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Fraud, corruption and other irregularities affecting the University

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

Introduction

1. The purpose of this policy is to set out how the University protects itself from losses from fraud, corruption and other irregularities.

2. Fraud can generally be defined as (i) wrongful or criminal deception intended to result in financial or personal gain or (ii) a person or thing intended to deceive others, typically by unjustifiably claiming or being credited with accomplishments or qualities. BUFDG 2016

3. Corruption is the action of a member of staff or office holder who allows 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 policy fraud is used to describe all forms of fraud, corruption or other irregularity.

Statement by Board of Governors

5. The Board requires all staff at all times to act honestly and with integrity and to safeguard the resources for which they are responsible. The Board will not accept any level of fraud or dishonesty; consequently, any case will be thoroughly investigated and dealt with appropriately. The Board is committed to ensuring that opportunities for fraud and corruption are minimised. The Board promotes an anti-fraud culture through the following:

  • Any allegation of fraud anonymous or otherwise will be investigated.
  • Consistent handling of cases without regard to position held or length of service.
  • Consideration of whether there have been failures of supervision. Where this has occurred, disciplinary action may be initiated against those responsible.
  • The Board will endeavour to recover losses resulting from fraud, through civil action if necessary.
  • All frauds will be reported to the Audit Committee at least annually.

Prevention and detection

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.

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 and clear authorisation requirements.

  • Control of access to IT systems
  • Application of formal tendering requirements and process for approving suppliers and for monitoring any use of non approved suppliers.
  • Informing all staff, by supplying them with a copy of the financial regulations with their joining pack, of their obligations to protect 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

8. The University's policy is that it will investigate any cases of suspected fraud and irregularity, and those involving criminal activity will be reported to the Police or Action Fraud as appropriate. Any exceptions to this policy must be agreed by the Vice-Chancellor and reported to the Audit Committee.

Role of audit

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

10. Internal Audit reports will be submitted to the next available Audit Committee for discussion.

Actions when fraud is reported or detected

11. Fraud may be detected through the University's procedures and/or reported through the Whistle-blowing policy or the Suspected Fraud Event reporting form.

12. The primary contact for suspected fraud or corruption issues will normally be both the Chief Financial Officer and Director of Finance via email:

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. After an initial assessment, they will instruct the caller of the most appropriate method of formal reporting.

University fraud response plan

13. The University fraud response plan defines processes, responsibility and authority levels, responsibilities for action, and reporting lines in the event of a suspected fraud or irregularity. See Annex A: University fraud response plan.

Approval

14. This policy and procedure was reviewed and approved by the Director of Finance and Legal Services, January 2020.

Next review due: August 2025

Cathy Burleigh
Director of Finance and Legal Services
August 2022