Anti-Fraud Policy

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The University is committed to conducting its activities fairly, honestly and openly, in accordance with relevant legislation, and to the highest standards of integrity.  Further, the University believes that action against fraud is in the broader interests of society. As a charity deriving a significant proportion of its income from public funds, benefactions and charitable organisations, the University is concerned to protect its operations and reputation and its funders, donors, staff and students from the detriment associated with fraud and other corrupt activity.

The University has no tolerance of fraud committed by staff or associated persons, and aims to reduce instances of fraud perpetrated against the University to the absolute practical minimum.  The University will take appropriate action to prevent fraud in respect of its activities. Fraud by University employees or student members acting on behalf of the University will be treated as a serious disciplinary offence.

Staff and other associated persons who act on behalf of or provide services to the University are expected to act at all times in a manner that is fair, honest and open.  In order to conduct the activities of the University to the highest standards of integrity, in accordance with relevant legislation, and to ensure that there can be no suspicion or appearance of fraud or corruption, they are expected to abide by the following standards:

  • no member of staff or person acting on behalf of or providing services for the University shall commit any form of fraud;
  • all staff shall ensure that the Information Security Policy and other relevant guidance is followed at all times, in order to reduce the risk of fraud from unauthorised access to systems and data;
  • any suspicion of fraud or irregularity should be reported immediately through the channels defined by this Policy, and the University will consider appropriately all such reported instances.

3.1. Scope

This Policy applies to all staff and associated persons of the University. It shall be made generally available and published publicly via the University website.

This Policy has been adopted by Council and applies throughout the University apart from Oxford University Press, which has its own complementary policy and procedures for the prevention and detection of fraud. This Policy applies in full to majority and wholly-owned subsidiary companies unless separate policies have been formally approved and adopted by the Boards of those companies and endorsed by Council’s General Purposes Committee.

3.2. Definitions

Fraud is a dishonest act or omission that is made with the intent of making a gain or causing a loss (or the risk of a loss). Under the Fraud Act 2006 there are three specific offences:

  1. fraud by false representation (Section 2);
  2. fraud by failing to disclose information (Section 3);
  3. fraud by abuse of position (Section 4).

Corruption is dishonest or fraudulent conduct, typically involving bribery.

Bribery is the offering, promising, giving, requesting, or accepting of a financial or other advantage with the intention to induce or reward improper performance. (See the University’s Anti-Bribery Policy.)

Additional information about these definitions is provided on the University website.

3.3. Examples

Examples of fraud in higher education institutions include, but are not limited to:

  • Fraud involving cash or physical assets
  • Fraud involving confidential information
  • Procurement and payment fraud
  • Payroll fraud
  • Fraudulent expense claims
  • Reference and qualification fraud
  • Immigration fraud
  • Recruitment, appointment and employment fraud
  • Bribery and corruption fraud
  • Academic fraud including admissions, examinations, awards and research
  • Accommodation-related fraud, including preference and payment

3.4. Responsibilities

Every member of staff and associated person who acts on behalf of or provides services to the University is responsible for ensuring that they comply at all times with this Policy.

The Registrar is responsible for ensuring that this Policy is implemented and maintained and that appropriate explanatory guidance is provided.

Heads of Division, Heads of Department (including Faculty Board Chairs), and Heads of University Services (UAS and ASUC) are responsible for ensuring that staff within their divisions, departments or sections (as appropriate), affected students, and other associated persons are made aware of this Policy and associated explanatory guidance.

The Boards of Directors of majority and wholly owned subsidiary companies of the University are responsible for ensuring that this Policy, or an alternate policy that is approved by Council’s General Purposes Committee, is implemented and maintained within those companies, and that staff and other associated persons are made aware of the Policy and associated explanatory guidance.

The risk of fraud should also be assessed as part of the wider risk assessment and management performed by divisions, departments and committees. Information about pre-employment screening, including standard compulsory checks, is available on the Personnel Services website.

Approved by Council on 20 June 2016

A downloadable PDF version of this policy is also available here:

Contact us

For further information contact the Risk, Compliance and Assurance Team.