The positioning of design research as a response to complex challenges across disciplines, underpinned by participatory approaches highlights both a growing awareness of the discipline, and the recognition that design can offer a new perspective for exploration and innovation. However, critical to successful adoption of design research methodologies is an understanding of ethical practices that are inherent within the discipline. This paper presents the findings of two participatory design workshops entitled 'Ethics by Design' which aimed to make visible the implicit ethical considerations underpinning the ethical practices within design research. Drawing on experiences of design researchers engaged in a health context, the workshops highlighted the challenges and underlying assumptions around ethics emerging from design research in complex contexts. This paper posits that the ability of the design researcher to identify and acknowledge their own position is critical to delivering rigorous and robust design research capable of enabling co-ownership and co-direction.