Bullying and harassment policy

We consider bullying and harassment of any kind, in any context, to be unacceptable. We believe that all people working at Wellcome or involved in Wellcome-funded activities should be able to work in an environment where everyone is treated, and treats others, fairly and with respect.

This policy forms part of our grant conditions and should be considered alongside our policies on good research practice and research misconduct.

What is bullying and harassment?

Bullying is any offensive, intimidating, malicious or insulting behaviour. It involves the misuse of power and can make the person being bullied feel vulnerable, upset, humiliated, undermined or threatened.

Harassment is any unwanted physical, verbal or non-verbal conduct that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. It may be persistent or a single incident.

What we expect from people involved in Wellcome funding

We expect all participants involved in Wellcome funding to treat each other with dignity and respect. Participants include:

  • award-holders
  • co-investigators
  • sponsors and supervisors
  • research staff
  • students
  • fieldworkers
  • collaborators
  • consultants
  • sub-awardees
  • Wellcome advisory committee members.

What we expect from the organisations we fund

When an organisation submits a grant application to us, they must confirm that the lead applicant (and sponsor and supervisor if relevant), has not had an allegation of bullying or harassment upheld against them for which there is either a current formal disciplinary warning or an active sanction.

If they have, we may reject the application.

It is the organisation’s responsibility to:

1. Have a policy in place that clearly sets out:

  • the standards of behaviour it expects from staff
  • their procedure for responding to complaints, including a first point of contact.

The policy should be available to all staff and ideally published on the organisation’s intranet.

2. Make sure there is an equivalent policy in place at any sub-awardee organisation, if relevant.

3. Investigate allegations of bullying and harassment in an impartial, fair and timely manner, and take appropriate action.

4. Tell Wellcome’s Director of Grants, in confidence, about any allegations of bullying or harassment that are upheld. This should happen after the full internal process is complete, ie after an appeal, if one is made.

This applies to any employee at the organisation who is associated with:

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

The information you provide should only include:

  • the name of the person against whom the allegation has been upheld
  • a brief factual statement about the nature of the allegation (eg bullying junior members of staff in a research group)
  • a brief factual statement on the outcome of the investigation, including any sanctions.

The information you provide should not include any:

  • sensitive personal information, eg relating to criminal offences or convictions
  • personal information about other people, eg the person making the claim.

Any information you send to us will be:

  • stored in accordance with data protection law requirements
  • communicated on a need-to-know, restricted-access basis only
  • updated and/or deleted in line with our retention policy.


If an organisation upholds a bullying or harassment allegation, we may apply our own sanctions. 

These will be independent of any set by the organisation. We may:

  • send a letter of reprimand
  • remove the award holder/sponsor from the affected grant(s)
  • withdraw funding from the award holder/sponsor
  • bar them from being a PhD supervisor on Wellcome 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.

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

  • respond to a bullying and/or harassment complaint promptly and objectively
  • keep Wellcome informed (as outlined in the ‘What we expect from the organisations we fund’ section above).

Sanctions may include:

  • not accepting new grant applications for a limited period of time
  • restricting applications for specific grant types, eg not allowing participation in PhD programmes or overseas-based research
  • suspending funding to the organisation in extreme cases.

How Wellcome handles allegations

If an allegation of bullying or harassment is made directly to a member of Wellcome staff rather than to the organisation, we will:

  • first discuss the circumstances with the informant
  • then tell an appropriate individual at the organisation.

If an informant wants to remain anonymous, we will respect this unless we have a legal obligation to reveal their identity. We’ll tell the informant before we do this.

The organisation is then responsible for following its procedures for handling allegations.

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.

Wellcome's role in any investigation

Wellcome does not carry out its own investigations, but we may:

  • ask for information about an organisation’s processes
  • check that an organisation has a policy and is following it.

This may be done as part of Wellcome’s organisation audits.

More information

See also our policies on:

Clinical trials

Research involving human participants

Research involving people in low- and middle-income countries