Reporting suspected fraud and whistle-blowing

University Council's Policy

When financial internal controls are operating satisfactorily within an institution the likelihood of theft or fraud is reduced, although it cannot be completely eliminated.

It is the responsibility of the Head of Institution, and for other senior staff within the Institution, to establish suitable controls to both prevent and detect fraud. However, where there is suspicion of any financial irregularity, then any member of staff aware of such an irregularity should notify the Director of Finance immediately. 

The Director of Finance may then advise the Internal Audit function and, where relevant, the University’s security adviser. Institutions are advised not to take action until the Director of Finance is informed and an appropriate fraud response plan prepared.

The Council is committed to maintaining an honest and open atmosphere within the University. It is therefore, committed to the elimination of fraud and to the rigorous investigation of any such cases. The Council wishes to encourage anyone who has reasonable suspicions of fraud to report them.

Definition of fraud and purpose of this procedure

For the purposes of these procedures, fraud is defined as the use of deception, or intentional misrepresentation, to obtain an unjust or illegal financial advantage or deprive the University of any value or property. This procedure note provides guidance on the steps to be taken by a member of staff within any institution, who has reasonable grounds for suspecting a fraud

Fraud Response Procedures for Institutions

Communicating concerns

Suspicion of fraud or irregularity may be communicated through a number of channels, including the following:

• Financial Regulations: requirement to report fraud or irregularity to the Director of Finance
• Internal and external audit work
• "Whistle blowing" policy
• Routine operation of procedures in accordance with the University's Financial Procedures Manual.

All actual or suspected incidents of fraud should be reported without delay to the Director of Finance (Financial Regulation 20.1). If the incident relates to the Director of Finance then the incident should be reported to the Registrary. Reporting an incident can be by means of e-mail, telephone or memorandum, and can be done anonymously.

Depending on the nature of the reported incident, the Director of Finance may convene a group to decide on the action to be taken. There will normally be an investigation, assisted by the internal auditor and if necessary the University Security Adviser and police.

All information provided will be treated in absolute confidence.

Prevention of further loss

Where initial investigation confirms that there are reasonable grounds for suspecting a member or members of staff of fraud, the Director of Finance will decide how to prevent or reduce further loss. This may justify the suspension, with pay, of the suspect(s) in accordance with any legal and relevant University procedures.

Establishing and securing the evidence

It is essential that concerns are reported immediately to the Director of Finance so that action can be taken to secure evidence of a fraud. Members of staff, including the Head of Institution, must not undertake their own internal investigation, as this may undermine any future investigation. It is important to ensure that the appropriate procedures under the Police and Criminal Evidence act are followed, that any investigation is, and is seen to be, objective and independent, and that all relevant University financial procedures and staffing policies are followed.

Reporting

The Director of Finance, when it is appropriate, will advise the Head of Institution of any relevant feedback, in particular or the outcome of the investigation and if there may be on-going implications for financial control within the institution.

Director of Finance
E-mail: Daniel Benham

Whistle blowing

Whistle-blowing is a term used to describe incidents where an employee publicly discloses some alleged wrong doing within an organisation.

The University policy on whistle-blowing can be found on the HR website.

Any member of staff who reasonably believes that there is serious malpractice relating to any 'protected matter' specified in the University's whistle-blowing policies should raise such an issue using the specified procedure.