AntiFraud Policy

Purpose

The University is committed to the highest ethical standards in the conduct of all aspects of its work. This policy outlines the procedure for reporting and investigating concerns relating to fraud or corruption and applies equally to full-time and part-time employees of the University, visiting lecturers, agency and work-experience staff and those on short or honorary contracts, regardless of seniority or length of service. Every employee should abide by its provisions.

Scope

The University expects its employees to act with integrity at all times, and not to engage in fraudulent or corrupt behaviour of any kind, even when this could be seen as benefiting the University. It is University policy to refer all instances of fraud or corruption to the police, whether committed by a current employee, a former employee or someone outside the University. This may only be varied with the agreement of the Vice Chancellor.

Policy

Responsibilities of individual staff members

Members of staff are responsible for ensuring that they work within the University's ‘Code of conduct for employees’, Financial Regulations, ‘Policy and procedure on bribery and corruption’ and ‘Policy on external work’. They must not use their position as employees, or any confidential information they may gain as a result of their work, as a means of obtaining fraudulent or corrupt financial gain for themselves or others.

Unless specific arrangements have been made, staff may not use the University's resources, financial or other, for the purpose of personal Reporting matters of concern

Any member of staff who suspects fraudulent or corrupt practice in relation to the business of the University, whether by an employee, a former employee a person or organisation associated with the University whether in the UK or abroad (for example an agent, supplier or a contractor), should report the fact immediately to their Head of Department, who should proceed in accordance with the steps described in paragraph 8 (below). Where it is not appropriate to make the concerns known to the Head of Department, or if the issue is of a serious nature, the member of staff may wish to make use of the University's ‘Policy and procedure on whistle blowing’. If the concern relates to financial fraud or irregularity, the matter may be reported directly to the University Secretary, as detailed in the ‘Investigation of fraud policy and procedure’ or, if it relates to bribery then as detailed in the ‘Policy and procedure on whistleblowing’. Staff members who are unsure about raising any issue may wish to discuss it first with their trade union representative or a solicitor.

If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against them. If, however, they make malicious or vexatious allegations, and particularly if they persist with making them, then disciplinary action may be taken against the individual concerned. Responsibilities of Heads of Department and equivalent supervisory staff

Department heads and equivalent supervisory staff are responsible for ensuring that sufficient safeguards are in place to prevent, detect and deter fraud or corruption in their work areas. Where they suspect that fraud or corrupt practice is occurring, or are made aware of such concerns by a member of staff, the departnt head should report the fact immediately to their senior manager and the appropriate person detailed in paragraph 9 (below), take all possible steps to protect any evidence that may exist, and co-operate fully with any subsequent investigation. They should also take immediate local action to identify and implement a means of preventing recurrence, and inform other managers of the potential need for additional safeguards.

Senior managers are responsible for ensuring that all allegations and suspicions of fraud or corruption are investigated thoroughly, by reporting them to the appropriate member of staff:  Concerns relating to the financial affairs of the University should be reported to the University Secretary, as detailed in the ‘Investigation of fraud policy and procedure’. The matter will then be investigated in accordance with the procedure.

Concerns relating to the receiving or giving of bribes either by employees or parties associated with the University (whether in the UK or abroad) should be reported to the University Secretary using the ‘Policy and procedure on whistleblowing’.

Concerns relating to corrupt practices involving academic conduct or judgements should be referred to the Registrar, who has responsibility for initiating investigation, and for calling in expert or audit help from within the University or externally.

If a prima facie case exists that fraud or corrupt behaviour has taken place, the senior manager who conducts the investigation is responsible for reporting the fact to the Vice Chancellor.

The University will seek recovery of any losses it has suffered as a result of fraud or corrupt activity, if necessary through the civil courts. 13 The Secretary to the Audit and Compliance Committee will be informed of disclosures made under this procedure, and the outcomes of investigations into disclosures, in order that they may be reported to the next meeting of the Audit and Compliance Committee. The University will retain full reports of the details of disclosures, of investigations conducted, and of action taken for three years after the investigation was concluded, and follow-up action initiated. Further advice 14 Independent external advice may be sought from ‘Public Concern at Work’, a charitable organisation which can provide free confidential telephone advice to people concerned about wrongdoing at work (see website www.pcaw.co.uk).