Sensitive Research Statement

Universities play a critical role in the development of new knowledge and technological innovation that is in the national interest and vital to Australia’s social, cultural and economic prosperity. A key feature of academic research is that it is based on open collaboration with researchers at the forefront of their fields, both within Australia and internationally. UQ is committed to implementing protective measures for sensitive research while preserving the openness and collaboration that is crucial to maintaining world-class research.

Our approach

UQ enables academic freedom and international collaboration through a wide range of support programs and initiatives. However, the University recognises that international collaboration occurs in a complex and changing security context and the principles of academic freedom are subject to boundaries imposed by law, including regulatory and compliance requirements associated with sensitive research.

In particular, UQ’s principles for entering into a research agreement and accepting research funds are clearly articulated in the Administration of Research Funding – Applications, Grants and Contract Research policy.

• UQ is committed to complying with the Guidelines to Counter Foreign Interference in the Australian University Sector and applicable laws, including the Australia's Foreign Relations (State and Territory Arrangements) Act 2020 under which research activities may be subject to review for consistency with Australia’s foreign policy.
• The University and its controlled entities will only accept research funding that is consistent with the University’s values, and is in the public interest.
• All funding for research purposes received by a UQ investigator must be contracted through a written agreement with UQ, even if the funds are not administered by UQ.
• A research agreement must not be entered into without consideration of the partner risks associated with the external entity, including an assessment of the financial and reputational risks.
• An agreement governing research activity must permit investigators to maintain academic integrity and must preserve the right to pursue research impartially and without bias.
• An agreement governing research activity must permit investigators to maintain academic freedom and will not be accepted where an external entity has a right to unreasonably delay or limit public dissemination of a research outcome generated through the funded project, or future research except on the grounds of reasonable commercial, cultural or security considerations.
• The University will not authorise a funding application or enter into any research agreement where an investigator(s) has an unmanaged conflict of interest.

Defence Export Controls are a key part of Australia’s national security framework that apply to every person in Australia, whether an Australian citizen or not. Defence Export Controls seek to regulate:

• the export, supply, publishing and brokering of military and ‘dual-use’ goods and technology
• the supply or export of goods and the provision of services that may assist or be used in a Weapons of Mass Destruction program
• goods that may contribute to a military end-use that would prejudice Australia’s security, defence or international relations.

Australian export controls legislation regulates the movement of controlled goods, software and technology from Australia to a place outside Australia. This includes both the physical transfer of items and transfer via electronic means.

The Defence and Strategic Goods List (DSGL) is a legislative instrument that defines what are controlled goods, software and technologies. The DSGL consists of 2 parts:

• Part 1 includes military goods, software and technologies designed or adapted specifically for military purposes, or that are inherently lethal, incapacitating or destructive.
• Part 2 includes goods, software and technologies primarily designed for commercial use but that may also have military application. For example, they may be used or adapted for use in a military program or may contribute to the development or production of chemical, biological or nuclear weapons systems. These are commonly referred to as dual-use goods or technologies.

The export, supply or brokering of items on the DSGL from Australia to a place outside Australia, or publication of technology included on Part 1 of the DSGL is controlled through a permit system operated by the Australian Department of Defence. Other goods, technology or software not controlled by the DSGL may be subject to catch-all export controls legislation if they are for a military end-use or may be for use in a weapons of mass destruction program.

Our approach

University policy specifies that researchers must record their research activities related to areas included in the DSGL on an annual basis in UQ’s Sensitive Research Register. Relevant changes in circumstances must be registered promptly.

The DSGL is a complex instrument, involving technical information and thresholds that often requires expert knowledge to understand. UQ researchers therefore play an important part in determining whether the activity they are undertaking involves any goods, software or technology that may be controlled by the DSGL. Our researchers use the Defence Export Controls website, which contains a ‘Self-assessment guide for controlled items’, to assist with determining whether the activity they are undertaking may be subject to export controls. They can seek advice and assistance from the International Safeguards unit or a supervisor, as needed. 

If the activity or good, software or technology is controlled, researchers contact UQ’s International Safeguards unit for advice on obtaining an appropriate permit. International Safeguards staff mediate all licence and permit applications with the relevant government authorities. Permit and approval holders are required to monitor research according to the permit and approval conditions and report suspected non-compliance to the International Safeguards unit. Our International Safeguards unit must be notified of each export or supply of items subject to a permit.

Since 2022, 3 permits have been issued to UQ researchers, and all have been in health-related areas.

Compliance with Australian sanctions law is an important part of the University’s contribution to global peace and security. Sanctions are measures, other than those involving the use of armed force, which are imposed by governments in response to a situation of international concern, including: 

• the grave repression of the human rights or democratic freedoms of a population by a government
• the proliferation of weapons of mass destruction or their means of delivery 
• internal or international armed conflict, or terrorism. 

Sanctions measures are intended to: 

• limit the adverse consequences of the situation of international concern (for example, by denying access to military goods)
• seek to influence those responsible for giving rise to the situation of international concern to modify their behaviour to remove the concern (for example, by motivating them to adopt different policies) 
• penalise those responsible (for example, by denying access to international travel or to the international financial system).

Australia implements both United Nations Security Council sanctions and Australian autonomous sanctions through various acts and regulations collectively known as Australian sanctions law. Sanctions impose restrictions on activities that relate to particular goods and services, individuals, entities or countries. Collectively, the sanctions legislation related to a specific country or theme is called a sanctions regime.

The sanctions regimes currently implemented under Australian sanctions laws are regulated by the Department of Foreign Affairs and Trade (DFAT). Under Australian sanctions legislation, the University is prohibited from dealing with designated individuals and entities or providing sanctioned individuals, entities or countries with certain goods or services.

A sanctions regime may include targeted and country-wide sanctions:

• Targeted sanctions apply only to designated persons and entities listed in the DFAT  Consolidated List, which is updated regularly.
• Country-wide sanctions can apply broadly to activities such as imports, exports, commercial activities and the provision of services (including technical advice, assistance or training). Sanctions often target military activities, arms or related materiel (e.g., items on the DSGL) and items related to transport, telecommunications, energy, oil/gas, minerals and luxury items.

Sanctions regimes may restrict how individuals can conduct research activities, including:

• the assignment of staff or students with a connection to sanctioned countries to specific research topics.
• the access of staff, students or visiting academics with a connection to sanctioned countries to research projects, equipment or restricted areas.
• research collaborations or consultancy activities with citizens/entities who have a connection to sanctioned countries or are in sanctioned countries. 

Our approach

UQ has policies and procedures in place to ensure University activities are compliant with both United Nations Security Council sanctions and Australian autonomous sanctions. These include screening all new staff and international students for connections to sanctioned countries, assessing research projects for compliance with sanctions law, and conducting due diligence on partners to ensure collaborations do not breach sanctions law.

The University advises researchers to be alert to potential sanctions restrictions on research activities when recruiting new staff and students. Recruitment of all staff (including visiting and honorary appointments) and enrolment of higher degree research students involves an assessment with respect to Australian sanctions laws, which is facilitated by the International Safeguards unit. Similar to the case for export trade controls, researchers play an important role in sanctions assessments due to their subject matter expertise. Where warranted, an additional layer of checking occurs via senior faculty/institute executives. University policy requires adherence to any conditions imposed on a research activity as a result of a sanctions assessment. Any changes to a researcher’s activities must be evaluated for compliance with the sanctions assessment and may necessitate completion of a new assessment.

For collaborative research, the University’s International Safeguards unit provides advice to researchers as to whether a proposed engagement may contravene sanctions requirements. 

• If the research activity is found to engage directly with a designated individual or entity, the engagement must be declined.
• If the research activity is found to engage indirectly with a designated individual or entity, the University International Safeguards unit must be contacted for assistance.
• If the research activity engages with an individual or entity with a connection to a sanctioned country, the applicable Sanctions Compliance and Assessment form for Collaborations and Contract Research must be completed.

Foreign influence refers to attempts by governments to influence deliberations on issues of importance to them. These activities, when conducted in an open and transparent manner, are a normal aspect of international relations and diplomacy and can contribute positively to public debate. 

The Foreign Influence Transparency Scheme Act 2018 (FITSA) imposes registration obligations for individuals and entities that undertake a registrable activity on behalf of a foreign principal or enter into a registrable arrangement with a foreign principal. The scheme established under the FITSA aims to improve transparency with respect to foreign influence over Australia’s political and government processes.

FITSA registration obligations apply in circumstances including when a person acts on behalf of a foreign principal including a foreign government or political organisation and engages in activities such as parliamentary and political lobbying, public communication or disbursements. 

Our approach

The University Foreign Influence Disclosure Procedure requires all staff to disclose any activities that may give rise to a requirement to register for the purpose of ensuring compliance with the FITSA. Academic and senior staff are required to disclose registrable activities through UQ's Foreign Influence Disclosure tool. 

If registration is required, this is done through the Foreign Influence Transparency Scheme Public Register housed on the Attorney-General’s website. The University applies for registration on the staff member’s behalf.

Academic staff and senior staff whose disclosures are assessed as registrable in the Transparency Register are required to:

• undertake relevant processes for disclosure and registration
• not commence the registrable activity until they receive advice from the University that the registration has been completed
• ensure the ongoing registration obligations are adhered to, as required under the University Foreign Influence Disclosure Procedure.

Foreign interference is defined as activities carried out by, or on behalf of a foreign actor, which are coercive, clandestine, deceptive or corrupting, and are contrary to Australia’s sovereignty, values and national interest. Given the high value of research conducted at Australian universities, the university sector has been assessed as one of the sectors at the highest risk of foreign interference. 

The University Foreign Interference Taskforce (UFIT) was established in 2019 to provide better protection for Australian universities against foreign interference. UFIT involves a collaboration between Australian universities and Australian Government agencies to guide university decision-making based on proportionate risk and to protect against foreign interference, while enabling universities to continue to produce world-class research.

UFIT has led to the development of a set of specific and measurable leading practice principles to counter foreign interference in the Australian university sector (the Guidelines). The Guidelines are not intended to inhibit the vast bulk of international interactions undertaken by universities, which form the basis for knowledge creation in the national interest. However, the Guidelines recognise that universities are at the forefront of research and scientific development as well as the development of commercially valuable and sensitive knowledge and as such are at potential risk from foreign governments and agents who may seek to influence research directions or gain access to valuable research, sensitive data or intellectual property. The Guidelines are based on the principle that transparency is the key to countering foreign interference.

Our approach

UQ has committed to safeguarding our sensitive research by implementing a range of measures aligned to the principles of the Australian Government’s UFIT Guidelines:

The University convenes a Disclosure and Management of Interests Taskforce as its accountable authority under the UFIT guidelines to oversee management of sensitive national security issues and to provide strategic direction for the University’s foreign interference risk framework. The Taskforce oversees regular reporting related to sensitive research, secondary employment and foreign influence disclosures, publication outputs, and higher degree research and visitor admissions and delegations. The Taskforce has developed risk registers and assessment tools that guide decision makers on how to proactively manage risks. The University has a dedicated Security Officer within its International Safeguards unit to oversee sanction compliance checks for staff recruitment and robust screening processes for defence export controls and sanctions.

The University’s Research Office has processes for assessing all grant applications submitted to major funding bodies, such as the ARC, NHMRC, MRFF and other federal and state government schemes, for evidence of potential foreign interference as part of the eligibility and compliance checks. If the application exhibits any concerning features, it is escalated for review to the Executive Director Research Office and the Deputy Vice-Chancellor (Research and Innovation). The Research Office also escalates any grant applications from foreign funders for review by Senior Executive staff. As a key component of the screening of funding applications involving partners, a due diligence screening platform (Bureau van Dijk) is used to facilitate comprehensive due diligence on our research partners, which covers country, commercial and reputational risk. 

The Australian Government has articulated Australia’s future defence capability needs through the National Defence Strategy and the Defence Integrated Investment Plan, which also details the role of research into emerging technologies. In addition, the Australian Government has signalled that the national interest is best served by strengthening partnerships with strongly aligned governments, such as the strengthening of collaboration between Australia, the United Kingdom and the United States through the AUKUS agreement. 

Australian Government defence funding and the Defence Industry Security Program

Australian universities that seek to partner with the Australian Department of Defence have an obligation to ensure the security of Defence personnel, information and assets. Universities partnering with Defence are required to take a range of actions to minimise security risks and raise their level of security. The Defence Industry Security Program (DISP) supports Australian entities to understand and meet their security obligations when engaging in Defence tenders, contracts and projects.

The DISP is a multi-level membership-based program that provides security vetting for Australian Universities engaged in Defence contracts and projects. The DISP provides a framework for universities partnering with Defence to:

• ensure the right security is in place for Defence tenders and contracts
• provide access to security advice and support services
• help the university to understand and manage security risks
• provide assurance to Defence and other government entities when working with DISP members.

DISP membership requirements might include facility certification and accreditation, personnel security clearances and physical security measures.

Our approach

UQ has obtained membership of the Defence Industry Security Program by investing in governance, personnel, physical, and cyber/information security standards to enable the University to work on Defence projects, contracts and tenders. This includes investing in secure physical facilities to ensure more sensitive work is protected from the threat of foreign interference.

UQ partners with the Australian Department of Defence on research in the national interest, ranging from topics in the social sciences and humanities, such as studies into the health and wellbeing of women in the Defence Force and the ethics and legal principles associated with autonomous systems, through to engineering and science projects involving critical and emerging technologies. Funding for current research projects at UQ with the Australian Department of Defence currently totals $21.7m.

Foreign government defence funding

The United States Department of Defense (US DoD) funds a broad range of basic research that can be accessed by non-US researchers. The research funded by the US DoD is basic research in nature, and frequently relates to veterans’ health and other health-related topics.

Our approach

UQ researchers apply and receive funding from the US DoD in a wide variety of discipline areas. In June 2024, current projects funded by US DoD total $37.9m, of which 77% is health-related research including studies on malaria, tuberculosis, arthritis, breast cancer, melanoma, and PFAS management. Non-health related projects were in the basic science areas of materials science and aeronautics, quantum sensing and computing, underwater acoustics, metals extraction, cyber defence, and magnetospheric research.

Weapons manufacturing corporations

Occasionally, UQ researchers collaborate with companies associated with Australia’s AUKUS partner countries that, as a part of their wider business operations, may manufacture weapons. In these cases, the University is not a party to the production of weapons or projects involving a high technology readiness level but is engaged in basic research programs.

As of 31 July 2024, UQ had current research agreements with three companies that are listed as being in the 100 largest weapons manufacturing corporations by the Stockholm International Peace Research Institute, with a total of 10 agreements.

UQ has no direct holdings, including any form of equity holding, shares, investment in or loan to:

• a business enterprise referenced in the UN Human Rights Council Resolution 31/36 database
• a weapons manufacturing corporation (including munitions and vehicles manufactured for the deployment of munitions).

UQ's investment portfolio includes actively and passively externally managed funds*.

UQ’s active fund managers do not hold investments in weapon manufacturing corporations.

Two of our active fund managers hold investments in two businesses listed in the UN database as shown in the table 1 below. This represents 0.67% of the University’s overall investment portfolio as at 30 June 2024.

Both fund managers are signatories to the United Nations Principles for Responsible Investment. We have directed them to consider the UN database when making future investment decisions.

Table 1: Investments held by independent actively managed funds in businesses listed on the UN Human Rights Council Resolution 31/36 database

*An actively managed fund makes purposeful decisions on where to invest. In contrast, UQ’s passively managed funds are automated and mirror the composition and performance of a specific index, such as the SPDR S&P/ASX 200 Fund. The composition and value of these passive funds change daily.