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Governance Documentation
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Anti-Bribery and Fraud Prevention Policy

1. Policy Statement/Purpose

1.1 Durham University ('the University') has a zero-tolerance policy towards bribery and fraud; actual or attempted. All staff, students, and associated persons are expected to conduct themselves with the highest standards of honesty, propriety, and integrity in all activities. The University is committed to encouraging prevention, detection, and a swift response to any instances of corruption.

1.2 The University is a charity and much of its income is derived from benefactions, public funds, and charitable sources. As such, the University has a legal duty to ensure that its resources and income are used solely for the purposes intended. The University must safeguard its operations and reputation, and the interests of its funders, donors, and members from the adverse consequences of fraudulent activities. 

1.3 The University is committed to preventing fraud through the promotion of a culture of integrity; it endorses and actively supports the implementation of proportionate, risk-based procedures to detect and prevent fraudulent activity. The University's fraud risk management framework is informed by the six key principles outlined within the Economic Crime and Corporate Transparency Act 2023 (ECCTA), namely:

  • Top level commitment.
  • Risk assessment.
  • Proportionate risk-based prevention procedures.
  • Due diligence.
  • Communication (including training).
  • Monitoring and review.

1.4 This policy is intended to deter any actions of fraud and assist staff and students in the detection of fraud for the purpose of safeguarding the University, its reputation and assets, and the assets of its members, supporters, partners and subsidiary companies, as far as is practicably possible. It sets out individual responsibilities in respect of both the prevention of bribery and fraud, and the procedures to be followed where bribery or fraud is detected or suspected.

1.5 This policy is applicable to all associated persons, including staff and student members of the University, all members of Durham Student Organisations, subsidiary companies, agents and other volunteer/lay members. Any fraudulent activities in relation to other individuals working with, on behalf of, or for the University should be reported through the same process. The Fraud Oversight Group (FOG) oversees the effectiveness and application of this Policy.

1.6 The University takes seriously any allegations of bribery or fraud and will investigate all such concerns. Staff or students found to be committing bribery or fraud (attempted or actual) will be subject to disciplinary proceedings which may result in dismissal or exclusion. The matter may also be referred to the policy and may lead to a prosecution.

2.0 Definitions and behaviours

2.1 Fraud

2.1.1 For the purposes of this policy, ‘Fraud’ is defined, in accordance with the Fraud Act 2006, as deception with the intent to 

a) gain an advantage, either for personal material (or other) gain, or for the benefit of another individual/group of individuals; and/or 

b) cause financial loss to the University or one of its subsidiary companies.

2.1.2 Intent is central to the University’s understanding of fraud regardless of whether actual gain or loss has occurred. It should be noted that fraud may be perpetrated by individuals internal or external to the University (for example, external fraud may occur via a breach of information security such as hacking), including associated persons. Fraud can be committed by making false representations, failing to disclose information, or by abuse of position.

2.1.3 This policy deems the following, (but is not an exhaustive list), as examples of fraudulent acts: 

  • Bribery.
  • Forgery.
  • Theft of cash or property.
  • Extortion.
  • Embezzlement.
  • Misappropriation.
  • False representation.
  • Concealment of material facts.
  • Destruction of records.
  • Knowingly retaining a salary overpayment.
  • Excessive personal use of University resources.
  • Money laundering and collusion.

2.1.4 ‘Failure to prevent fraud’ applies to several specific ‘base fraud’ offences, as outlined within schedule 13 of the ECCTA. Aiding, abetting, counselling, or procuring the commission of any of the listed offences also qualify as a base fraud offence.

2.2 Bribery

2.2.1 ‘Bribery’ is specifically defined in the Bribery Act 2010 as an inducement or reward that can be ‘financial or other advantage’ (such as money, contracts, gifts or offers of employment) which is offered, promised, or given to gain commercial, contractual, regulatory, or personal advantage. The offence of being bribed is defined as requesting, accepting, or agreeing to accept such an advantage, in exchange for improperly performing such a function or activity.

2.3 Behaviours

2.3.1 The following list of behaviours, which is not exhaustive, could be an indicator of fraud or irregularity but may also highlight personal or mental health issues and as such should be addressed with sensitivity:

  • Frequently altered documents, (particularly financial documents).
  • Incomplete or vague claim/expense forms.
  • Erratic or inconsistent application of processes and procedures; particularly those relating to cash handling.
  • Erratic, or noticeable changes in, behaviour.
  • Regular delays in the completion/submission of claims and financial reports.
  • Staff or students seemingly living beyond their means.
  • Staff or students seemingly under constant financial, academic or other stress (possibly due to situational pressures).
  • Reluctance to hand over or being secretive about work; particularly if the individual concerned is solely responsible for a risk area, including a reluctant to take annual leave to retain ownership of work.
  • Avoidance of audits or peer reviews (internal or external).
  • Inconsistent performance or standard of work.
  • Refusal of promotion.
  • Insistence on dealing with a particular individual.
  • Management override of controls.


3.0 Responsibilities

3.1 The Vice-Chancellor has overall accountability for managing the risk of fraud or bribery, but overall responsibility for the design of arrangements to manage fraud risks is delegated to strategic and operational risk owners (i.e. the University Executive Committee (UEC), directors and senior managers).

3.2 UEC leads by example, demonstrating the highest standards of ethical conduct and integrity. It actively promotes a culture where concerns can be raised openly, responsibly, and without fear of retaliation. staff, students, and associated persons are encouraged to speak up where they have concerns under this Policy, and the University will support those who raise concerns in good faith.

3.3 The University Secretary is responsible, in consultation with other senior managers, for ensuring adequate systems of internal control, including clear objectives, segregation of duties, and proper authorisation procedures. This includes the provision of regular fraud risk assessments to identify and evaluate potential threats posed by associated persons, which will be used to inform the design and implementation of reasonable fraud prevention procedures. These control procedures are designed to mitigate the risk of attempted/successful fraud and bribery in those areas most vulnerable to fraud and bribery risk.

3.4 The internal auditors can offer advice on process design and undertake internal audits of activity to highlight any areas of vulnerability which are felt to expose the University to a variety of risks, including fraud and bribery. It is the responsibility of internal auditors to assess the adequacy of control arrangements and to investigate or supervise the investigation of allegations of bribery or fraud. The University Secretary and the Chair of the Audit and Risk Committee (ARC) must be notified of all suspected or actual instances of fraud or bribery as soon as practicable to allow appropriate assessment, investigation, and oversight. Internal audit can advise on the most appropriate approach to investigation and reporting.

3.5 FOG is responsible for overseeing the University's fraud risk management framework. This includes the review of significant fraud and bribery risks, monitoring of fraud-related incident and investigations, consideration of themes, trends, and lessons learned, and overseeing the implementation of agreed improvement actions.

3.6 Day-to-day responsibility for the prevention and detection of fraud or bribery rests with line managers who are responsible for the implementation of policies and procedures within their area.

3.7 All staff and students have a responsibility to report any suspicions of bribery or fraud.

4.0 Policy, procedures and enforcement

4.1 The University has adopted reasonable and proportionate measures to prevent fraud, tailored to the nature, scale and complexity of its operations. These procedures are reviewed and updated periodically to ensure continued effectiveness.

4.2 The University applies risk-based due diligence to all associated persons, including employees, agents, and subsidiaries - to mitigate fraud risks; this includes vetting, monitoring, and contractual safeguards.

4.3 The University provides a mechanism to communicate fraud risks, reporting mechanisms, and roles and responsibilities for staff and associated persons under this Policy. These will be monitored by FOG to ensure they remain fit for purpose, and include consideration of fraud risk assessments, internal audit activity, analysis of reported incidents and near misses, a review of trends and emerging threats, and lessons learned. Findings will be used to improve prevention measures and ensure the ongoing suitability and effectiveness of this Policy.

4.4 The University will promote a culture of integrity by ensuring staff, students, and associated persons are aware of the risks of fraud and bribery and understand their responsibilities under this policy. Required learning must be completed by relevant staff every three years, whilst this Policy and associated reporting mechanisms will be reinforced through staff communications and management briefings. Line Managers will ensure colleagues within their areas understand and comply with the requirements of this Policy.

4.5 The University recognises that emergencies, crises, and other exceptional circumstances may increase exposure to fraud risks due to accelerated decision-making, changes in operating arrangements, emergency procurement, or urgent deployment of resource. During such circumstances, proportionate fraud prevention controls must continue to operate; where normal procedures are modified, appropriate compensating controls, enhanced review arrangements, and retrospective assurance activities must be implemented. The University will have regard to relevant good practice guidance, including that issued by the International Public Sector Fraud Forum, when managing fraud risks during emergency situations.

5.0 Equality and diversity

5.1 This policy has been designed to ensure that no-one receives less favourable treatment due to protected characteristics.

5.2 Investigations will take place without regard to position, length of service, or relationships.

6.0 Related information

6.1 This Policy is designed to comply with the requirements of the ECCTA, including the offence of failure to prevent fraud as set out in section 199-206 and schedule 13 of the Act.

6.2 The following resources should be considered when navigating this Policy:

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Approval date: 27 October 2026

Approved by: Council

Contact for further information: University Secretary’s Office

 

Appendix 1: Fraud and Bribery Investigation and Reporting Process

Incident Reporting

It is important that all individuals are able to report their concerns about any suspected incident of fraud or bribery without fear of reprisal or victimisation and are aware of the means to do so. The Public Interest Disclosure Act 1998 (the ‘Whistleblowers Act’) provides appropriate protection for those who voice genuine and legitimate concerns through the proper channels. 

Concern should normally be reported to line managers, supervisors, academic departments or college staff. Where this would be inappropriate, concerns may be reported directly to:

  • The University Secretary.
  • The Chief Financial Officer.
  • A member of the Fraud Oversight Group (FOG).

All suspected, attempted, or actual instances of fraud, bribery, theft, corruption, or financial irregularity must be reported as soon as reasonably practicable following receipt of the allegation or concern. Reportable incidents include (but are not limited to):

  • Suspected fraud.
  • Attempted fraud (including near misses).
  • Actual fraud.
  • Bribery or suspected bribery.
  • Significant financial irregularities.
  • Material control failures.

Reports should be made at the earliest opportunity and can be done openly or anonymously; individuals raising concerns in good faith will not suffer detriment or prejudice if reporting a genuine concern. Concerns may also be raised under the University's Whistleblowing Procedure, and all reports will be managed in accordance with the protections and principles set out within that procedure.

Initiating Action

Following initial discussions, where the suspicion of fraud or irregularity remains, it should be reported without delay to the University Secretary who should consult with FOG within 72 hours to decide on the initial response.

If a member of FOT is under suspicion, an alternative senior officer will be appointed to the group in their place. Similarly, FOG may ask a nominated deputy to stand in on behalf of individual members, and others may be called to assist in the investigative process where their expertise is required.

Emergencies, major incidents, crises, and exceptional operating arrangements may increase exposure to fraud risks; fraud reporting requirements will continue to apply during emergencies, and FOG may expedite investigative arrangements where circumstances require urgent action.

Investigation

FOG will determine the most appropriate course of action, which will normally include the appointment of an Investigating Officer and the issuance of clear terms of reference and guidance. Investigating Officers will be independent of the area being investigated, and must not have any actual, potential, or perceived conflict of interest in relation to the matter under review. Where these exist, an alternative Investigating Officer shall be appointed. Investigations involving senior colleagues shall normally be led by the University Secretary. The investigation will consider:

  • The nature and extent of any loss.
  • Action required to prevent further loss.
  • Recovery action.
  • The appropriateness of additional sanctions (including disciplinary action or criminal prosecution).

FOG will ensure staff co-operate with requests for assistance by the Investigating Officer and will approve the appointment of external specialists if required to assist with the investigation.

On completion of an investigation, a written report shall be submitted to the Vice-Chancellor and the Audit and Risk Committee (ARC) by the University Secretary containing:

  • A description of the incident, including the value of any loss, the people involved and the means of perpetrating the fraud.
  • Action taken against any party where the allegations were proved.
  • Actions taken to recover any loss.
  • Any recommendations and/or action taken to minimise any recurrence.
  • Any actions needed to strengthen future responses to fraud.

The University Secretary will inform the reporting individual of the outcome of the investigation. However, there may be occasions where the need for confidentiality prevents the release of specific details of the investigation or any disciplinary action taken as a result.

Following the conclusion of each investigation, FOG shall conduct a lesson's learned review, considering root causes, control weaknesses, policy or procedural deficiencies, training requirements, and other learning opportunities. FOG will monitor the implementation of agreed actions from investigation reports.

The University will follow its own internal disciplinary proceedings against any member of the University who has committed fraud. The Investigating Officer will maintain familiarity with the University’s disciplinary proceedings to ensure that evidence collected during any fraud investigation meets the appropriate requirements for disciplinary action.  

Police Referral

The University will normally pursue the prosecution against any member of the University who has committed fraud. The University Secretary, in consultation with the Investigating Officer, will decide if (and when) to inform and maintain contact with the police.  All staff will co-operate fully with any police enquiries, which may have to take precedence over any internal investigation or disciplinary proceedings. Wherever possible, teams will co-ordinate their enquiries to maximise the effective and efficient use of resources and information. Where the police are not notified of a suspected or actual fraud, ARC must be advised of the reason.

The Investigating Officer should be familiar with, and follow rules on the admissibility of documentary and other evidence in, criminal proceedings including the Police and Criminal Evidence Act (1984), the Investigatory Powers Act (2016), the Human Rights Act (1998), and the Equality Act (2010).

Prevention of Further Loss

Where the investigation provides reasonable grounds for suspecting a member of the University of fraud, FOG will consider how to prevent further loss. For staff, this may require suspension of the individual(s) in accordance with the University’s Disciplinary Regulations. It may be necessary to plan the timing of suspension(s) to prevent the destruction or removal of evidence that may be needed to support disciplinary or criminal action. The decision to suspend will be taken by the Chief People Officer, in consultation with the University Secretary or Chief Financial Officer and the Investigating Officer. Suspension should not be regarded as disciplinary action, nor should it imply guilt. In addition to actions concerning the individual(s) involved, consideration shall be given to the immediate implementation of temporary or permanent control improvements to prevent further loss and mitigate ongoing risk.

The Chief People Officer will provide advice on how any potential suspension of staff should be conducted; this may include informing the individual(s) of suspension without prior notice but the rationale and relevant arrangements (such as review periods) should be explained to them. Individual(s) being suspended should be supervised when leaving the University's premises; they should be allowed to collect personal property under supervision but should not be able to remove any property belonging to the University, unless specifically agreed with HR following consultation with the Investigating Officer. Any security passes, keys to premises, offices and furniture should be returned. Nothing within this process prevents the University from taking precautionary measures, including the suspension of staff, before the completion of the triage stage where allegations are considered sufficiently serious and/or where such action is deemed necessarily to protect staff, students, assets, evidence, or the integrity of any investigation.

The Director of Estates and Facilities can advise on the best means of denying access to University premises while the individual(s) remains suspended. The Chief Information Officer may be instructed to withdraw, without delay, access permissions to the University's IT facilities. The Director of Procurement can advise of matters relating to the conduct, actions, or activities of third parties, suppliers, contractors, consultant or other external organisations engaged by the University.

The University Secretary shall consider whether it is necessary to investigate systems other than that which has given rise to suspicion, through which the individual(s) may have had opportunities to misappropriate the University's assets.

Recovery of Losses

FOG shall ensure any losses are quantified in fraud investigations and repayment of losses should be sought in all cases.

Where losses are substantial, the University’s insurers should be notified and legal advice should be obtained without delay about the need to freeze the individual(s) assets through the courts, pending conclusion of the investigation. Legal advice should also be obtained about prospects for is not feasible, the University should consider claiming against any relevant insurance policies and would normally expect to recover costs in addition to losses.

Reporting

Upon receipt of allegations pertaining to fraud, bribery, corruption, or financial irregularity, the University Secretary will undertake an initial assessment and triage to determine whether a formal investigation is required. The purpose of the triage is to:

  • Assess the nature and credibility of the allegation.
  • Determine whether sufficient information exists to justify a formal investigation.
  • Identify any immediate risks to staff, students, assets, or reputaion.

If the threshold has been reached, an investigation should be conducted without delay, with the Investigating Officer providing regular updates to the University Secretary. Reports should include quantification of loss(es), progress with recovery action, criminal action, and disciplinary proceedings, an estimate of resources required and timescales to conclude the investigation, and actions taken to prevent and detect similar incidents.

ARC will be advised of all reports of actual or suspected fraud and the progress of investigations.

Internal Audit will be made aware of all reports of actual or suspected fraud via ARC or directly by the University Secretary if the incidents are material as detailed below.

The University Secretary shall report any incident of actual or suspected fraud to the regulator and/or other funding bodies (in accordance with their reportable incidents requirements), together with the Chair of Council, if any of the following circumstances apply:

  • The loss, theft, or fraud of charity assets or other irregularity where money involved is, or is potentially, more than £25,000.
  • A case reveals systemic weaknesses of concern beyond the institution.
  • The particulars of the fraud are novel, unusual or complex.
  • There is likely to be public interest because of the nature of fraud or the individuals involved.

Consideration should also be given to reporting obligations arising under funding agreements, research funding conditions, statutory requirements, insurance arrangements, and any other applicable reporting frameworks.

The University Secretary shall ensure that any departure from this procedure is reported and explained promptly to the Chair of ARC.

FOG will produce an annual assurance report, which will be submitted to ARC for consideration during Michaelmas term.

Further Action

Any request for a reference for a member of staff or a student who has been disciplined or prosecuted for fraud shall be referred to the Chief People Officer (staff) or the Academic Registrar (students), who shall approve any response to a request for reference.