Handling reports concerning scientific integrity

Any individual who believes that he or she has witnessed or been the victim of a possible breach of scientific integrity (SI) may report the matter to the SI Referent (RIS) and/or the head of the institution (Dean of the Faculty of Health Sciences).
Both the RIS and the head of the institution can be reporters.
 The report cannot be anonymous and, while it may initially be made by any means of communication, including orally, it must be confirmed in writing by the reporter.
If the report is made solely to the RIS, the latter is not obliged to pass it on to the head of the institution, particularly if the reporter so requests. Unless the RIS itself is implicated, a report to the head of the institution alone will be communicated to the RIS.
In all cases, the report is treated confidentially by the RIS and the head of the institution.
If the alert concerns several research operators, the RISs designate a coordinating RIS, who will inform the alerting party of the admissibility decision and of the collective referral to several RISs. The heads of the institutions concerned may propose this coordinating RIS.
The admissibility of an alert, i.e. the decision to open an investigation file, is judged within a "reasonable" timeframe by the RIS, possibly after consulting the head of the institution if authorized to do so by the reporter.
The general criteria for the admissibility of alerts include (but are not limited to) :

• Data falsification or invention
• Plagiarism
• Incorrect scientific behavior related to the designation and order of authors
• Research conducted outside the applicable regulatory framework
• Erroneous and fraudulent publications
• Incorrect management of data or materials
• Incorrect collaborative work behaviour
• Incorrect advice/expertise and peer review behaviour
• Incorrect behavior with regard to scientific integrity procedures :
  • allegation of a violation of scientific integrity without sufficient grounds
  • concealing or minimizing breaches of scientific integrity committed by third parties
  • discrimination against people who report incidents
• The creation or support of journals or platforms without adequate quality control

A limitation period will be set on a case-by-case basis by the RIS and the head of the institution.

Referral to the Scientific Integrity Officer (RIS) means the opening of an investigation file, after an alert has been declared admissible by the RIS.
The referral is triggered by the RIS after it has declared the report of a possible breach of scientific integrity (SI) admissible.
 If the regulations applicable to the operator for which it is the RIS so provide, the RIS may refer the matter to itself following observation of a possible breach of scientific integrity. In this case, the RIS's self-referral must be formalized in writing.
The date and origin of the referral will be mentioned in the investigation report.
The person who has reported a potential breach of scientific integrity to the RIS undertakes :

• To maintain confidentiality throughout the appraisal process with regard to information and documents received from RIS.
•  To make available all information in its possession relating to the case.

The RIS informs the person(s) who has (have) filed a report of misconduct of the terms and conditions of the investigation procedure that will be applied to this report.
 If the victim finally decides not to refer the matter to the RIS, the RIS may, if it deems necessary, inform the head of the establishment; the latter may then decide to refer the matter to the RIS to investigate the case, if it considers that the establishment has suffered prejudice.

Investigating a case of breach of scientific integrity (IS) involves gathering relevant information, examining the evidence, interviewing and/or collecting comments from the persons concerned, drawing up a preliminary report and then a final report.

At any time during the investigation, the RIS may suggest conciliation-mediation, depending on the nature of the case and its context.

Investigation is carried out by the RIS, by several RISs if the case involves several institutions, or by an ad hoc committee if the case is particularly complex or sensitive.

The RIS may call in expert(s) after obtaining their confidentiality undertaking.
Investigation is based on the principles of formalization, fairness, respect for the adversarial process, rigor, confidentiality, control of links of interest and transparency.
It is carried out within a "reasonable" period of time and, if delays are expected, the protagonists are informed.
The RIS may ask to interview, in camera, any person as part of the investigation, in compliance with the following principles concerning the person interviewed:

• She must undertake to respect confidentiality.
• She may refuse the hearing and submit her observations in writing within a specified period.
• She may ask to be accompanied by a third party, on condition that the third party undertakes to respect confidentiality.
• The hearing of a lawyer is excluded in principle, as the investigation procedure is not a disciplinary procedure.
• The hearing may be recorded, subject to the prior written agreement of the persons auditioned, the purpose of which is to establish a verbatim record.

The RIS may call in outside experts specializing in the discipline concerned by the allegation of a breach of the SI. These experts must submit a written report to the RIS on completion of their assessment.
A pre-investigation report is drawn up by the RIS. This preliminary report contains the initial conclusions and recommendations of the investigation.
The pre-report is sent to the protagonists, specifying that it is confidential and requesting their written comments, which may be incorporated into the final report.
The final report is prepared by the RIS on the basis of the pre-report, and may take into account comments returned by the protagonists. Comments not taken into account are appended to the final report.

The investigation report is a document drawn up by the RIS and/or, where appropriate, by an ad hoc committee, containing all the elements of the pre-investigation, the comments made by the protagonists and any recommendations made by the RIS.
The final investigation report contains the essence of the pre-report, supplemented or modified according to the remarks received from the protagonists. It is primarily intended for the person responsible for deciding on the action to be taken on the report's conclusions (the Dean for Sorbonne Université Health Sciences).
The final report contains a detailed analysis of the facts and :

• The engagement letter and/or official message informing you of the RIS referral;
• The identity of the ISR(s) and persons interviewed or asked to provide expert advice (including when they have been or have recused themselves);
• The dates of the alert, admissibility and referral to the RIS, the latter marking the start of the procedure;
• Declaration by the RIS(s) that they have no ties of interest; 
• Minutes of any hearings held as part of the internal investigation;
• Copies (or list) of documents used in the instruction ;
• A list of potential recipients other than the head of the institution.

In the case of a report drawn up by an ad hoc committee, the RIS may consider it useful to provide the head of the institution with information on the setting up of the committee in a supplementary report, separate from the final report and not dealing with the substance of the problem.
It is up to the head of the institution to decide how and which parts of the report are to be distributed. One of the following three methods is typically chosen:

• Report retention: only the RIS and the head of the institution retain the report.
• Confidential distribution: the report is sent to a small number of people, possibly including the protagonists, under the seal of confidentiality.
• Public distribution: subject to applicable legal provisions, the final report of an investigation is distributed publicly, after anonymization if necessary, by any means deemed appropriate (university website or other, press release, press release to an operator involved, such as a scientific journal, etc.).

The outcome of the investigation consists both of the measures taken by the head of the research institution (the dean in the case of SU Faculty of Health Sciences), after the final investigation report has been sent to him or her, which concludes the procedure carried out by the RIS, and of any follow-up action taken on the case.
These measures do not a priori fall within the RIS's remit, as its role is limited to investigating the report. At the request of the head of the institution, the RIS may nevertheless be entrusted with some of them.

In the absence of a breach of scientific integrity (SI), these follow-up measures may concern actions that may be necessary to rehabilitate the person wrongly accused and/or check that the report has not been abusive, made in bad faith or with malicious intent.
In the event of a proven breach, this may involve :

• Scientific: retraction, corrections, cancellation of a thesis or dissertation, etc.
• Disciplinary: according to university regulations.
• Support: training, mentoring, mobility, etc.
• General: directly or indirectly affecting company policy, such as the implementation of scientific or organizational measures, awareness-raising or training initiatives, or mediation or regulation mechanisms designed to prevent the occurrence of SI breaches.

It is the sole responsibility of the head of the employing institution or of the person responsible for the breach to decide what action to take.
It is recommended that the RIS be informed by his or her manager of the measures taken as a result of his or her instructions, but the decision to inform the RIS rests solely with the manager of the institution.
The RIS must take care not to become involved in the implementation of disciplinary measures.