Policy and procedures for the prevention and detection of fraud, corruption and other irregularities affecting the University

Introduction

  1. The purpose of this paper is to set out how the University protects itself from losses from fraud, corruption and other irregularities.
  2. Fraud is defined as dishonest, irregular or illegal acts, characterised by a deliberate intent at concealment or false representation, resulting in the diversion of resources, whether or not for personal gain, for the benefit of an individual or group of individuals and resulting in a loss or the potential loss of resources to the University.
  3. Corruption is the action of a member of staff or office holder who allow themselves to be influenced by a third party, usually by the receipt of some benefit, to act or appear to act in a way that is detrimental to the best interest of the University in order to benefit the third party or some other group or individual.
  4. For the purpose of the remainder of this paper fraud is used to describe all forms of fraud, corruption or other irregularity.

Prevention and detection

  1. The University's Senior Managers and Governors are committed to the highest standards of behaviour in public office as codified by the Committee of Standards in Public Life, and a strict policy on conflict of interest, including the registration of interests, is maintained.
  2. The aftermath of fraud is costly, time-consuming, disruptive and unpleasant. The University's approach is therefore to place emphasis on the prevention of fraud, though all of these systems also play a significant role in the detection of fraud, through the implementation of its financial regulations and procedures and other policies as they impact on staff's conduct, including:
    • The design and operation of systems so as to minimise the opportunity of fraud including the segregation of duties, authorisation requirements etc;
    • Control of access to IT systems;
    • Application of formal tendering requirements and process for approving suppliers and for monitoring the use of non approved suppliers;
    • Informing all staff, by supplying them with an abridged copy of the financial regulations with their joining pack, of their obligations to secure the financial resources of the University from loss;
    • Staff adherence to the University's policy on Acceptance of Gifts, Hospitality and Benefits;
    • Staff adherence to the University's policy on Conflicts of interest;
    • The application of its Whistle-blowing Policy to encourage staff who suspect fraud to report it;
    • Adherence to the University's policy on The Provision of References and verification of relevant qualifications for potential staff which requires in addition to the receipt of written references, obtaining an oral reference to verify the authenticity of the written reference and confirm the trustworthiness of the prospective employee. Confirmation of relevant qualifications must also be obtained. This policy applies to all staff but must be diligently adhered to for staff in positions of control over University resources.

Prosecution

  1. The University's policy is that it will report to the Police any cases of suspected fraud and irregularity. Any exceptions to this policy must be agreed by the Vice-Chancellor and reported to the Audit Committee.

Role of audit

  1. The Internal Auditors systematic review of systems and the management of risk by the University both strengthens the University's prevention of fraud and increase the potential that it will be detected.

Actions when fraud is reported or detected

  1. Fraud may be detected through the University's procedures or reported through the Whistle-blowing policy or other channels. The primary contact for suspected fraud or corruption issues will normally be the Director of Finance and Legal Services, unless they are suspected of involvement; in which case the Registrar and Chief Operating Officer will be the primary contact. The primary contact will initiate action under the University's fraud response plan which is presented in the annex.

Approval

  1. This policy and procedure was approved by the Director of Finance and Legal Services, December 2016.

Cathy Burleigh
Director of Finance and Legal Services
December 2016

Annex A: University fraud response plan