Fraud Policy

University College London (UCL) aims to be an honest and ethical institution, seeking to conduct its business to the highest standards of integrity and objectivity. In order to protect its financial systems, resources, and assets, and the honesty and integrity of its staff, it is important that UCL has an established policy in place to minimise the risk and impact of fraudulent or corrupt activity.

This document sets out a framework for the investigation and resolution of allegations of financial irregularity made against employees of UCL. Financial irregularity is taken to include in particular (but is not limited to):

Fraud

Intentional deception with intent to make a gain or to cause a loss, or to expose another to the risk of loss. It can be perpetrated for the benefit of or the detriment to UCL, and can be committed by persons outside as well as inside UCL.

The Fraud Act 2006 provides for a general criminal offence of fraud, with three ways of committing it: by false representation (with the intention of making a gain or causing a loss or risk to another); by failing to disclose information to another person where there is a legal duty to disclose such information; and by dishonestly abusing one’s position. The Act also makes it an offence for any person, by any dishonest act, to obtain services for which payment is required, with the intent to avoid payment. 

Corruption

The offering, giving, soliciting, or acceptance of an inducement or reward which may influence the action of any person.

To protect the excellent reputation and high standards of integrity of UCL and its staff, UCL will always prosecute suspected fraudsters whenever there is sufficient evidence to support a prosecution under the Fraud Act 2006.

All staff of UCL are under a general obligation to ensure the proper use of finances, assets, and resources; in particular, if they have good reason to suspect any financial irregularity involving UCL's finances, cash, stores, property or other assets, they should report their suspicions as prescribed below.

Nonetheless, staff should bear in mind that an allegation of financial irregularity is serious and potentially defamatory, and could lead to the instigation of legal proceedings. It is in that context that this procedure contains provision for preliminary investigation of allegations, and lays stress on the principles of confidentiality.

It also seeks to ensure that no-one making an allegation of financial irregularity is victimised for having made the allegation. However where any such allegation is found to have been made with malicious, mischievous, or otherwise reckless intentions disciplinary action in accordance with UCL’s disciplinary procedures will be recommended.


1. Introduction and Objectives

2. Responsibility for the Prevention and Detection of Fraud

3. Responsibility to Report a Suspected Fraud

4. Investigation Procedures

5. Investigation Reporting Procedures

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Page last modified on 01 mar 16 12:33