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Review of the Australian Code for the Responsible Conduct of Research Submission

Personal Details
This submission reflects the views of
Organisation Name: 
John Wiley & Sons
Specific comments
Specific comments: 
Principles in Code

P3. “Research methodology, research findings and knowledge will be shared and communicated openly”. What does “openly” mean? (see below, comment on R19 “responsibly, accurately and broadly” – we would support the use of “openly” but we also recognize that it is ambiguous and suggest internal consistency perhaps replacing it with “responsibly, accurately and broadly”).

P3. “Conflicts of interest will be disclosed and managed”. How do you suggest conflicts of interest are “managed” beyond their disclosure? This is a complex area, and we note that there’s a planned future topic for guidance around conflicts of interest. “Managing” conflicts of interest should be covered there.

Responsibilities for Institutions in Code

R9. “Investigate and resolve potential breaches of the Code, and have mechanisms in place to receive concerns or complaints about potential breaches of the Code.” How will the Code encourage the communication and collaboration that is needed between research institutions and publishers to correct the published record when the outcome of an investigation determines that this is needed? Text could be added to recognize the dependencies between research institutions and publishers with respect to stewardship of published research (ie, corrections, retractions).

Suggested new addition, as R13 or in the Guide in section 2.1. “Make it clear who at the research institution is responsible for responsible research conduct, and how they can be contacted by parties with concerns.” You cover this somewhat in the Guide in section 5.1, page 10, but it would be helpful if this was explicit.

Responsibilities for Researchers in Code

R17. “Disclose and manage actual, potential or perceived conflicts of interest.” How do you suggest conflicts of interest are “managed”? (see also above, P3).

R19. “Disseminate research findings responsibly, accurately and broadly.” Perhaps this is what you mean by “openly”, per comment above on P3?

R28. “Report suspected breaches of the Code to the relevant institution and/or authority.” Suggest addition so the statement reads: “Report suspected breaches of the Code to the relevant institution and/or authority and/or publisher(s).”

Guide Section 2

2.1. New bullet “Correct the published record, by collaboration with publishers, when the outcome of an investigation determines that this is needed”

Guide Section 3

3.1. “Failure to disclose and manage conflicts of interest.” How do you suggest conflicts of interest are “managed”? (see also P3 above).

3.2. Final paragraph under Box 1 on page 4. “Corrective actions should be commensurate with the breach, and may include for example, corrections to the public record.” Please add a requirement for institutions, when they are correcting the published record, to identify all published work that should be retracted/corrected, and to collaborate with publishers to make those retractions/corrections.

Guide Section 4

Figure 2, page 7. Please indicate where in this workflow collaborations between institutions and outside parties (eg, publishers) may be warranted. The process as it stands could easily be interpreted as highly focused within an institution, but investigations, and outcomes (eg, retractions), may need to involve collaboration with third parties.

Guide Section 6

6.3. An outcome that requires retraction or correction of published work is a possibility here. This should be noted.

Guide Section 7

7.4.3. “The institution is responsible for ensuring the public record is corrected.” Please emphasize correction of all articles that require correction, and the requirement for collaboration with publisher(s) to do this.

Guide Appendix 3

Appendix 3. Final checkbox, “…(for example, funders, external stakeholders)” please change to “…(for example, funders, external stakeholders, publishers)”


Specific consultation questions
Question 1: Do you like the new approach to the Code, namely the principles-based document being supported by several guides that provide advice on implementation?: 
Yes. The new Code is presented clearly, and with the breadth and flexibility required to enable it to support responsible research in settings across the research and scholarly disciplines. Critical voices may suggest that the new Code should be more specific (for example, in its definitions of misconduct) and prescriptive (for example, in its description of outcomes or sanctions chosen when specific types of breach occur). We note that definitions of specific types of “breach” are present in the accompanying Guide (section 3.1), and that outcomes and sanctions are almost always dependent on the circumstances of individual cases and may also be based on legal advice, so recommendations for prescriptive outcomes are not possible.
Question 2:The draft Code is intended to be used by all research disciplines. Do the principles adequately capture the expectations for responsible research across all research disciplines?: 
Question 3: The draft Guide refers to breaches of the Code rather than providing a definition of research misconduct, and states that institutions can decide whether or not to use the term research misconduct in their own processes.: 
We note that the Guide lists examples of “breaches”, and these breaches include and reach beyond the commonly understood descriptions of research misconduct (ie, fabrication, falsification, plagiarism; section 3.1). This is a reasonable and practical approach to enabling departures from norms accepted by a research community to be classified as a potential “breach” and therefore to qualify for investigation under the Code. It creates flexibility. At the same time, it would be interesting to consult a legal expert on the additional ambiguity created by this more flexible description of misconduct, and what any likely legal implications might be.
Question 4: Do you think the process described for investigating and managing potential breaches of the Code is clearly described and practical?: 
The processes for investigating and managing potential breaches are clearly described. The sections of the Code and Guide that relate to outcomes (for example, retractions, expressions of concern, corrections) provide little detail. Brief descriptions could be added: #1 to encourage clear and transparent communication between institutions and publishers (and other parties as warranted) during investigations #2 to refer users of the Code and Guide to well-tested processes for investigations (for example, the COPE flowcharts http://publicationethics.org/resources/flowcharts) #3 to encourage use of “corrections” where these are warranted and – when a retraction is needed – to encourage “useful” retractions that meet recognised standards (for example, with enough information to allow readers to understand the reasons for an article retraction http://publicationethics.org/files/retraction%20guidelines_0.pdf)
Question 5: The Code Review Committee and working group are considering what additional resources should be developed to support implementation of the Code and Guide.: 
Case studies would be useful to help institutions manage potential breaches. Figure 1 on page 5 of the Guide is a particularly good start. Case studies would be of further help. Wiley would be pleased to discuss how we might support NHMRC / ARC / UA with cases that reflect our experiences.
Question 6: Are the mechanisms for review of an investigation clearly and correctly described in Section 7.6 of the Guide? If not, where are the inaccuracies?: 
Yes, mechanisms for review of an investigation are clearly described.
Question 7: Please comment on which three topics you would nominate as being the highest priority and why.: 
We refer to a recent study of the COPE case archive. Slide 7 of 14 here presents the results: http://publicationethics.org/files/u7141/Hames_presentation_final2.pdf. In that context, the first of the planned next two guides is a good choices: Authorship is a steady source of problems presented to COPE. The COPE study does refer to “Data” as a major and rapidly growing focus of problems presented to COPE, but “data” here is more about problems around misrepresenting data in published papers than it is about “data management” per your suggestion. However, putting the COPE study to one side, we perceive “data management” (and publishing data in general) to be a hot topic, and support your selection of this topic for a new guide. For your next three topics, areas of growth in the problems presented to COPE that match your suggested topics include: “Peer review”, “Conflicts of interest”, plus – with a little interpretation – your topic of “supervision” could map onto the COPE classification of “Misconduct and questionable behavior”. Last, “collaborative research” is such an important part of the future of research that it seems to us to a strong contender as one of the three guides you plan to create. We hope that this commentary helps you make your choices.
General comments

Submission from John Wiley & Sons on the Australian Code for the Responsible Conduct of Research


At Wiley we have published the work of more than 15million researchers. We work with 1000+ scholarly society partners to make this happen. We support science and evidence as the bedrock of public policy and the solutions to our most urgent problems, from protecting public health to mitigating climate change.1


The standards expected of research and researchers in Australia (and globally) have real impact on the work we do as publishers. We are the stewards of the journals that communicate that research. We train and support editors and peer reviewers to work to recognized standards. We deploy tools that support the integrity of what we publish, like “similarity checkers” to identify and help us manage plagiarism.2 We support community-based initiatives, like the work of COPE3, that define processes to resolve problems. When “breaches” to expected standards occur, we follow due process and take action to retract (or correct) the published record, working in collaboration with researchers and research institutions.


We congratulate NHMRC, ARC, and UA on the new draft Code, and welcome the recommendations it makes. We suggest that it provides the world with a model of clarity and pragmatism to aspire to – it is balanced and sensible. We are delighted to share comments, focused on the specific areas from the new draft Code that are closest to the processes that publishers like Wiley oversee. We are also happy to share answers to your 7 specific questions.


Thank you for the opportunity to submit these comments. We look forward to contributing to and supporting your work further, as opportunities arise.


Deb Wyatt, Editorial Director, and Mark Robertson, Vice President and Publishing Director, on behalf of John Wiley & Sons

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Page reviewed: 17 September, 2018