RELATED DOCUMENTS:

UM6P Research Integrity Policy; UM6P Code of Honor; Non-Retaliation and Whistleblower Policy; Research Data Management Policy; Plagiarism Policy; Research Conflict of Interest Policy.

SECTION 1: STATEMENT

1.1. UM6P is dedicated to ensuring all research activities are conducted with the highest ethical standards.

1.2. UM6P strictly prohibits any form of retaliation against individuals with its community who, in good faith, report about perceived unlawful conduct, or who participate in investigation related to such conduct.

SECTION 2: PURPOSE

2.1. It is the policy of University Mohammed VI Polytechnic (UM6P) to inquire into and, if necessary, to investigate and resolve in a timely and fair manner all instances of alleged research misconduct. In carrying out its research mission, all persons engaged in research are expected to adhere to the highest standards of research integrity to protect the accuracy and reliability of the research record and published results.

2.2. The purpose of this document is to promote UM6P’s compliance with its policies and UM6P Code of Honor, to implement best practices for dealing with research misconduct, and to protect the integrity and reputation of UM6P and its research community from false or unproven allegations of research misconduct. Failure to comply with these principles and rules is considered a serious misconduct.

SECTION 3: SCOPE AND APPLICABILITY

3.1. This procedure applies to all research activities conducted at, for, or on behalf of UM6P, and to all individuals involved with research activities, including faculty, scientists, trainees, technicians, staff members, students, fellows, visiting scholars, guest researchers, consultants, and collaborators.

3.2. Individuals accused of research misconduct are presumed innocent of any allegations until the contrary has been established by a final decision reached through the procedures detailed in this document.

SECTION 4: DEFINITIONS

The following definition(s) apply to these procedures:

4.1. Allegation refers to any formal claim in a written or oral way that states of possible research misconduct made to the Research Integrity Officer (RIO).

4.2. Bad faith allegation refers to an allegation that is not made in good faith with knowing or reckless disregard for information that would negate the allegation or testimony or willful ignorance of facts that would disprove the allegation.

4.3. Complainant refers to an individual who, in good faith, makes an allegation of research misconduct. A complainant can be the victim or witness of a research misconduct.

4.4. Conflict of Interest refers to a situation in which financial or other personal considerations may compromise or appear to compromise professional judgment or integrity in the conduct or reporting of research.

4.5. 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.

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

4.7. 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.

4.8. 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, 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 Activitiesrefers to proposing, conducting, reviewing, or reporting the results of research or other scholarly investigation.

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 an investigations. The Policy Office Lead is the Research Integrity Officer for UM6P.In the case of conflict of interest: RIO conflicted in any way regarding the nature, source or involved parties in the allegation, the RIO should inform top management to nominate another person to fulfill this role.

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.

4.14.1. Fabrication refers to creating and reporting false data or results.

4.14.2. Falsification refers to manipulating research materials, equipment, or processes, or changing or omitting data or results such that the research is not accurately represented in the research record.

4.14.3. Plagiarism refers to the use of other people’s work and ideas without proper reference to the original source.

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

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

4.15. Research misconduct includes misrepresentation of:

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

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

4.15.3. Qualifications, experience and/or credentials; and

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

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

4.16. Research misconduct proceeding refers to any actions related to alleged research misconduct taken under this part, including but not limited to, allegation assessments, investigations, hearings, and administrative appeals.

4.17. Research Support 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.

4.18. Research record refers to 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.

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

4.20. Retaliation constitutes any act, whether conducted directly or indirectly through proxies, targeting an individual due to their sincere reporting of an accusation regarding the infringement of university policy, rule, or regulation, or their involvement in any capacity in the investigation of such an accusation, or with the intent to dissuade an individual from taking such actions.

4.21. 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.

4.22. 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.

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

4.24. 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: PROCEDURES AND GUIDELINES

5.1. Reporting Suspected Research Misconduct

5.1.1. Allegations of research misconduct may be filed by anyone, whether or not associated with UM6P. All persons associated with UM6P should report promptly any concerns regarding possible research misconduct. If an individual is uncertain about whether the concern qualifies as research misconduct, they may contact the RIO via fatima.elyousfi@um6p.ma 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 with responsibility for resolving the concern as necessary and appropriate.

5.1.2. Allegations should be made in writing to the RIO or any other university leader, who in turn will forward them to the RIO. All allegations should be supported by evidence.

5.2. General Procedure

5.2.1. The procedures for evaluating and responding to allegations of research misconduct proceed in two stages:

1. A preliminary assessment of the allegations to determine if the report requires further investigation.
2. An investigation to make definitive findings of fact and reach conclusions.

5.2.2. A finding of research misconduct requires that:

• There be a significant departure from accepted practices of the relevant research community;
• The misconduct be committed intentionally, knowingly, or recklessly; and
• The allegation be proven by a preponderance of evidence.

5.3. Preliminary Assessment of the Allegation

5.3.1. Allegation Assessment

5.3.1.1. Allegations of research misconduct should be reported to the Research Integrity Officer (RIO) who will determine if the allegations fall under the definition of research misconduct as defined by this policy and whether the report requires further attention and investigation. The purpose for the preliminary assessment is to determine the appropriate roles and responsibilities of UM6P, its personnel, and oversight agencies with respect to evaluating the allegations, as well as to identify individuals, information, and data relevant to the allegation.

5.3.1.2. Upon receiving an allegation of research misconduct, the RIO will immediately assess the allegation to determine whether it is sufficiently credible and specific so that potential evidence of research misconduct may be identified if the allegations fall under the definition of research misconduct as defined by this policy.

5.3.1.3. The assessment period should be brief, preferably concluded within one w In conducting the assessment, the RIO need not interview the complainant, respondent, or other witnesses, or gather data beyond any that may have been submitted with the allegation, except as necessary to determine whether the allegation is sufficiently credible pecific so that potential evidence of research misconduct may be identified.

5.3.1.4. If the RIO determines that the criteria for an investigation are met, the investigation process should be initiated immediately.

5.3.2. Determination to Dismiss an Allegation

5.3.2.1. If, after assessing the allegation, the RIO finds that the allegation does not warrant further action and/or does not meet the definition of research misconduct as defined in the policy, the RIO will formally dismiss the allegation. The RIO need not notify the respondents of such allegations but will notify the complainant that the allegations will not be pursued under UM6P’s policy on Research Integrity.

5.3.2.2. The RIO will document the determination related to the preliminary assessment of all allegations, regardless of their disposition, in sufficient detail to permit later assessment of that determination. Documentation will be maintained as outlined in the record retention requirements for these procedures.

5.4. Conducting an Investigation

5.4.1. Purpose of Investigation

5.4.1.1. If it has been determined that the criteria for an investigation have been met, the RIO will initiate the investigation process within 30 calendar days. The purpose of the investigation is to determine, based on a preponderance of the evidence, whether research misconduct has occurred and, if so, to determine the responsible person(s) and the nature and seriousness of the research misconduct.

5.4.2. Timeframe for Completing the Investigation

5.4.2.1. The investigation committee is generally convened within 30 days of the determination to convene an investigation. All aspects of the investigation, including conducting the investigation, preparing the report of finding, providing the draft report for comments and distribution of the final report must be completed within 120 days of beginning the investigation.

5.4.2.2. If the investigation cannot be completed within 120 days, the RIO may request in writing an extension of the time limit. This is submitted to the President for formal approval.

5.4.3. Sequestration of Records

As soon as possible after the initiation of the investigation the RIO will take all reasonable and practical steps to obtain custody of and sequester in a secure manner all research records and evidence needed to conduct the research misconduct proceeding and to sequester records and evidence in a secure manner. The RIO may obtain the assistance of other individuals to assist in obtaining and sequestering records. Upon obtaining any additional research records, the RIO will inventory, record, and secure all records.

5.4.4. Notifications

5.4.4.1. Within 15 days of the determination to convene an investigation, the RIO will notify the respondent in writing of the decision to convene an investigation. Respondent notification includes:

• The specific allegation(s);
• The research project in question;
• The study sponsor, if applicable;
• The rights and responsibilities of the respondent;
• The role of the investigation committee;
• A reminder of the need to maintain confidentiality;
• The investigation process timeline; and
• Copies of UM6P’s Research Integrity Policy and these procedures.

5.4.4.2. The notification to the Respondent will be copied to the Deciding Official and other university officials as deemed appropriated by the RIO.

5.4.5. Selection of Investigation Committee

5.4.5.1. The RIO will recommend to the President for appointment a minimum of five full-time faculty members to serve on the investigation committee and select one member to chair the committee. The RIO will serve as an ex officio, non-voting member of the investigation committee. Administrative assistance will be provided as needed and UM6P’s Legal Department will be available to advise the committee.

5.4.5.2. The investigation committee must include faculty members at the level of Associate Professor or above who:

• Have the necessary scientific expertise to evaluate the evidence and issues related to the allegation;
• Have no personal, professional, or financial conflicts of interest with the complainant or respondent;
• Have no supervisory or mentor relationship with the respondent or complainant;
• Have not been a close collaborator or co-investigator with the respondent or complainant;
• Have not been a party to a scientific controversy with the respondent or complainant; and
• Fall within any other circumstance that might appear to compromise the individual’s objectivity in reviewing the allegations.

5.4.5.3.When appropriate, the RIO, in consultation with the investigation committee, may appoint experts from outside of UM6P to serve on the investigation committee. The RIO will take reasonable steps to ensure an impartial and unbiased investigation to the maximum extent practicable, including participation of persons with appropriate scientific expertise who do not have unresolved personal, professional, or financial conflicts of interest with those involved with the investigation.

5.4.5.4.The RIO shall provide the respondent notice of any new allegations of research misconduct within a reasonable amount of time of deciding to pursue allegations not addressed during the initial notice of investigation.

5.4.6. Responsibilities of Investigation Committee

5.4.6.1. The investigation committee is responsible for conducting a thorough examination of all facts and evidence to the investigation to determine, based on a preponderance of evidence, whether research misconduct has occurred and, if so, to determine the responsible person(s) and the nature and seriousness of the research misconduct. The investigation committee may also identify, in the course of its duties, if there are issues which would justify broadening the scope of the misconduct proceeding beyond the initial allegation.

5.4.6.2. The investigation committee must interview the complainant, the respondent, and any other available persons who have been reasonably identified as having information relevant to the investigation. Interviews are recorded or transcribed and provided to the interviewee for correction. The investigation committee comes to a finding for each allegation determining whether research misconduct occurred, by whom and to what extent, taking into account that a finding of research misconduct requires a preponderance of evidence, a significant departure from accepted practices in the relevant scientific community, and that the research misconduct must have been committed intentionally, knowingly and recklessly. The investigation committee summarizes its findings and recommendations in a written report that will be submitted to the Deciding Official. The decision will be made based on a simple majority vote of all voting committee members only.

5.4.7. Charge to Investigation Committee

5.4.7.1. The RIO provides the charge to the investigation committee, which includes:

Purpose of the investigation;

• Definition of research misconduct;
• Requirements for findings of research misconduct;
• Timeframe for completion;
• Identification of respondent;
• Specific allegations to be evaluated;
• Responsibilities of the investigation committee, including:

-Examination of evidence; including review of all relevant documentation;

-Interviews of complainant and respondent;

-Interviews of other persons as necessary and appropriate;

-A finding, for each allegation, determining whether research misconduct occurred, and if so, to determine the responsible person and the nature and seriousness of the research misconduct;

-Preparation of a final report;

• Copies of the UM6P’s Research Integrity Policy and these procedures.

5.4.7.2. Members of the committee, experts, witnesses, and attendees will agree in writing to observe the confidentiality of the proceeding and any information, documents, materials, testimony or other evidence reviewed as part of the investigation. Outside of the official proceedings of the committee, they may not discuss the proceedings with the respondent or complainant, witnesses, or anyone else not authorized by the RIO to have knowledge of the Investigation.

5.4.8. The Investigation Report

5.4.8.1. Required Content

5.4.8.1.1. At the conclusion of an investigation, the investigation committee will prepare a written report that summarizes its findings and recommendations. The required elements of the investigation committee report include:

• The name and position of the respondent;
• External funding information;
• Specific allegation(s) evaluated;
• Purpose of the investigation;
• Definition of research misconduct;
• Requirements for findings of research misconduct;
• Timeframe for completion;
• Policies and procedures;
• Research records and evidence;
• Any comments made by the respondent and (if applicable) complainant on the draft investigation report;
• Whether any publications need correction or retraction;
• Responsibilities of the investigation committee, including:

-Examination of evidence, including review of all relevant documentation;

-Interviews of complainant and respondent;

-Interviews of other persons as necessary and appropriate;

-A finding, for each allegation, determining whether research misconduct occurred, and if so, to determine the responsible person and the nature and seriousness of the research misconduct;

-Preparation of a final report.

5.4.8.1.2. The Investigation Committee will submit a draft Investigation Report to the RIO, who will provide the respondent with a copy of the draft report for comment and rebuttal. The respondent must provide any written comments within 20 business days of receipt of the draft investigation committee report. The Investigation Committee will review any submitted comments, revise the report as appropriate, and submit a final copy of the Investigation Report to the RIO. The written comments submitted will be attached to the final report.

5.4.8.1.3. In addition, the RIO may provide the complainant with those portions of the draft investigation report that address the complainant’s role and opinions in the investigation.

5.5. Institutional Decision

5.5.1. If the investigation committee finds that research misconduct has occurred, the RIO will transmit the final Investigation Report and any comments to the Deciding Official who will determine whether the allegations of research misconduct are substantiated.

5.6. Institutional Actions

5.6.1. If the Deciding Official determines that the findings of research misconduct are substantiated, the Deciding Official will then decide on the appropriate sanction. Sanctions may include, without limitation, one or more of the following:

• Removal from a specific project;
• Letter of reprimand;
• Special monitoring of future work;
• Disciplinary actions in accordance with the labor code.

5.6.2. In consultation with the UM6P Legal Department, university administrators may release appropriate information to the public about the incident, particularly when public funds were used in supporting the research.

5.7. Finding of no misconduct

5.7.1. If the allegations of research misconduct are not substantiated, UM6P shall undertake reasonable, practical, and appropriate efforts to protect and restore the reputation of any person alleged to have engaged in research misconduct, but against whom no finding of research misconduct was made, if that person or that person’s legal counsel or other authorized representative requests that the university do so. In addition, appropriate disciplinary action may be taken against any individual whose involvement in the research misconduct proceedings as was determined by the Deciding Official to have been malicious or intentionally dishonest.

5.8. Notifications

5.8.1. The respondent shall be notified by the RIO in writing of the results of the investigation, including a copy of the final investigation report with access to all attachments. The RIO will notify the head of department or equivalent in the respondent’s department. As required, the RIO will notify any oversight agencies in writing of the investigation committee’s findings, whether the university accepts the investigation committee’s findings and any completed or pending UM6P actions or sanctions. Any formal notification will include a copy of the investigation report with all attachments. The RIO may also notify the complainant of the results of the investigation. Institutions and sponsoring agencies with which the individual has been affiliated will be notified if there is reason to believe that the validity of previous research might be questionable. Notification shall also be sent to publishers and any relevant regulatory bodies.

5.8.2. At any time during the assessment period or research misconduct proceedings, the RIO will notify the appropriate funding and oversight agency(ies) if:

• Public health or safety is at risk;
• Agency resources or interests are threatened;
• Research activities should be suspended;
• There is reasonable indication of possible violations of civil or criminal law;
• Federal action is required to protect the interests of those involved in the investigation; or if
• It is probable that the reported incident is going to be reported publicly and the research community or public should be informed.

5.9. Appeals

5.9.1. The respondent has the right to appeal the decision or sanction. The appeal should be filed according to the procedures provided in UM6P’s Appeals Policy.

5.10. Record Retention

5.10.1. All documentation and records related to allegations of research misconduct, shall be retained and secured by the RIO in the Office of Research Governance for a period of seven years from the date of the receipt of the allegation.

5.10.2. All documentation and records related to research misconduct investigation will be retained and secured for a period of seven years from the date of the completion of the research misconduct proceedings.

SECTION 6: RESPONSIBILITIES 

6.1. The Research Integrity Officer facilitates all preliminary assessments and inquiries.

6.2. The designated chair of the investigation committee shall lead the investigation and finalize preparation of the final report.

APPENDIX 1: RESEARCH MISCONDUCT FLOWCHART