Key changes to recently updated policies
The University has updated a number of important policies and procedures relating to anti-bribery, fraud and whistleblowing to counter a global rise in fraudulent activity such as cybercrime. The changes were approved in September 2020.
The four policies and accompanying procedures that have been updated and published online are:
- Anti-Bribery and Corruption
- Gifts and Hospitality
You can find them below:
The policies will explain to staff and students:
- what fraud is, how to prevent it and how to report it.
- recognise bribery, how to prevent it and how to report it
- the process to follow when receiving or giving gifts/hospitality; the registers to maintain
- what whistleblowing is, the steps to take should you need to raise a concern and how you are protected by the law and the University
Summary of key changes
- A major change has been to separate out policy and procedures into two separate documents
- There is now a clear policy document and procedures document, which outline what you should and shouldn’t do if you discover suspected fraud.
- All staff and students are responsible for recognising and reporting fraud in the correct way.
- Suspected fraud should be reported through the reporting lines laid out in the Procedures in order for it to be dealt with as quickly and efficiently as possible.
- Investigation should only be carried out by a trained officer.
- A new flowchart takes you through the process of the Fraud Investigation procedure.
- We have clarified what is covered by whistleblowing law, including the distinction between a personal grievance and a whistleblowing complaint in the public interest.
- The policy aims to encourage staff to report suspected misconduct without fear of reprisal.
- Information such as communication channels, and what is required when making a complaint are explained more clearly.
Anti-Bribery and Corruption
|Breaches||Breaches of this policy could lead to the University or its subsidiary companies committing the criminal offence of failing to prevent bribery.|
|Reporting Form||A separate reporting from is available for staff to raise concerns around money laundering.|
|Training||Training on anti-bribery and corruption is available via the University’s online portal. Line managers will confirm with staff which training they are required to undertake as part of their role.|
|There is a Finance online training module about how the Bribery Act 2010 affects your work.|
|Guidance note changes|
|1.1 FAQ||If a member of staff of the University in the UK or overseas needs to promote the University's activities with a foreign public official, the member of staff must contact their Head of School/Support. Department in advance to confirm what steps are appropriate in any dealings they intend to have with the foreign public official.|
Gifts and Hospitality
- Other business ethics policies are now cross-referenced in the Gifts & Hospitality Policy.
- The Policy applies irrespective of country of operation.
- Two registers of gifts and hospitality (G&H) must be kept, one for G&H received and one for G&H provided. Details of what the register must contain are set out in appendices 1 and 2 of the policy.
- The updated G&H Policy sets out the processes to be followed by staff. Heads of School or Professional Service units must approve any offers of gifts and hospitality over £50 for acceptance.
- A formal record of gifts and hospitality accepted over £50 must be kept in a Register in Schools or Professional Services units. Such records must be maintained by the relevant School or Professional Services unit in a complete, up-to-date, and accurate manner. On request by an interested party, the information may be published at the discretion of the University, requested for review by Internal Audit, or made available under the provisions of the Freedom of Information (Scotland) Act.
Please read this list of Frequently Asked Questions for further information on the above policies.
Please use this form to submit any questions you have that are not answered in these FAQs.
Reporting fraud: It is very important that you follow the correct procedure, which can be found here. Search for the policy and/or procedures relevant to your issue, and follow the instructions within the document.