Bribery and fraud

We have created a page containing helpful answers to questions such as What is bribery? What are facilitation payments? And when is a gift not a gift? Visit Definitions and Interpretations.

The following PDF provides a very short briefing on UK legislation and the corresponding University policies for all members of staff:

• Bribery: essential reading ( , 467kb)

A number of case studies from different parts of the University are available.

The University's Anti-Bribery Policy (for all staff and associated persons).

The University's Anti-Fraud Policy (for all staff and associated persons).

In a recent news update, the British Universities Finance Directors Group (BUFDG) noted that ‘over the last few months there have been a number of alerts circulated by BUFDG members about Executive impersonation fraud, whereby a fraudster uses clever email tricks to send an email to the finance department – purporting to be from a university leader (normally a V-C, FD, or similar) – requesting a payment. Enough of these have been doing the rounds (not just in HE) to gain the attention of the Government Internal Audit Agency. It has produced a useful briefing, which provides context, detection and protection tips, and more':

• A4 Briefing on Executive Impersonation Fraud ( , 244kb)

Further information can also be found on the University’s Information Security website.

The procedure for reporting suspected cases of bribery or fraud can be found at the end of both the Anti-Bribery and Anti-Fraud Policies.

The University also has a Public Interest Disclosure (Whistle-blowing) Code of Practice.

The aim of this toolkit is to enable departments to consider and assess the risk of bribery and fraud occurring within their activities. It may be used in whole or in part and consists of the following elements:

• consideration of the ‘why’, the ‘what’ and the ‘how’ of bribery and fraud;
• activity analysis;
• relationship analysis;
• risk assessment;
• due diligence;
• warning signs – indicators of potential corruption.

View the PDF here:

• Bribery and Fraud Risk Awareness Toolkit ( , 1.36MB)

Staff and students are encouraged to raise initial queries or requests for guidance on matters relating to bribery or fraud with departmental administrators in the first instance. If you have a query that cannot be dealt with by your departmental administrator, then contact the Vice Chancellor’s and Registrar’s Office Compliance Team by telephone or e-mail at:

• Telephone: (01865) (2)80179
• compliance@admin.ox.ac.uk

The following links may provide useful additional information in considering bribery and fraud risk within the University:

• Transparency International (for a variety of publications, including the annual Corruption Perceptions Index)
• Ministry of Justice (for guidance on interpreting the UK Bribery Act 2010)
• Crown Prosecution Service (for guidance on interpreting the UK Fraud Act 2006)
• Serious Fraud Office (for information on bribery and fraud, including links to the SFO's Corruption Indicators)
• Action Fraud (for information about fraud, including updates on the latest types of fraud)
• Public Concern at work (for free, confidential advice from this whistle-blowing charity).