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University Fraud and Bribery Policy

Information about the University's approach to Counter Fraud and Bribery

University Counter Fraud and Bribery Policy

Fraud, bribery and corruption divert money and management attention away from the University’s core operations and could threaten the University’s reputation.  Like many organisations, the University is exposed to a range of corruption-related related risks and to individuals or groups who may act in a corrupt manner.  

Fraud and Bribery risks

Examples of fraudulent behaviour include:

  • Scams which target our students
  • Creating or using forged or falsified documents (e.g. exam certificates)
  • Theft of cash or University property, equipment and software 
  • Misuse of the corporate credit card
  • Falsifying time or expense records
  • Dishonest use of Intellectual Property
  • Using University-paid travel for private purposes
  • Misuse of sick or family leave
  • Receiving or giving kickbacks or secret commissions to or from third parties

Related Money Laundering risks

A specific type of fraud which the University may be exposed to is where people and/or organisations wish to use the University to launder money, to make it their "dirty" money (e.g. gained through criminal activities such as drugs, prostitution or people trafficking) appear legitimate.  They could try to give us this cash or items purchased by that cash (normally art or artefacts), which could mean that the University inadvertently "handles the proceeds of crime".  This is a particular legal offence and reporting of suspicious transactions is strictly regulated (i.e. outwith the normal fraud and corruption reporting procedures) to ensure that criminals are not "tipped off" inadvertently, which is also a criminal offence.   

The University's response

The University has a number of Policies which should minimise these risks, including a Counter Fraud and Bribery Policy and an Anti-Money Laundering Policy and an e-learning "Business Without Bribery" module for key members of staff.   

The University is committed to high standards of ethical behaviour, acting with integrity and upholding the law.  Acts of fraud, bribery and other corrupt behaviour will not be tolerated in any of the University’s activities, at home or abroad, including where such activities are carried out by third parties acting on the University’s behalf. 

The University also strives to create and maintain an honest, open and well-intentioned working environment where University staff and other stakeholders are confident to raise their concerns without fear of reprisal. 

This Policy outlines expectations of staff and third parties and 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 necessary steps will be taken to recover any losses incurred.

To view the full University Fraud and Bribery Policy document, please click here(pdf).

To view a reporting procedure flowchart, please click here (pdf)

Key information on global fraud and corruption (including anti-money laundering), as well as related information on University banking restrictions caused by international sanctions, can be found here

 

Key contacts:

Queries on Fraud, Bribery and Corruption should be referred to one of the following:

  • Policy Owner: Adam Dawkins, Head of Governance, extension 4335
  • Susan O'Donnell, Risk Manager, extension 4222

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