ࡱ> ` vbjbjss 8nZ6Z6Z6Z6<6d_277777777 _______$`h(c3_|:77|:|:3_77H_r<r<r<|: 77 _r<|: _r<r<nYK-\76 n]bZ6: Z \,^_0_[c:c@-\c-\7s8hr<8T/9M7773_3_\<777_|:|:|:|:#v( v(  Policy for Fraud Prevention, Detection and Investigation Introduction The University, like other public bodies, has a duty to conduct its affairs in a responsible and transparent way and to take into account both the requirements of funding bodies and the standards in public life enunciated in Lord Nolans reports. The University has a responsibility to the Scottish Funding Council (SFC), its staff, students, suppliers and the public in general to take all reasonable steps to prevent the occurrence of fraud. The Universitys policy on fraud is set out in the Fraud Policy Statement which is attached at Appendix 1. This policy sets out in more detail procedures for fraud prevention and detection; and the investigating and reporting of fraud. The objectives of this policy are to: encourage staff to be aware of fraud; bring suspected fraud to notice; provide a framework response plan for investigating and reporting fraud; and ensure both alleged and proven fraud are dealt with in a consistent and timely manner. The University has a unique role to play in the community and any instances of fraud or corruption may be damaging to public confidence and support. Losses due to fraud, theft or corrupt practices can have a direct effect on jobs and the level and quality of service provision. It is wrong to assume that actual financial losses are the only negative outcome of frauds. The full cost is usually much greater than the amount misappropriated, as the costs associated with correction can often be substantial. Staff morale and the level of confidence of students, clients, suppliers and funding organisations may decline as a result of successful frauds. Although the University recognises that the vast majority of staff are honest and diligent, there is no room for complacency. Vigilance is essential since all staff are responsible for ensuring that the best possible service is provided to the Universitys students and that value for money from the expenditure of public funds is obtained. Successful fraud prevention involves creating an environment which inhibits fraud. Taking immediate and vigorous action if fraud is detected is not only necessary to prevent future losses, but also helps deter other frauds. A manager who is alert to the possibility of fraud and who acts accordingly on a day to day basis is a powerful deterrent against fraud. This policy compliments the Universitys policy on Public Interest Disclosure and the Code of Good Practice for Research which details how research fraud will be dealt with. Fraud Prevention Definitions Fraud can be defined as any act of wilful dishonesty to gain individual or collective advantage. It is taken to include theft, misuse of property, corruption, the alteration of financial or other records or any unauthorised act which results directly or indirectly in financial gain to the perpetrator or a third party. Fraud can be perpetrated against the University by staff, students, suppliers, Government Agencies or Departments or the public. Staff should be aware that gifts, including hospitality, offered by contractors, suppliers and service providers may place an employee in a vulnerable position. For guidance, business gifts, other than items of small intrinsic value such as business diaries, pens or calendars, should not be accepted and any cash or gifts, gratuities or rewards, which exceed 15 in value, should be politely refused. Modest hospitality is an accepted courtesy of a business relationship but the recipient should not allow him or herself to reach a position where he or she might be deemed by others to have been influenced in a business decision as a consequence of accepting such hospitality. The frequency and scale of hospitality should not be significantly greater than the recipients employer would be likely to provide in return. Offers of gifts and hospitality of an unreasonable nature should be politely declined and advice sought from the relevant Head of Department or Service Director, or in the case of these staff the University Secretary of Deputy Principal. Management Responsibility and Risk Management The prime responsibility for preventing fraud lies with management through: identification of risks to which systems and procedures are exposed; the design, implementation, documentation and operation of internal controls; establishing an environment that promotes compliance with internal controls; promoting fraud awareness amongst staff; and fostering an anti fraud culture. However, while managers are responsible for assessing and controlling the level of risk within their areas of authority, it is the responsibility of all staff to be aware of fraud and take the necessary steps to minimise the risk to the University. Managing the risk of fraud is the same in principle as managing any other business risk. It is best approached systematically both at organisational and operational level. Managers should identify risk areas, assess the scale of risk, allocate responsibility for managing specific risks and implement and test controls to minimise the risks. Management also has a responsibility to familiarise itself with common fraud techniques in areas for which it has control. This should include being alert to signs, which may indicate that fraud is taking place, examples are given at Appendix 2. Internal Controls Internal controls are the key element in preventing fraud, these include both financial and non-financial controls e.g. annual leave records; and those that are in place to safeguard the mis-use of University assets including computing systems. The Financial Regulations are just one example of these controls. Financial and other non-financial procedures, however, should be definitive and all procedures should be fully documented and widely available to all staff, who should be reminded regularly as to the importance of compliance. It is the responsibility of management to ensure that controls in their areas of responsibility have been documented and communicated. In order to set a good example, managers should be seen to be complying with all controls. The emphasis should be on creating a culture of honesty and fraud detection, not on increasing the volume of detailed operational and supervisory checks and controls unnecessarily. Management should periodically monitor compliance with controls; this will also be supported and reinforced by reviews conducted by Internal Audit. It should be emphasised that the prime function of internal audit is to evaluate the effectiveness of the overall framework of internal control, with management being responsible for ensuring implementation and monitoring of the framework. Common excuses for non-compliance with controls are that they are no longer applicable, insufficient time is available or they are not appropriate. It is important that such comments are reported to line managers so that the need for the controls can be re-evaluated. Management Checks The prevention and detection of fraud and impropriety is only possible where strong internal controls are present and constantly applied. Routine checks and monitoring by management to ensure that procedures are being followed are, therefore, essential. The benefits from implementing a culture of strong management controls are: a deterrent effect when it is known that management is actively involved in ensuring that procedures are followed, and the results of the checks will allow management to identify any operational areas where controls are not being uniformly applied and investigate whether systems have been exploited. Staff/Training Staff adhering to systems and procedures, and who are not inhibited to challenge matters which do not appear to be correct, provide the best protection against fraud and corruption. It is important, therefore, that University policy on fraud prevention and investigation is fully communicated to all staff. The lack of clear guidance and ignorance of procedures will often be the first excuse used by offenders. The recruitment of suitable staff is the Universitys first defence in preventing fraud. Best practice recruitment policies such as detailed application forms including a statement on criminal records, communication with referees and past employers and verification of educational and professional qualifications will be strictly adhered to. Staff awareness of policy and procedures is fundamental to the effective operation of systems. The University will comply with best practice, which includes: instruction in and discussion of control and probity issues as part of staff induction; formal staff training on operational procedures; desktop instructions for specific tasks; publication of University policy on fraud; and regular staff notices regarding changes to financial procedures. Reporting and Investigating Fraud Proper and consistently applied procedures for reporting and investigating fraud will play an important part in preventing further fraud. The University expects that reported suspicions will be investigated. Such investigations will by necessity remain confidential, but management will ensure that the lessons to be learnt from each incident are disseminated to the appropriate members of staff. Appendix 3 details the Fraud Response Plan which will be implemented where fraud is suspected. Fraud Detection and Reporting The primary responsibility for detecting fraud lies with management through the implementation, documentation and operation of effective systems of internal control. The Universitys internal auditors, through their evaluation of the control framework also have a role to play in preventing and detecting fraud, although this is not the main function of internal audit. All staff have a responsibility to be aware of the potential for fraud and take the necessary steps to minimise the risk to the University. Management should ensure staff in their areas of operation are familiar with the common types of fraud. The University is not advocating the creation of an overtly suspicious environment, but expects staff to be alert to the potential for fraud in areas where they operate. Staff will often be the first to notice the potential for, or actual, fraud. Staff suspicious of fraud should in the first instance report their concerns to the University Secretary. If for any reason it is felt that reporting in this manner is inappropriate, staff may report directly to any of the officers named below, who collectively will investigate all frauds. If the allegation is about the University Secretary then the allegation should be made to the Principal. Fraud Investigation Group The Director of Finance The Chief Accountant Head of Treasury & Capital Accounting University Secretary The Director of Human Resource Services This requirement to alert management is not confined to suspicions about other members of staff, but includes any misgivings staff may have about students, contractors, suppliers, etc. (See also Public Interest Disclosure Policy.) Staff should not be dissuaded from reporting actual or suspected fraud as all cases will be treated in the strictest confidence. The University is fully committed to supporting and protecting staff who raise legitimate concerns and the anonymity of individuals who report any suspicions will be preserved if requested unless this is incompatible with a fair investigation. Provided the allegations have been made lawfully, without malice and in the public interest, the employment position of the person will not be disadvantaged for reasons of making this allegation. Any action to prevent the reporting or any attempts at intimidation will be treated seriously and the University will take immediate action. The Fraud Investigation Group will investigate any suspicion of fraud. After an initial in-house investigation to establish if there is substance to any suspicions, the Group will determine the action to be taken subsequently, which may include reporting to the Internal Auditors; in the case of major frauds this will include the Scottish Funding Council and the Police as appropriate. Fraudulent or corrupt activity is regarded as a breach of contract and where there are reasonable grounds for suspicion then suspension, pending the outcome of enquiries, is likely. Where fraud is detected then disciplinary procedures will be instigated and this may lead to dismissal of the individual concerned. In all cases the University will co-operate fully with whichever investigating body has been appointed. In the event that the Police become involved, the University will pursue prosecutions where possible. Line managers should note that staff suspected of fraudulent activity have certain rights under the law and no action (such as interviewing staff) should be taken without prior consultation. Failure to follow established procedures in relation to investigating fraud and interviewing the staff involved can invalidate disciplinary action and compromise the success of any future investigation and/or prosecution. The Department of Human Resource Services must always be involved. APPENDIX 1 Fraud Policy Statement The University is committed to taking all practical steps to prevent it being subjected to fraud whether perpetrated by staff, students, contractors and suppliers, other organisations or members of the public. The University will maintain robust control mechanisms to both prevent and detect fraud. All line managers have a responsibility for maintaining documented control systems and must be seen to be setting an example by complying fully with procedures and controls. The effectiveness of controls will be subject to cyclical review by the Universitys internal auditors. All members of staff have a responsibility to protect the assets and reputation of the University and are expected to be alert to the potential for fraud. Line managers will be expected to brief staff on the common types of fraud perpetrated in their areas of responsibility. Confidential mechanisms have been established to allow staff (see footnote) to report suspected frauds to management. All reported suspicions will be investigated by the Fraud Investigation Group. If this initial investigation suggests that suspicions are confirmed, the Fraud Investigation Group will then decide which body is best placed to undertake further investigative work and will inform the Principal, the Chairman of Audit Committee, the Chairman of Court, the auditors, the Scottish Funding Council and Police as appropriate. If fraud is proven which involves staff, appropriate disciplinary action will be taken. Such action may be considered not only against those found to have perpetrated the fraud, but also against managers whose negligence may have facilitated it. Further information for staff on reporting fraud and their role in the prevention and detection of fraud is given in the University Policy for Fraud Prevention, Detection & Investigation. Relationship with other University Policies The Public Interest Disclosure Policy relates to allegations made by employees, students or Governors of serious malpractice in the conduct of work of the University. The Public Interest Disclosure Policy requires that any such allegations must be made in the first instance to the University Secretary, and it will be his decision as to whether or not any allegations made under this Policy are passed to the Fraud Investigation Group. APPENDIX 2 Signs that may indicate a fraud is taking place Staff under stress without a heavy workload Staff always working late Prime documents being lost and replaced by photocopies Excessive use of correcting fluids. Reluctance of staff to take leave Staff refusing promotion Unexplained wealth and sudden change in lifestyle New staff resigning quickly Suppliers/contractors insisting on dealing with a particular member of staff Cosy relationships with suppliers/contractors/customers Sudden changes in behaviour APPENDIX 3 Fraud Response Plan Introduction Management and staff are likely to have little experience in dealing with fraud and when suspected cases arise, may be unsure of the appropriate action to take. The objectives of this response plan are: to provide a documented framework which the University can refer to in the event that fraud is suspected or reported; and to ensure that in the event of fraud, timely and effective action is taken to prevent further losses, identify fraudsters, safeguard evidence, minimise publicity, reduce adverse effect on the business and to learn lessons. Distribution of the plan should be restricted to those who need to know, but its existence widely communicated to reinforce commitment to preventing and detecting fraud. Reporting Fraud The Fraud Policy outlines two methods by which staff can report suspected fraud: to the University Secretary; to a member of the Fraud Investigation Group When staff report suspected fraud it is important that their suspicions are treated seriously and that all details provided by the reporting employee are recorded accurately and in a timely manner. They should be repeated to the reporting employee to confirm understanding. Of primary importance, regardless of the method of reporting, is the need to put staff at ease since the decision to report may be traumatic for the individual concerned. Employees (or others) reporting fraud should be assured that all information will be dealt with in the strictest confidence and that their anonymity will be preserved if requested, unless that is incompatible with a full and fair investigation. Regardless of the direction any future internal or Police investigation may take, the anonymity of any whistleblower must be guaranteed during the initial investigation. The advice of Human Resource Services must be sought at an early stage to see if any guarantees over future employment would be appropriate. The University would not normally expect the employment status of any whistleblower to be affected unless they themselves have broken the law or admit to gross misconduct. Having recorded the details of the individual case, the University Secretary should immediately contact a member of the Fraud Investigation Group providing all recorded details together with any supporting evidence or documentation. At this stage management should also take whatever steps are necessary to prevent further losses, e.g. by changing procedures or suspending payments - without compromising the quality of evidence or alerting the fraudsters. Initial Enquiry The University has established a Fraud Investigation Group comprising staff at a suitable managerial level who have the full support of senior management and Court and who are provided with sufficient resources to allow effective investigations to be undertaken. It will be the Fraud Investigation Groups responsibility to gather and review information on all reported fraud and advise senior management and the Police of all significant cases. On receiving details of a suspected fraud, the Fraud Investigation Group should undertake as limited a review as is necessary to establish whether the accusation does require further investigation. Any detailed internal investigation at this stage runs the risk of alerting the perpetrator and the destruction of evidence. Until there is sufficient evidence to support the accusation, the details of the case should be kept internal to the University, and ideally restricted to the Fraud Investigation Group. If such an initial investigation does support the allegation, the Principal, Chairman of the Audit Committee and the Chairman of Court should be advised. Once the Fraud Investigation Group is satisfied that there is a case to be answered, immediate steps should be taken to safeguard any evidence and to revisit the action taken to see if further measures can be taken to prevent further losses. If staff are implicated at this stage and it would appear that there is sufficient evidence to justify future disciplinary action, the possibility of suspension should be considered. The rights of staff on suspension should be acknowledged, such as their right to union representation and to be informed why they are being suspended. At this stage the University must decide if they wish to involve external parties including SFC, and the Police. Such a policy is consistent with maintaining an environment of probity and provides a clear message to employees as to the Universitys attitude towards fraud, corruption or misappropriation. Consideration should also be given to informing SFC, both internal and external auditors and other educational institutions, if appropriate. Delays in contacting the Police may prejudice future enquiries and alerting them immediately is important since they will be able to advise the University how best to proceed and consult with management on the most effective methods to gather evidence. Conducting a Fraud Enquiry Once it is agreed that there is sufficient evidence to justify a fuller investigation, the Fraud Investigation Group should meet with the Police to decide who is best placed to undertake the further investigation. Should it be decided that an internal investigation is appropriate, either in tandem with a police investigation, or on its own, it is important that it is undertaken by individuals with experience in fraud investigations. This is most likely to be the internal auditors, supported as necessary by University staff who may have the specialist knowledge required. HM Treasury recommends that Directors of Finance and Chief Internal Auditors initiate contact with the local Fraud Squad and agree with them a course of action to follow when fraud or corruption is suspected. Close liaison, together with adherence to this Fraud Response Plan, should help ensure that police investigations and internal enquiries/disciplinary procedures are complimentary and can proceed concurrently. Properly conducted internal investigations can greatly assist the Police and it is, therefore, important that there is prior consultation and agreement to the scope, objectives and methodology of any subsequent enquiries. Once the Fraud Investigation Group has decided that an internal enquiry should take place, and who should undertake it, a detailed remit should be agreed, including deadlines for reporting. Throughout the course of the enquiry there should be regular meetings between the investigators and the Fraud Investigation Group with minutes taken and agreed. All involved should be clear on the scope of any investigation. Is it simply to confirm that there is sufficient evidence to support the allegations, to gather evidence for the Police or does the University wish to quantify the total potential loss? There is an obvious requirement to record all details fully, accurately and in a manner that is accessible. The Police should be able to advise on an appropriate recording format. Developing a simple form to log all events and contacts made will provide a quick case summary, ease the recording process and provide documented support for any future enquiries or possible prosecution. It is also important that any losses incurred by the University are fully and accurately recorded and that costs are correctly apportioned. In addition to the direct cost of losses attributable to the fraud, all costs associated with enquiries should also be recorded as these will be required under loss reporting procedures and may also be required by the Courts if the decision to prosecute is taken and in determining any assessment of costs or compensation and insurance recoveries. Staffing Issues A member of Human Resource Services should be on the Fraud Investigation Group as further investigations may have employee rights and disciplinary repercussions. Human Resource Services has a role to play in ensuring confidentiality and protecting individuals who report fraud and any policy developments should include their input from Human Resource Services. Of crucial importance in any fraud investigation is the need to conduct enquiries within the parameters of relevant laws and regulations. Employees have certain statutory rights, and if infringed, the likely success of disciplinary action or prosecution is diminished. It is vital, therefore, that any interviews with suspects are undertaken strictly in accordance with established procedures. No interviews should progress without first seeking advice from the Police and Human Resource Services on the relevant procedures and rules to be followed. In particular, all those involved in interviewing suspects should have knowledge of the 1994 Police & Criminal Evidence Act. Concluding an Investigation At the end of a case, irrespective of outcome, it is important that the progress of the investigation is reviewed to see what lessons can be learnt and to assess the effectiveness of the action taken. Such reviews will help identify any weaknesses in internal control that initially led to the fraud and should highlight any deficiencies in the systems for reporting and investigating, enable more effective future enquiries and precipitate changes to internal procedures designed to prevent reoccurrence. Reviews should be undertaken by a member of the Fraud Investigation Group in consultation with relevant line managers and a brief report summarising the main points of the case produced for Audit Committee discussion and consideration. Where enquiries have resulted in disciplinary action or a successful prosecution, consideration should be given to publishing summary details for staff circulation. This could be in the form of a staff notice, briefly covering the case details and reiterating the overall University policy on fraud. This open approach is likely to be appreciated by the majority of staff, would emphasise the Universitys active commitment to maintaining probity of operations and may indeed have a deterrent effect. Finally, in recognition of collective commitment to maintaining robust systems of internal control, copies of such reports should be circulated to both Internal and External Audit in order that they can assess the impact on the control systems and (in consultation with management), evaluate and amend their planned activity accordingly. APPENDIX 4 Fraud Investigation - Checklist for Line Managers The following is a checklist of points for consideration following the reporting of an alleged fraud to line management. Do not rush in - consider all options and plan the approach. Establish facts without alerting anyone. Maintain confidentiality. Make an immediate note of everything reported. Repeat these notes to whoever is reporting the details to ensure clear understanding. Take steps to minimise any immediate further losses. Secure any evidence. Inform the University Secretary or a member of the Fraud Investigation Group. Fraud Investigation - Checklist for Fraud Investigation Group The following is a checklist of points for consideration following the reporting of an alleged fraud by line management to a member of the Fraud Investigation Group. The Fraud Investigation Group convenes to consider allegation. Initial investigation to establish substance of allegation. Consider legal implications. If substantiated, inform the Principal et al. Agree if further investigation is required and who will undertake it. Agree a remit, establish scope of investigation and reporting deadlines. Ensure investigating team has adequate resources, including secure storage. Prepare for interviews thoroughly. Ensure existing staff disciplinary policies are followed. Secure any evidence. Assume the worst case scenario in terms of losses and staff involved. If not already requested to undertake the investigation, inform Police, Auditors and SFC as appropriate. Hold regular progress meeting at which progress and agreed action is documented. Identify all internal and external sources of information and evidence.  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