2.8 Policy and Procedures on Fraud Response

2.8.1 University Policy on Fraud

The University adopts a zero tolerance approach towards fraud.

The University’s response will include the involvement of both the internal audit service and, where necessary, the police in investigations, as well as taking action through its disciplinary procedures. In all cases where there is sufficient evidence the University will work with the police to pursue a prosecution.

The governance of fraud response falls to Audit Committee but action remains with management.

All members of staff have a duty to protect the University from the possibility of fraud by remaining vigilant and by reporting any suspected instances of fraud to the University’s Director of Finance. In reporting their suspicions, members of the University will be protected by the University’s Policy on Whistleblowing .

2.8.2 Procedures in the event of a suspected fraud

As soon as practicable after notification of a suspected fraud a meeting of the Fraud Incident Group will be convened. This will comprise:

  • Director of Finance (chair)
  • A senior representative of the University’s internal audit service
  • Director of Human Resources, or senior representative

At this initial meeting the Group will review the information presented and decide whether further investigation is warranted.

Where it is decided that the incident merits further investigation the Fraud Incident Group will then:

  • Decide whether the University’s internal audit service be commissioned to conduct a formal investigation or whether an investigation should be undertaken by University staff.
  • Where the Fraud Incident Group decide that the is a need for a formal investigation by the internal audit service the Group will define the terms of reference for the internal auditor’s investigation team. The investigation team must ensure that the investigation:
    • is undertaken to professional audit standards;
    • operates within the University’s disciplinary procedures;
    • collects evidence and conducts interviews within the scope of the Police and Criminal Evidence Act;
    • considers all breaches of legislation that may have occurred; and
    • ensure that individuals receive the protection offered by legislation.
  • Ensure that management and staff of the University cooperate with the investigation and that any information required by investigation team is provided expeditiously.
  • Assess whether the information currently available to them warrants the involvement of the police and review this on a regular basis.
  • At the earliest possible opportunity, notify the following that an investigation is taking place.
    • Chair of Audit Committee;
    • Chair of Council;
    • President and Vice Chancellor;
    • Registrar and Secretary
    • The University’s external auditors
  • In conjunction with the Investigation Team, manage whatever short term remedial action is deemed appropriate to recover lost funds or prevent further losses. This may involve liaison with the University’s suppliers, customers, bankers, insurers and other relevant parties, as well as the police where it has been decided that the incident merits police involvement.
  • Arrange for those suspected of involvement in the alleged fraud to be suspended from the University where it is considered that this is necessary to prevent destruction or removal of evidence that may be needed to support future disciplinary or criminal action. This must be led by the Division of Human Resources who must formally suspend the suspect(s) in line with the University’s Ordinance on Discipline. Staff from the University’s Security Office should also be present, if appropriate.
  • Contact the Director of Information Technology Services to request the withdrawal of the suspended individuals’ access rights to the University’s computer systems.
  • Ensure the coordination, where appropriate, of internal disciplinary, criminal prosecution and professional sanctions for relevant employees.
  • Determine whether the circumstances are such that the University should inform HEFCE, as required by the HEFCE’s Memorandum of Accountability and Assurance and action this.
  • Take responsibility for liaising with other relevant external bodies such as research councils.

In the event of any press enquiries, the Fraud Incident Group will refer these to the Director of External Relations, who will be briefed by the Chair of the Group.

2.8.3 The Investigation and Report to Audit Committee

The Fraud Incident Group will liaise with the investigation team throughout their investigation and provide regular updates to the Chair of Audit Committee; the Chair of Council; the President and Vice-Chancellor and the University’s external auditors.

On completion of the Internal Audit investigation, a written report shall be submitted to the Audit Committee containing:

  • a description of the incident, including the value of any loss, the people involved, and the means of perpetrating the fraud;
  • the measures taken to prevent a recurrence; and
  • any action needed to strengthen future responses to fraud, with a follow-up report on whether or not the actions have been taken.

This report will normally be prepared by the Internal Audit service.

2.8.4 Whistleblowing arrangements

As stated above, information about a fraud may be brought forward under the umbrella of the University’s whistleblowing policy, provided under the Public Interest Disclosure Act 1998.  All disclosures made will be treated under the terms of the policy.

2.8.5 Other potential criminal activity

Members of the University who have concerns regarding potential instances of bribery or corruption should report their concerns to the Registrar & Secretary under the terms of the University’s Policy on Bribery & Corruption. All other suspected criminal activity, for example, theft of University or personal property, vandalism or intruders on University property should be reported to the University’s Security Office directly.

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