Bribery and fraud

Guidance for academic, administrative and support staff, including anti-bribery and anti-fraud policies

Bribery and fraud are criminal offences under UK law and under the criminal codes of many other countries. They are activities that divert money and resources towards the personal gain of a few, often to the cost and detriment of the many. Globally they hinder growth of the legitimate economy, and act as a barrier to efficient and effective governance; their presence can also aggravate insecurity and potential conflict.

Within the context of the University’s undertakings, its use of public funds, and objectives for the advancement of learning for the wider benefit, such unethical activities clearly cannot be sanctioned or supported. In addition to ethical concerns, the incidence of bribery or fraud could have wide-reaching and practical implications that directly affect the primary work of departments and research groups.

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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:

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':

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:

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:

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).

Contact us

Stephanie Norman, Head of Risk, Compliance and Assurance 

Email: stephanie.norman@admin.ox.ac.uk

Tel: (01865 2) 70285