Fraud Policy Statement

2.1 - For the purposes of the University's policy fraud is defined as the use of deception with the intention of:

• Gaining an advantage, personally and for family or friends; or
• Causing loss (financial and otherwise) to the University or one of its subsidiary & associated undertakings.

2.2 - The main types of irregularity are: 

• Theft -this may include the removal or misuse of funds, assets or cash;
• False accounting- meaning
  • dishonestly destroying, altering or hiding any document or record with a view to personal gain (or gain by someone else)
  • or with the intent to cause loss to the University
  • or supplying information which is or may be false;
• Abuse of position - including authority, resources or information wither for personal gain or to cause loss to the University. 

2.3 - Some examples of fraud include the following:

• Stealing or misuse of cash from cash boxes, cash registers, takings from outlets, vending machines or from other funds
• Theft of stock including theft of stationery for private use;
• Fraudulent encashment of payable orders or cheques
• Misuse of assets including misuse of information and intellectual property, for example
  
  • unauthorised use of University property
  • vehicles
  • computers
  • other equipment
• Purchasing or purchase ledger fraud examples are:
  
  • setting up accounts & approving/paying bogus suppliers
  • approving/paying for goods not received
  • approving/paying inflated prices for goods and services
  • accepting any bribe
• Travel and subsistence claims overstated or falsely claimed, This may include advances not recovered or forging of counter signatories
• Accepting pay for time not worked examples being:
  
  • false claim for hours worked
  • failing to work full contracted hours
  • false overtime claims
  • falsification of sickness self-certification
• Computer fraud (e.g. altering or substituting records, duplicating or creating records or destroying or hiding records)

4.1 - Fraud takes many forms and it is hard to be definitive on how to best approach a situation. Should you suspect fraud has been committed then:

You must:

• Report the situation to your manager promptly who will attempt to confirm your suspicions discreetly. There may be alternative explanations for the situation. If it is a potential fraud your line manager will inform the Chief Financial Officer immediately.
• Preserve confidentiality only discuss suspicions with your manager or people they refer you to
• Seek immediate advice from a member of your senior management team if you suspect your line manager is committing fraud:
• Raise concerns to someone outside your direct management line where a senior member of university staff is suspected of fraud. Relevant phone numbers are as follows:
  • Chief Financial Officer (Andrew Connolly) - 01392 723093
  • Internal Audit Partner Ruth Ireland - 023 8088 1735
  •  Chair of Audit Committee (Gerry Brown) - (via executive suite) 01392 723002

You must not:

• Keep quiet and hope the problem will go away
• Confront the individual with your suspicions
• Contact the police directly as that is the responsibility of the Chief Financial Officer
• Discuss with anyone else other staff including family and friends. Any alleged fraud must remain confidential at all times and not become the subject of gossip or broadcast on social media

4.2 - Concerns can be raised in the knowledge that they will be treated in confidence and properly investigated. The University is fully committed to dealing with any concerns confidentially, swiftly and thoroughly

4.3 - In addition to concerns raised by staff and students; members of the public and others coming into contact with the University are encouraged to report concerns through the above channels

4.4 - Where concerns or allegations are made by staff and and are subsequently proved to be malicious and unfounded then such abuses will be viewed as a serious disciplinary matter.

5.1 - The University recognises the importance of prevention in its anti-fraud strategy and has in place various measures including denial of opportunity, effective leadership, auditing and employee screening.   

5.2 - All financial systems and financial procedures take into account the need for internal checks and internal control and staff are required to receive training in the operation of all systems. The possible misuse of information technology is prevented through the management of physical access to terminals and with electronic access restrictions.

5.3 - Staff recruitment is required to be in accordance with approved University procedures laid down by Council. References are routinely taken up and candidates are required to provide evidence of their qualifications. Potential recruits are also required to declare any connections with existing University Officers or members of staff.

5.4 -  During induction new staff should:

• familiarise themselves with the Finance web pages especially the Financial Regulations
• ensure they complete (as appropriate to role and grade) both the Bribery Act 2010 and information awareness online courses which can be found online
• ensure they are aware of the implications of receiving gifts and hospitality
• additionally look at the courses offered by Finance Services which help support the obligations of all staff in protecting the University from loss

5.5 - The University supports the obligations of Council, its Committees, senior managers and staff by ensuring that clear policies exist in respect of:

• Commercial ethics
• Registration and Declaration of Interests
• Receiving Gifts and Hospitality
• Code of Conduct
• Prevention of Bribery
• Whistleblowing

5.6 - The University's Audit Committee provides an independent and objective view of internal controls by overseeing both Internal and External Audit Services, reviewing audit reports, systems & procedures and ensuring compliance with the University's Financial Regulations and the requirements of the Higher Education Funding Council for England (HEFCE)

5.7 - All internal management systems are designed consistently utilising wherever possible the expertise and advice of the University's Auditors. The approach includes the need for:

• Segregation of duties
• Timely reconciliation of procedures
• Random checks of transactions
• Reviews of management accounting information including exception reports
• Internal training and communications to support the above

5.8 - Audit activity is an important defence mechanism and Auditors may be required to use special techniques on occasions to identify fraudulent transactions.

6.1 - The University recognises the unpredictability of fraud or irregularity and the disruption which it may cause once identified. It recognises the need to safeguard its staff, students, assets, recover losses and secure evidence for legal and disciplinary processes.

6.2 - In order to meet these objectives and to clarify its approach when fraud is suspected and/or investigations are needed the University has a Fraud Response Plan

6.3 - The Chief Financial Officer is responsible for investigation and reporting all actual or suspected incidents following the protocols set out in the Fraud Response Plan.  The purpose of the Fraud Response Plan is to support the Chief Financial Officer by defining what to do in the event of a suspected fraud or irregularity.

6.4 - In summary the Fraud Response Plan addresses:

• Initiating action
• Prevention of further loss
• Establishing and securing evidence
• Significant fraud
• Recovery of losses
• References for employees disciplined or prosecuted for fraud
• Reporting to Chairs of Council and Audit Committee
• Special Investigation

» View the Fraud Response Plan‌