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The purpose of this plan is to define processes, responsibility and authority levels, responsibilities for action, and reporting lines in the event of a suspected fraud or irregularity. The use of the plan should enable the institution to:
These matters are dealt with below.
There are a number of ways fraud may be detected or suspicion of fraud reported. Within the University all such instances are required to be reported directly to both the Chief Financial Officer (CFO) or Director of Finance by email, unless either is suspected of involvement, when the Registrar and Chief Operation Officer (R&COO) should be informed. Suspected Fraud Event reporting form.
The CFO/R&COO as appropriate will then form a working group which should comprise:
The action taken may include:
The Director of ECS or Deputy Director of ECS should be informed and advised on any action needed to deny the suspect access to the University, while they remain suspended.
The Chief Information Officer should be instructed to withdraw without notice all access to all IT systems.
The internal auditor shall consider whether it is necessary to investigate systems other than that which has given rise to suspicion, through which the suspect may have had opportunities to misappropriate the University’s assets.
7. The OfS takes a risk based approach to regulation and will examine the context surrounding each case. OfS provides guidance for registered providers on reportable events.
Factors for reporting to OfS:
Examples of reporting include:
Submitting an additional 10 humanities students in the HESES return would not be likely to constitute a reportable event, but submitting an additional 10 clinical stage medicine students would.
8. In these circumstances the CFO/R&COO will:
Factors for not reporting to OfS:
9. Recovering losses is a major objective of any fraud investigation. The CFO/R&COO should ensure that in all fraud investigations the amount of any loss will be quantified. Repayment of losses should be sought in all cases.
10. Where the loss is substantial, legal advice should be obtained without delay concerning the steps needed to secure the suspect's assets through court proceedings.
11. Any request for a reference for a member of staff who has been disciplined or prosecuted for fraud shall be referred to the Chief People Officer. The Chief People Officer shall prepare any answer to a request for a reference having regard to employment law.
Any variation from the approved fraud response plan, together with reasons for the variation, shall be reported promptly to the Chair of the Audit Committee.
On completion of an investigation, a written report shall be submitted to the Audit Committee containing:
The CFO/R&COO shall provide on behalf of the working group a confidential report to the Chair of Audit Committee, the Vice-Chancellor, and the external audit partner at least monthly, unless the report recipients request a lesser frequency. The scope of the report shall include:
16. This plan will be reviewed for fitness of purpose at least annually or after each use.
17. This policy and procedure was reviewed and approved by the Chief Financial Officer, August 2022.
Next review due: August 2025
Cathy BurleighChief Financial Officer August 2022