Section 2: Compliance

Section 2: Compliance

2.01 Audit Arrangements
2.02 Conflict of Interests
2.03 Irregularities
2.04 Accounting Systems
2.05 Consultancy and Commercial Activity
2.06 Subsidiary Companies


2.01 Audit Arrangements
University Court has established an Audit Committee whose remit is to oversee the arrangements for external and internal audit of the University’s financial and management systems and of activities and processes related to these systems.

The primary role of the external audit service is to report on the University’s financial statements and to carry out such examination of the statements and underlying records and control systems as is necessary to reach an opinion on the statements and to report on the appropriate use of funds.  The external auditor’s duties will be in accordance with advice set out in the Scottish Funding Council’s Financial Memorandum and the Auditing Practices Board’s statements of auditing standards.

The primary role of the internal audit service is to provide the Audit Committee and University Court with assurances on the adequacy of the University’s internal control system. The internal auditor’s duties will be in accordance with advice set out in the Scottish Funding Council’s Financial Memorandum and they will also comply with the Auditing Practices Board’s auditing guideline Guidance for Internal Auditors.

Both the Internal and External audit services are independent in their planning and operation and have unrestricted access to all records, assets, personnel and premises as required to perform their duties.

The University may, from time to time, be subject to audit by other external agencies such as the European Court of Auditors and Her Majesty’s Revenue and Customs.  They have at least the same rights of access as external and internal auditors.

2.02 Conflict of Interests
University employees and others with responsibility for administration or management of University funds must not use their authority or office for personal gain and must always seek to uphold and enhance the standing of the University.  Any personal interest which may impinge on an employee's impartiality in any matter relevant to their duties should be declared by the employee to their Head of School, Research Institute or Administrative Service or other appropriate authority, in accordance with the University’s policy on registration and declaration of interests.

With the exception of low value items such as a gift worth less than £25 or hospitality worth less than £50, employees must seek written permission from their Head of School, Research Institute or Administrative Service before accepting gifts or hospitality from potential or existing suppliers or their agents dealing with the University.  Under no circumstances must the receipt of gifts or hospitality influence the choice of supplier. If there should be any doubt, then gifts and/or hospitality should be refused.

2.03 Irregularities
Any suspicion of theft, fraud, conflict of interests, money laundering or financial irregularity should be notified immediately to the relevant Senior Management Group Member who will inform the Secretary of Court. The Secretary of Court will advise the Director of Finance, Chair of Audit Committee and the Internal Audit service.  The University’s Security Officer and the police may also be notified as appropriate. 

The Secretary of Court is responsible for co-ordinating action where there are reasonable grounds for suspecting that a criminal offence has occurred. Therefore, Senior Management Group members should not take any subsequent action following the notification of potential irregularity without the approval of the Secretary of Court. 

Whilst an allegation against a member of staff is under investigation, the Director of Human Resources, acting on the Principal's delegated authority shall have the power, where it appears necessary and for reasons stated, to suspend that member of staff on full pay for a period not exceeding one month, or, where the matter is subject to investigation by the police, for the duration of that investigation. Any extension of this period shall require the explicit approval of the Principal, for reasons stated, for a period not exceeding one month at a time, and shall be reported to the next meeting of University Court.
 
The Public Interest Disclosure Act, which came into effect on 1 January 1999, gives legal protection to employees against being dismissed or penalised by their employers as a result of publicly disclosing certain serious concerns. The University has made provision for an employee to disclose information which they believe shows malpractice or wrongdoing within the University. The Code on Public Interest Disclosure is available from the Human Resources department website.

It should be emphasised that the Code on Public Interest Disclosure is intended to assist individuals who believe they have discovered malpractice or impropriety. It is not designed to question financial or business decisions taken by the University in the normal course of business; nor may it be used to reconsider any matters which have already been addressed under harassment, complaint or disciplinary procedures.
 

2.04 Accounting Systems
All members of staff with access to the University finance system must comply with the rules laid down by IT Services. These can be accessed at the IT Services website.

In order to access the University finance system, staff members are required to attend an appropriate training course. This can be arranged by contacting the Finance Systems Support and Development Section within the Finance Office.

All financial transactions should be properly recorded within the University's finance system either through direct input or through an appropriate interface from another University approved system platform.

Heads of School, Research Institute or Administrative Service are responsible for notifying the Finance Systems Support and Development Section of any new users or leavers. 

Where an individual’s personal data is recorded within the University’s financial system or within any other approved University system that deals with financial transactions, all staff members must ensure that working practices comply with the Data Protection Act 1998. Advice on these matters may be obtained from the Data Protection and Freedom of Information website.

2.05 Consultancy and Commercial Activity
All staff members must comply with the University’s policy on consultancy and commercial activity. The full policy is available from the Research website. 

The University is liable for the actions of its employees entering into work-related consultancy arrangements with outside agencies. The University therefore strictly prohibits staff from entering into work-related consultancy arrangements with outside agencies without approval from the relevant Senior Management Group Member and the Director of Research & Enterprise. Before approval is sought, all staff members should ensure that a risk assessment is carried out and documented. The risk assessment should identify any actions, events or sets of circumstances that could arise as a result of the consultancy or commercial activity, that could adversely impact on the University’s ability to achieve its objectives. The risk assessment should also identify how the risks can be i) avoided, ii) reduced to an acceptable level, or iii) managed and contained. Staff involved in non-work related consultancy must not use the University of Glasgow name to endorse this activity or use University premises and facilities for non-University purposes.

The Finance Office is responsible for the invoicing and cash collection of consultancy and commercial contracts and will also arrange payment to members of staff for personal consultancy in line with the University policy on consultancy and commercial activity. Schools, Research Institutes or Administrative Services must not raise invoices in respect of consultancy and commercial activity.

Payment of personal consultancy to a member of staff will only be arranged once the University has received payment from the invoiced customer. The subsequent payment to the member of staff will be net of employment taxation.

2.06 Subsidiary Companies
No University company may be set up without first obtaining approval from the Director of Finance in advance of any approval being submitted for review and recommendation by the Finance Committee before approval by University Court.