Finance


Fraud Response

Fraud can be defined as including any of the following: theft, false accounting, bribery, corruption, money laundering, forgery, deception and collusion or other financial malpractice.

The issue of financial fraud is covered in the Financial Regulations and Financial Procedures. Financial Regulation 2.4 sets out the framework of control:

2.4 “The Registrar, Secretary and Chief Operating Officer has the authority to request an investigation into matters involving irregularities or suspected irregularities in the exercise of activities of the University. On financial matters, this responsibility will usually be delegated to the Director of Finance, who will take appropriate steps to involve the internal auditors, or where appropriate, other investigatory bodies. Reports will be forwarded to the Audit Committee. The University has adopted a Fraud Response Plan, describing in detail how the above procedures are implemented. The Audit Committee shall approve changes to the Fraud Response Plan.”

The Financial Procedures provide more detail:

FRAUD AND OTHER FINANCIAL IRREGULARITIES

2.9. Financial Regulation 2.4 and the University’s Fraud Response Plan set out the responsibilities in dealing with irregularities or suspected irregularities in the exercise of the business of the University.

2.10. The Director of Finance must be informed, as soon as is practical, of any irregularity or suspected irregularity concerning financial matters. Fraud can be defined as including any of the following: theft, false accounting, bribery, corruption, money laundering (see sections 4.50 to 4.53 below), forgery, deception and collusion or other financial malpractice. Allegations of suspected bribery must be reported to the Head of Compliance and Risk.

2.11. The Registrar, Secretary and Chief Operating Officer is ultimately accountable for the investigation of all such matters, but will usually delegate to the Director of Finance the responsibility for setting up such investigations. He or she will involve the internal auditor and other relevant staff, and may, if necessary, contact external agencies such as HEFCE and the police. See section 4.53 and the Money Laundering Policy below on reporting suspected money laundering.

2.12. The report that is produced from the investigations that are undertaken will be forwarded to the Registrar, Secretary and Chief Operating Officer who will take such steps as are necessary to pursue the matter. This may, if any investigation confirms the irregularity, involve the commencement of action under the University's disciplinary procedures.

The Fraud Response Plan illustrates how investigations into such allegations should be conducted. It provides staff with information regarding the reporting lines, authority levels and responsibilities for action in the case of a suspected fraud. The Fraud Response Plan allows the University to vary the approach taken in individual cases, within the constraints of General Regulation VIII, the Financial Regulations and Financial Procedures. Generally, the approach taken shall depend on the perceived risk to the University in a financial or reputational sense, based on the information available. The Registrar, Secretary and Chief Operating Officer will usually delegate the responsibility for investigating allegations of fraud to the Director of Finance. However, ultimate accountability rests with the Registrar, Secretary and Chief Operating Officer.

If a fraud is suspected, please report it to the Director of Finance without delay, cc the Internal Control Accountant.

The University has an Anti-Corruption and Bribery Policy.

There is also a Bribery Act Statement.

Both these policies are overseen by Dr David Barker, the Director of Compliance and Risk, who is the University’s Anti-Bribery Officer. Any alleged incidents of bribery or corruption should be reported to Dr Barker without delay

Further information on the Compliance and Risk Office is available.

Investigations into academic fraud are not undertaken by staff in the Finance Directorate. Allegations of fraud in research, such as plagiarism of research, unethical behaviour and faked results, are dealt with by the Research Governance, Ethics and Integrity Section within the Directorate of Research and Business Engagement Support Services. Mrs April Lockyer is the Head of Research Governance, Ethics and Integrity.

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