent, including providing a letter of the results of the investigation.

5.15.2. Complainants University officials who receive or learn of a report of research misconduct will treat the complainant with fairness and respect and, when the report has been made in good faith, will take reasonable steps to protect and restore the position and reputation of any complainant, witness, or committee member and to counter potential or actual retaliation against those complainants, witnesses and committee members.

5.16. Interim Protective Actions At any time during a research misconduct proceeding, the university may take appropriate interim actions to protect public health, research funds and equipment, and the integrity of supported research processes. The necessary actions will vary according to the circumstance of each case, but actions that may be necessary include: 1) delaying the publication of research results, 2) providing for closer supervision of one or more researchers, 3) requiring approvals for actions relating to the research that did not previously require approval, 4) auditing pertinent records, or 5) taking steps to contact other entities that may be affected by an allegation of research misconduct. Such administrative actions will not be deemed disciplinary in nature.

5.17. Confidentiality in Research Misconduct Inquiries and Investigations Efforts will be taken to ensure confidentiality is maintained. Disclosure of the identity of respondents and complainants in research misconduct proceedings is limited, to the extent possible, to those who need to know, consistent with a thorough, competent, objective and fair research misconduct proceeding, and as allowed by law. The applicable laws and regulations may require the university to disclose the identity of respondents and complainants to oversight agencies, should they exist. Examples of when a release of information may occur include, but are not limited to, the following circumstances:

5.17.1. As required by the rules of, or contract with, a funding entity;

5.17.2. As required by the need to inform the research community of the conclusions reached in order to protect the integrity of the research involved;

5.17.3. As part of a disciplinary sanction imposed;

5.17.4. As deemed necessary by the RIO and Deciding Official (DO) to protect the legitimate interest of human subjects involved in the research;

5.17.5. As deemed necessary by the RIO and DO, whether or not proceedings external to the university (investigations or oversight review) are ongoing;

5.17.6. At the request of the respondent; or

5.17.7. As required by law.

The RIO, in consultation with the DO, is responsible for determining when a release of information is necessary or appropriate. During the research misconduct proceedings, if release of information outside the university is deemed necessary, the respondent will be informed of the release.

The goal of maintaining confidentiality does not prohibit university officials from consulting, on a confidential basis and to the extent necessary, with persons within or outside the university with relevant experience or expertise to thoroughly investigate the allegations. Nor does it prohibit university officials from disclosing information, on a need-to-know basis, to individuals responsible for oversight of the respondent’s research activities or to other university officials involved in the questioned research, such as head of department or deans.

Except as may otherwise be prescribed by applicable law, confidentiality must be maintained for any records or evidence from which research subjects might be identified. Disclosure is limited to those who have a need to know to carry out a research misconduct proceeding.

5.18. Legal Counsel The presence of legal counsel at the proceedings of the inquiry and investigation committees shall be at the sole discretion of the committees. The respondent(s) will be informed that the university’s Legal Department serves as an advisor to the university and cannot render advice to the respondent(s), but that the respondent(s) may obtain their own legal advisor at any time during the proceedings established by this policy document and related procedural documents. The respondent(s) will be informed that any person, including other university personnel such as the ombudsperson, can act as an advisor as long as that person’s university position does not have any formal role in the process.

5.19. Deadlines Due to the sensitive nature of allegations of research misconduct, each complaint will be resolved as expeditiously as possible. The nature of some complaints may render normal deadlines difficult to meet. If a procedural deadline set forth in the Procedures for the Review of Allegations of Research Misconduct cannot be met during the research misconduct proceeding, the RIO will review and approve, where appropriate, requests for additional time.

5.19.1. The term “day” as used in this policy means “calendar day.” If the last day of a designated time period falls on a weekend or a day on which the university is closed, the time period will expire at the close of business on the next succeeding business day.

5.20. Termination of University Affiliation by Respondent If a respondent terminates affiliation with the university before a research misconduct matter is resolved, the proceedings under this policy will continue, to the extent possible, until a final determination is reached.

5.21. Correction of Research Record The university has the responsibility to identify whether correction or retraction of published or submitted work is required to ensure the integrity of the scientific record is maintained.

5.21.1. If research misconduct is found under this policy and falsified, fabricated, or plagiarized research has been published or submitted, including within grant proposals, the respondent must work with the RIO and any other university officials or publishers to correct, retract, or withdraw the research record.

5.21.2. If research misconduct is not found under this policy, but falsified, fabricated, or plagiarized research has been published or submitted, including within grant proposals, due to honest error or for any other reason, the RIO working with the researchers involved will seek to correct, retract, or withdraw the research record.

5.21.3. The university may request correction or retraction of the published work at any time during the research misconduct proceedings or during a resolution with the respondent(s) when there is clear evidence of falsified, fabricated, or plagiarized research. The correction or retraction may occur before a final determination of research misconduct against a respondent has been made or if the university finds there are no research records available to support the published or submitted research.

5.22. Reopened Complaints Any complaint that has been closed with a determination that research misconduct did not occur may be reopened only if, in the opinion of the RIO in consultation with the DO, new and potentially significant information of research misconduct, not previously considered, has been presented.

5.23. Conflicts of Interest in Research Misconduct Inquiries and Investigations

In compliance with the adversarial principle, throughout the process the university will take precautions to ensure that the response to allegations is conducted in a thorough, competent, objective and fair manner, including precautions to ensure that individuals responsible for carrying out any part of the research misconduct proceeding do not have unresolved personal, professional or financial conflicts of interest with the complainant, respondent or witnesses.

SECTION 6   RESPONSIBILITIES

6.1. The Policy Office (PO) is responsible for developing and disseminating a clear research code of honor and research core values as part of the UM6P Guidelines for Good Research Practice.

6.2. The PO prepares and makes available for the academic community, including by posting it on the UM6P internal web portal, additional detailed guidelines and procedures related to this policy document.

6.3. The Research Integrity Officer (RIO) is responsible for facilitating an impartial investigation of allegations of misconduct or breaches of good practice.

6.4. The UM6P Human Capital and Legal Departments are responsible for assuring the rights and confidentiality of both the complainant and the respondent.

6.5. PO is responsible for ensuring necessary policies and procedures are in place to manage conflicts of interest in research, guide human subjects research, guide animal research, and articulate data management requirements.

SECTION 7   REVIEW AND MONITORING STATEMENT

7.1. This policy document is reviewed once every four (4) years, or more frequently when requested by the president or subsequent to changes in regulations or accreditation requirements.