Finance Governance

Financial Regulations

The Financial Regulations and supporting financial processes are established to ensure the proper use of University financial resources, satisfying requirements for accountability, internal control, and the management of financial risk, as well as fulfilling legal and financial obligations (e.g., requirements of government agencies, funders, and donors). All staff are responsible for complying with these regulations and the financial control requirements of financial processes.

The Financial Regulations are relevant to all staff even if their role is not primarily financial. For example, they cover purchasing, expense claims, and managing research funding, so anyone involved in these should ensure they are familiar with relevant processes. The Financial Regulations also set out how key authorities are delegated, for example for committing the University in contracts or committing expenditure.

The NDCN Finance Team is available to ensure that the department carries out activity in line with the Financial Regulations. So that we can best support you, please contact finance@ndcn.ox.ac.uk in advance of relevant activities.

Fraud

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). The University is committed to conducting its activities fairly, honestly and openly, in accordance with relevant legislation, and to the highest standards of integrity. 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.

Staff are expected to act at all times in a manner that is fair, honest and open and 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.

Compliance with the Anti-Fraud Policy is important to fulfil the law.

Gifts and Hospitality

Gifts and hospitality are defined as the provision or receipt of property, consumables, services, entertainment or money for which no reasonable fee is paid in return by the recipient. The University operates on a global basis in pursuit of its mission to achieve and sustain excellence in every area of its teaching and research. Integrity and fairness, both actual and perceived, are vital to its success in achieving this mission. The University's staff and representatives must act, and be seen to act, at all times in a manner that is fair, impartial and without favouritism or bias.

The Gifts and Hospitality Policy may be summarised as follows:

1. The University's staff and representatives must act, and be seen to act, at all times in a manner that is fair, impartial and without favouritism or bias.
2. Gifts and hospitality may only be accepted by University staff or representatives when:
   
   
   • the offer has been made for a proper purpose;
   • acceptance is consistent with the purposes of the University;
   • it is appropriate and its value reasonable and proportionate to the circumstances;
   • acceptance accords with all applicable University policies and governmental legislation
3. Gifts and hospitality may only be provided by University staff or representatives when:
   
   
   • the offer is consistent with the purposes of the University;
   • the purpose is not to influence improperly;
   • it is appropriate and its value reasonable and proportionate to the circumstances;
   • provision accords with all applicable University policies and governmental legislation.
4. There is a requirement to record gifts and hospitality above certain thresholds in a departmental Gifts & Hospitality Register using this Gifts & Hospitality Form. Please note there are lower thresholds with regard to public officials.
5. The University does not make political donations.

Compliance with the policy is vital in order to protect the reputation of the University and individual staff, and to also ensure compliance with the Anti-Bribery Policy.

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. The UK Bribery Act 2010 makes the giving, solicitation or receiving of bribes a criminal offence, and makes it a corporate offence for an organisation to fail to prevent bribery by an associated person (such as a member of staff or a service provider) regardless of geographical location.

The University is committed to conducting its activities fairly, honestly and openly, in accordance with relevant legislation, and to the highest standards of integrity; it has no tolerance of bribery. All staff are responsible for ensuring that they comply at all times with the Anti-Bribery Policy and guard against the commission of bribery.
Staff are expected to act at all times in a manner that is fair, impartial, and without favouritism or bias and to abide by the following standards:

• no member of staff or person acting on behalf of or providing services for the University shall seek a financial or other advantage for the University through bribery; nor shall they offer, promise, give, request, agree to receive or accept a bribe for any purpose;
• the payment or acceptance of facilitation payments is unacceptable and will not be tolerated, except where the relevant territory specifically permits such payments in its written law;
• staff and persons acting on behalf of or providing services for the University must abide by the University Policy on Gifts and Hospitality;
• any suspicion of bribery should be reported immediately through the channels defined by this Policy, and the University will consider appropriately all such reported instances.

Everyone is encouraged to review Bribery: essential reading.

Anti-Facilitation of Tax Evasion

Tax evasion, and (since 2017) the deliberate and dishonest facilitation of the commission of tax evasion by another person in the UK or overseas, are criminal offences as set out in the Criminal Finance Act. Risks arise from a number of activities and the University has a number of policies, processes and tools in place that ensure that these are addressed, including:

• Employment taxes (including the HMRC Check Employment Status for Tax (CEST) Tool to support the assessment of individual employment status and Personal Services Companies to ensure employment taxes are appropriately managed.
• Research VAT treatment including the VAT Research Tool, to support the assessment of research income, costs etc for appropriate VAT treatment.
• Collaborator VAT treatment (included in the VAT Research Tool) to support the appropriate identification of collaborative relationships versus supplier relationships to ensure correct VAT treatment.
• Donations are managed to ensure appropriate due diligence is undertaken and they are correctly accounted for.
• An International Working Arrangements Policy supports (1) staff working internationally and ensure that the risks posed by cross-border working can be mitigated; and (2) departments/faculties in making informed decisions when sending employees overseas or choosing to support employees working internationally.
• The Gifts and Hospitality policy is in place to ensure gifts given or received are identified and any tax implications dealt with.

If in doubt, contact finance@ndcn.ox.ac.uk or James.lee@ndcn.ox.ac.uk before commencing these activities so that we can ensure the right arrangements are in place.