1. 1.1 Purpose of this document: 1.1.1 This document provides a framework for considering bribery and fraud risk within the University and assessing, in particular, whether an activity is subject to heightened exposure. Where this is the case, consideration is also given to controls that might mitigate the risk. 1.1.2 The University’s Bribery & Fraud Policy imposes the following requirements in respect of risk assessment: 4. Risk assessment 4.1 Bribery and fraud risk should be regularly assessed as a specific part of the wider risk assessment and management performed by Divisions, Departments and Committees. Significant transactions those that are of high value, or high risk, or high profile – – should always be subject to a specific bribery and fraud risk assessment. Proportionate preventative and detective controls should be identified and implemented, together with regular reviews to determine their efficacy. 4.2 Where risk assessments indicate a significant risk that bribery or fraud might occur appropriate due diligence must be conducted prior to proceeding with the relevant transaction. 4.3 The University provides specific guidance to aid the completion of risk assessments and on the conduct of appropriate due diligence into significant transactions that may be subject to heightened risk (The guidance’ referred to in paragraph 4.3 is this document.) ‘specific 1.1.3 Departments are required to assess bribery and fraud risk as set out in the Policy. Whilst use of the particular tools detailed in this document is not mandatory (since not all will be applicable for every department or situation) departments must demonstrate compliance with the Policy using either these tools or more appropriate alternatives. 1.2 Arrangement and summary of provided: 1.2.1 The following topics are addressed: (a) Defining the subject matter Risk relates to the threats or opportunities that may affect the activities undertaken by a department in seeking to achieve objectives. Activity analysis and relationship analysis are tools that help understand what a department’s key objectives, main activities and relationships are, and how they might be affected by risk. (b) Assessment and control of risk A questionnaire-based bribery and fraud risk assessment is provided to help determine where areas of increased risk might lie. This also includes suggested mitigating controls and a quick means of determining progress in addressing risk. In addition guidance is provided on that might be undertaken to due diligence assess the inherent risks of new relationships with suppliers, partners, collaborators, customers, etc.
1. 1.1 Purpose of this document: 1.1.1 This document provides a framework for considering bribery and fraud risk within the University and assessing, in particular, whether an activity is subject to heightened exposure. Where this is the case, consideration is also given to controls that might mitigate the risk. 1.1.2 The University’s Bribery & Fraud Policy imposes the following requirements in respect of risk assessment: 4. Risk assessment 4.1 Bribery and fraud risk should be regularly assessed as a specific part of the wider risk assessment and management performed by Divisions, Departments and Committees. Significant transactions – those that are of high value, or high risk, or high profile – should always be subject to a specific bribery and fraud risk assessment. Proportionate preventative and detective controls should be identified and implemented, together with regular reviews to determine their efficacy. 4.2 Where risk assessments indicate a significant risk that bribery or fraud might occur appropriate due diligence must be conducted prior to proceeding with the relevant transaction. 4.3 The University provides specific guidance to aid the completion of risk assessments and on the conduct of appropriate due diligence into significant transactions that may be subject to heightened risk (The ‘specific guidance’ referred to in paragraph 4.3 is this document.) 1.1.3 Departments are required to assess bribery and fraud risk as set out in the Policy. Whilst use of the particular tools detailed in this document is not mandatory (since not all will be applicable for every department or situation) departments must demonstrate compliance with the Policy using either these tools or more appropriate alternatives. 1.2 Arrangement and summary of provided: 1.2.1 The following topics are addressed: (a) Defining the subject matter Risk relates to the threats or opportunities that may affect the activities undertaken by a department in seeking to achieve objectives. Activity analysis and relationship analysis are tools that help understand what a department’s key objectives, main activities and relationships are, and how they might be affected by risk. (b) Assessment and control of risk A questionnaire-based bribery and fraud risk assessment is provided to help determine where areas of increased risk might lie. This also includes suggested mitigating controls and a quick means of determining progress in addressing risk. In addition guidance is provided on due diligence that might be undertaken to assess the inherent risks of new relationships with suppliers, partners, collaborators, customers, etc.
Bribery-Fraud-Risk-Awareness-Toolkit-Issue-2-130529.docx