Introduction
The University is committed to the proper use of funds, both public and private through the prevention of fraud and the promotion of an anti-fraud culture.
As a consequence, it is essential that everyone associated with the University - including Council members, staff, students, and third parties - are aware of the risk of fraud, corruption, theft and other activities involving dishonesty, in all its forms.
The University requires Council members, staff, students and its partners to act honestly and with integrity at all times by ensuring that their activities, interests and behaviours do not conflict with these obligations, regardless of their position and to report all suspicions of fraud. This policy gives guidance on how concerns should be raised, investigated and resolved.
Where justified, disciplinary and/or legal action will be taken against any individual or group who perpetrates any act constituting fraud against the University and all steps will be taken to recover any losses incurred.
Definitions
Fraud essentially involves using deception to dishonestly make a personal gain for oneself and/or create a loss for another. This can include theft, the misuse of funds or other resources, or more complicated crimes such as false accounting and the supply of false information. Refer to the section below, common types of fraud.
Individuals can be prosecuted under the Fraud Act 2006 if they make a false representation, fail to disclose information or abuse their position.
Roles and Responsibilities
University Council has responsibility for: Ensuring that the University “has a robust and comprehensive system of risk management, control and corporate governance. This should include the prevention and detection of corruption, fraud, bribery and irregularities.”
Audit and Risk Assurance Committee has Responsibility for: Overseeing and approving the institution’s policy on fraud, including being notified of any action taken under that policy (within the Fraud Annual Report). Reviewing the assurance arrangements with respect to counter-fraud.
The Standing Group for Financial Probity has responsibility for: Preparing an annual report to the University Executive Board on the implementation and monitoring of the Counter-Fraud Policies & Procedures and its periodic review of the associated risk assessment. The Standing Group is chaired by the Chief Compliance Officer and includes the Deputy Director of Finance, Head of Procurement, Legal Adviser and Head of Internal Audit.
The University Executive Board has responsibility for: Developing, implementing and maintaining adequate systems of financial management and internal control to prevent and detect fraud.
The Director of Finance has responsibility for: The University’s approach towards Fraud, Bribery, and Corruption.
Students, Staff and other related third parties are responsible for: Maintaining and monitoring compliance with internal controls and agreed policies and procedures, Immediately reporting details of any suspected fraud, whether by an employee or an external organisation, and Assisting in the investigation of suspected fraud.
Culture
The University is determined that the culture and tone of the organisation is one of honesty and an intolerance of fraud and corruption.
The University's expectation on propriety and accountability is that students and members of staff at all levels act with integrity and lead by example in ensuring adherence to rules and that all procedures and practices are above reproach. The University also expects that individuals and organisations that it comes into a contact with will act towards the University with integrity and without thought or actions involving fraud or corruption.
The staff and students of the University are an important element in its stance on fraud and corruption and they are positively encouraged to raise any concerns that they may have on these issues where they are associated with University business or activity; this includes concerns related to the provisions of the Public Interest Disclosure Act 1998. Such concerns can be raised in the knowledge that they will be treated in confidence and properly investigated. Public Interest Disclosure Policy
Where any fraud is committed against the University, consideration will always be given to prosecuting the person/organisation responsible through all criminal and/or civil means available. The University will follow disciplinary procedures against any member of staff or student who has committed fraud.
Prevention & Detection
The University is committed to reducing the opportunity for fraud associated with any of its activities, operations and locations to the practical minimum and to the robust investigation of any fraud issues that should arise.
The University recognises the importance of prevention and has in place various measures including denial of opportunity, effective leadership, auditing and employee screening. Fraud is minimised through usefully designed and consistently operated management procedures which deny or restrict opportunities for fraud. In particular financial systems and procedures take into account the need for internal check and internal control and staff are required to receive training in the operation of all systems. Additionally the possible misuse of information technology is through the management of physical access to terminals and protecting systems with electronic access restrictions.
The University takes steps to ensure that the behaviour of Council, its Committees and senior managers is always demonstrably selfless and that clear policies exist in respect of: a) commercial ethics b) registration and declaration of interests c) accepting of hospitality and gifts.
Employees are expected to follow any Code of Conduct related to their professional qualification and employment at the University and this is to be emphasised at staff induction sessions.
The University's Audit and Risk Assurance Committee provides an independent and objective view of internal controls by overseeing Internal and External Audit Services, reviewing reports and systems and procedures and ensuring compliance with the University's Financial Regulations and the requirements of the Office for Students (OfS). The Audit & Risk Assurance Committee contains within the Terms of Reference the oversight of action taken under the Counter-Fraud Policy and receives a Fraud Annual Report that details the University’s approach.
The review of the University's systems by Internal Auditors is designed to deter attempted fraud and should result in continuous improvements in control. The risk of fraud is a factor in all audit plans and in particular the frequency of audits. The External Auditor's reviews of financial checks and balances and validation testing provides a further deterrent to fraud and advice about system development/good practice.
All internal management systems are designed with detective checks and balances in mind and this approach is applied consistently utilising wherever possible the expertise and advice of the University's Auditors. The approach includes the need for segregation of duties, reconciliation procedures, the random checking of transactions and the review of management information including exception reports.
The University views its preventative measures by management, coupled with sound detective checks and balances, as its first line of defence against fraud. Audit activity is however an important defence mechanism also and Auditors may be required to use special techniques on occasions to identify fraudulent transactions.
Fraud Risk Management
As part of the University’s commitment to developing a robust understanding of the associated risks, a fraud risk register will be maintained that will document the University’s risks related to fraud. This will be maintained with periodic reporting to the Standing Group for Financial Probity and the Audit & Risk Assurance Committee.
Training
The University has a commitment to ensuring that the appropriate staff have a good understanding of the University’s policy and procedures with respect to fraud. In response, a training approach will be adopted with respect to University’s counter-fraud approach, in co-ordination with the training provided with respect to anti-bribery, anti-money laundering, and anti-criminal finances.
Reporting fraud
Where there is suspicion that fraud or corruption has occurred, or is about to occur, then it is essential that the appropriate person within the University is contacted immediately. As documented within our University’s Fraud Response Plan, any person that has reason to believe that a fraud or suspected fraud has taken place, is required to inform their Head of Department and the Internal Auditor immediately. The Head of Department will in turn notify the Director of Finance. If it is suspected that the Head of Department is involved in the fraud, the matter should be notified to the Director of Finance and Internal Auditor directly. Alternatively, if deemed appropriate, frauds and suspected frauds can be reported through the University’s Public Interest Disclosure Policy which handles whistleblowing allegations.
- Do report your concerns, as above; reports will be treated as confidential.
- Do persist if your concerns remain.
Do retain or copy any relevant document(s). This holds documents for use in any subsequent investigation and avoids any documents being accidentally - or purposely – destroyed.
Don’t be afraid to seek advice from an appropriate person.
Don’t confront an individual or individuals with your suspicions.
Don’t discuss your concerns with colleagues or anyone else other than an appropriate person.
Don’t contact the police directly - that decision is the responsibility of the appropriate person and other senior University officers (with due acknowledgement of the notifications under the Public Interest Disclosure Policy).
Don’t under any circumstances suspend anyone if you are a line manager without direct advice from Human Resources and other appropriate person(s).
Common types of Fraud
These can include but are not limited to:
Fraud involving cash, physical assets, intellectual property or confidential information:
- Theft of University property
- Unauthorised removal of University property
- Passing on company data or intellectual property
- Unauthorised disclosure of confidential information
- False invoices being created
Misuse of accounts:
- Accessing bank accounts
- Fraudsters impersonate innocent victims to obtain products or services in their name, also known as identity fraud
- Attempting to change bank account details of suppliers and payees
- Identity theft where staff are persuaded to reveal login and passwords details
Procurement fraud:
- Falsely creating or diverting payments
- Bid rigging
- Diverting goods or services for personal use
- Colluding with suppliers to accept inferior goods or services
- Payoffs and kickbacks
- Conflicts of interest with third parties and acquaintances
Senior Staff fraud:
- Fraudsters impersonating senior staff to demand that a bank transfer is made to an improper account
Payroll fraud:
- Unauthorised changes to HR or payroll system
- Inputting incorrect details in e.g. hours worked
- Dummy or ghost employees
- Faking self-certified / doctors’ sick notes
Financial accounting fraud, including fees:
- Falsifying accounting or other records
- Falsifying financial returns or claims
- Use of the University name, logo or letterhead for personal reasons
- Embezzlement
- Internal theft
- Under recording income
- Unauthorised removal or destruction of records
- Forgery or alteration of documents
Fraudulent claims:
- Mileage
- Personal use
- Falsifying or manipulating receipts
- False / duplicate expense claims
- Falsifying applications for research grant funding
Related Policies & Procedures
The following policies are associated with our counter-fraud, bribery and corruption University response: