Financial Regulations and key policies

Financial Regulations and key policies

There are a number of key regulations and policies in place in the University underpinning financial administration and ethical decision-making. Departments are responsible for ensuring that all staff are aware of them, and all staff are responsible for ensuring that they comply with them.

Please find links to the policies and a brief overview below. If you have any queries or concerns, please contact Jane (jane.sherwood@rdm.ox.ac.uk), compliance@admin.ox.ac.uk or financial.assurance@admin.ox.ac.uk. Each policy contains details of how to report or manage issues. A list of all policies is also available.

Financial Regulations and supporting financial processes

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 finance team in the department 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 Jane (jane.sherwood@rdm.ox.ac.uk) in advance of relevant activities. If you would like advice from the Finance Division, please contact financial.assurance@admin.ox.ac.uk who will be happy to advise. 

Statement of policy and procedure on conflict of interest

In a University of the size and complexity of Oxford, conflicts of interest are bound to occur. The policy does not prevent activities taking place, but aims to facilitate activities and to protect individuals and the University from any appearance of impropriety.

A conflict of interest arises where the commitments and obligations owed by a member of staff or student to the University or to other bodies (for example a funding body) are likely to be compromised, or may appear to be compromised, by:
a) personal gain, or gain to immediate family (or a person with whom the staff or student has a close personal relationship) whether financial or otherwise; or
b) the commitments and obligations that person owes to another person or body.

Each individual is responsible for recognising situations in which they have a conflict of interest or might reasonably be seen by others to have a conflict, to declare that conflict to the appropriate person and to take such further steps as may be appropriate in line with the conflict of interest policy.

The general rule (with the exception of committee business) is that disclosure should be made in writing to the Head of Department (or equivalent) at the time the conflict first arises or it is recognised that a conflict might be perceived. Note that the duty to declare a possible conflict applies to the perception of the situation as well as the actual existence of a conflict. This is important to protect the reputation of the University and funders, as well as to avoid any consequences (e.g. financial loss) of conflicts arising.

There are a number of examples and further guidance provided on the website. For further support in the department please contact jane.sherwood@rdm.ox.ac.uk. There are two training courses available:

• Conflict of Interest: Identifying interests and making declarations aimed at staff making declarations
• Conflicts of Interest Managing Declarations and Conflicts aimed at those reviewing declarations and COI management plans

If you would like advice from the central University administration, please contact compliance@admin.ox.ac.uk who will be happy to advise.

Guidance Notes on the Holding of Outside Appointments

University academic and academic-related employees (with the exception of Associate Professors who have colleges as their main employer) are permitted to hold outside appointments and to undertake other outside activities, including consultancies, which require a commitment of time that otherwise might reasonably be expected to be devoted to University duties, subject to the approval of their direct line manager (where relevant) and their head of department or the chair of the faculty board.

The total commitment to such outside work and appointments, without any deduction from salary, must not exceed thirty days in any academic year. Applications should be submitted, as necessary throughout the year, on the OA1 form. Approval to hold outside appointments must always be obtained before work commences. This is to allow any conflict of interest issues to be resolved, the Conflict of Interest Committee updated with reports and to ensure that the department/division and individual can reach agreement on any necessary repayment of salary if the individual will exceed 30 days of outside appointments as a result of the request.

Anti-Bribery Policy

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.

Anti Bribery & Corruption: Managing the Risk training can be accessed via the link on the righthand side of the Anti-Bribery Policy page.

Anti-Fraud Policy

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, and the University will consider appropriately all such reported instances.

Gifts and hospitality Policy

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 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. 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.

Anti-Facilitation of Tax Evasion Policy

Tax evasion and the deliberate and dishonest facilitation 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 ensures 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, Jane (jane.sherwood@rdm.ox.ac.uk) before commencing these activities so that we can ensure the right arrangements are in place.

Guidance for University staff for the acceptance of donations and research funding

The University’s core objectives of teaching and research are supported to a significant extent by donations and research funding. The University is careful to ensure that funding does not impinge on academic freedom or create potential conflicts of interest (that cannot be disclosed and appropriately managed), or otherwise harm the reputation of the collegiate University. In addition to considering reputational issues and the wider interests of the University, funding is also reviewed in light of the University’s responsibilities as a charity.

There is a formal process for the acceptance of funding, which forms part of the Financial Regulations of the University.

If a donation is anticipated or you are entering discussions about donations to the University, you should, as early as possible, contact the team or individual responsible for development in their area, who will be able to assist with ensuring that the correct process is followed and unnecessary delays avoided (contacts are detailed on the website).

Research Services has a process to check research funding and departments can ask Research Services to undertake the checks (or flag potential issues) at any point in the pre-award negotiations/application phase. Undertaking checks early in the process will help avoid later delays.

Public interest disclosure (whistle-blowing) code of practice

The University places the greatest importance on the integrity of its operations, and has in place a number of policies and procedures to address problems that may arise for its employees and students, including those relating to grievance, harassment, discipline and individual allegations of fraud. Where there are genuine concerns about possible malpractices or improprieties that are not adequately covered by other University policies or procedures, staff are encouraged to make a public interest disclosure.