Counter-Fraud and Anti-Bribery policy

We are committed to ensuring that we conduct our business in an open, ethical and transparent manner.

We are committed to the proper use of funds, both public and private. As a consequence, it is essential that staff, students, members of the Council or Committees established by the Council, contractors and third-parties are aware of the risk of fraud, corruption, theft and other activities involving dishonesty, in all its forms.

Our Counter Fraud and Anti-Bribery Policies apply to all staff and other persons associated with the University. The policies operate in the context of the Fraud Act 2006, the Bribery Act 2010, and all other related UK legislation which governs fraud, bribery and corruption.

Fraud is deemed to be the deliberate intent to deprive the University (and its associate activities) of money or goods. Attempted fraud is treated as seriously as accomplished fraud.

Fraud is broken down into three key sections:

• Fraud by false representation;
• Fraud by failing to disclose information; and
• Fraud by abuse of position.

It is the responsibility of everyone associated with the University to comply with this policy and report any suspicions of fraud or corruption. We have a “no retaliation” policy for people reporting suspicions, and concerns can be raised if necessary under the University’s Whistleblowing Policy.

Bribery is defined as giving someone a financial or other advantage to perform their functions or activities improperly or to reward that person for having already done so. A bribe does not have to be cash, neither does it have to be received; offering or requesting a bribe is sufficient to contravene the Act.

Bribery could include seeking to influence a decision maker by giving some kind of extra benefit other than what can legitimately be offered as part of a tender process. It could also include donations made to an institution which might be seen as influencing a trustee or official to act or decide in a certain way.

The Bribery Act is not intended to cover genuine hospitality or similar business expenditure that is reasonable and proportionate. Genuine hospitality, promotional or other business expenditure, in line with the guidance contained in our Financial Regulations can still be provided or accepted.

Further information

For further advice and guidance on the Anti-Bribery Policy, please contact:

For further advice and guidance on the Counter-Fraud Policy, please contact the Risk Advisor: