RISK ASSESSMENT AND ADEQUATE PROCEDURES
The Internal Auditor and the University Secretary and Legal Counsel (USLC), using
guidance from the British University Finance Group, carried out a desk top review of
the organisation of the University. They concluded that the areas where bribery or
the risk of bribery was the greatest were:
1)
2)
3)
4)
5)
6)
Student Recruitment – specifically overseas agents, facilitation payments;
Registry – bribery in relation to places and awards;
Procurement – from bidders and potential bidders;
International Relations – overseas government officials, facilitation
payments;
Estates and Research Park and Planning – contractors and other suppliers;
Alumni – donations being used as bribes.
Accordingly, the Internal Auditor and the USLC held the following meetings with
those responsible for the above area of the organisation:
Date
Department
th
27 February 2012 Alumni
1st March 2012
Student Recruitment
7th March 2012
International Relations
13th March 2012
Registry
13th March 2012
Procurement
19th March 2012
Research Park Office
20th March 2012
Estates and Facilities
Responsible
Mr. Chris Gethin, Director of
Development
Mrs. Sue Webb, Deputy Director and
International Support Manager
Mrs. Lucy Thomas, Recruitment and
Marketing Manager
Professor Colin Grant, Pro ViceChancellor International Relations
Dr. David Ashton, Registrar
Mr. Nicholas Pike, Head of Admissions
Mr. Robin Hunt, Director of
Procurement
Dr. Malcolm Parry, Director of Surrey
Research Park
Professor Steve Baker, Development
Director (Surrey Research Park)
Mr. Derry Caleb, Director of Estates
and Facilities
The following documents were produced by the above individuals to reflect their
understanding of the bribery risks in their area and the procedures that are in place,
to as far as is reasonably possible, eliminate them.
ALUMNI – RISK ASSESSMENT AND ADEQUATE PROCEDURES
The University has a Donations Policy and Accounting Procedures that is followed in
all circumstance. Within this policy and as a matter of practice it provides that:
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As part of the due diligence involved in accepting a gift the University will
identify if there are any present or upcoming University Tenders that maybe
of interest to the donor. If there is a possible link no gift will be accepted or
discussed until the University has ensured there is no possible conflict of
interest.
The University will accept gifts from parents of current students but will make
it clear within the gift agreement and related communication that the gift will
in no way have any bearing or influence on how the University will treat their
child as a student.
For gifts that will be referred to Council for approval (i.e. those over £1m) the
University will engage a third party to carry out due diligence in addition to
the due diligence carried out by the University.
Where a donation is offered, the donor is asked to agree to the following statement
in the Gift Agreement.
Gift Agreement Statement
The University gratefully accepts the gift and under the terms of this agreement will
carry out the work supported and report back to the donor on progress. Both the
University and the donor recognise that as a result of this donation no preferential
treatment or influence will be granted to the donor or expected by the donor with
regard to any other aspect of the University’s business or policy making.
Mr. Chris Gethin
Director of Development
STUDENT RECRUITMENT – RISK ASSESSMENT AND ADEQUATE PROCEDURES
Student Recruitment Bribery Risks
The following points detail the Bribery related risks associated with recruitment of
students in the UK, EU and internationally, most obviously connected to the Student
Recruitment Office / International Student Office (SRO/ISO) but also applicable to
any staff involved in student recruitment activities for the University.
University of Surrey Bribery Policy circulated – All appointed educational agents
were sent the University’s Bribery Policy along with their new contracts by
December 2011, ensuring they are aware of the institution’s rules and regulations.
Minor bribery risk associated to appointment of educational agents – The selection
of educational agencies is an area where potential bribery of SRO/ISO team
members could take place, however the detailed process of a questionnaire,
interview/s, references and visit/s should ensure this risk is kept to a minimum.
Educational agency commission is low – agents representing the University of
Surrey are only paid the standard 10% of first year fees commission, with no quantity
bonuses or sliding scales.
SRO/ISO have very little offer-making powers – apart from a handful of cases each
year, the team members from the SRO/ISO do not make decisions on student
applications and offers.
Bribery risk for academics with decision-making powers – Often academics taking
part in student recruitment activities are able to make decisions on applications,
allowing a possible bribery risk of these individuals by applicants or their families.
This risk should be kept to a minimum by the University’s entry requirements for
students coming from the UK and overseas, and the processing of all applications
through the Faculty Admissions team and Registry.
No bonuses connected to student recruitment numbers – If an individual receives a
PRP (Performance Related Pay) it is in recognition of their overall annual
performance and not directly connected to the number of students recruited.
Agent hospitality and gifts minimal – Although SRO/ISO team members are often
taken for meals by agents the level of hospitality is not excessive and other
institutions are often also invited. The giving of gifts is a regular part of the role for
SRO/ISO team members, particularly from certain countries where it is culturally
expected, however gifts are normally just small tokens and the team understand not
to accept presents worth more than £25.
Minor bribery risk associated to processing of visas – The processing of visa
applications for current students or their dependants is an area where potential
bribery could take place, however the International Support team members have no
decision-making powers for visa applications and the open-plan nature of the
working environment would make any such approach difficult.
Bribery risk of facilitation payments particularly overseas – There is a risk of
officials in positions of responsibility requesting facilitation bribes from SRO/ISO
team members or other members of staff travelling overseas. This risk is managed
through ensuring all staff travelling overseas understand to avoid such situations
where possible and to only pay when in a vulnerable position, for example, if on own
at a country’s immigration border and there is no other alternative.
Mrs. Lucy Thomas
Recruitment and Marketing Manager
RESEARCH PARK & PLANNING – RISK ASSESSMENT AND ADEQUATE PROCEDURES
Planning
The Research Park Office operates in collaboration with the Estates Department of
the University to secure planning permissions. The planning process involves
discussions with the local authority to secure their views, which are to an extent
influenced by local authority policy, and from this an application is prepared and
submitted to the local authority as a formal planning application.
Applications are subject to a statutory process involving a number of statutory
consultees. Subject to their responses permission can either be granted under
delegated powers by a planning officer or be put to the full planning committee for
consideration should there be any objections to application.
This process has the fail safe of a statutory consultation process, planning officers
approving proposals against policy which is defined by the Borough and if there is
any question about an application this is referred to a formal members’ committee
for approval in an open and democratic public debate and vote.
Procurement of Buildings and Works
All of the building contracts are procured in accordance with University standing
orders and EU procurement regulations. This ensures that, at all stages of the
procurement process, i.e. identifying contractors and consultants, sending out
tender documentation, receiving tenders, opening tenders and the award of
contracts are carried out in transparent manner involving the requisite number of
personnel. We believe that our procurement methods mitigate the possibility of
accepting or giving bribes to contractors.
Lettings
The letting procedure for buildings on the Surrey Research Park always involves a
negotiation with a third party for some space which might either be an agent or a
company representative. This process involves working with the University’s
professional advisors in the form of Strutt and Parker who are well respected
professional surveying company, and close collaboration with the University’s
Finance Manager for the Foundation Fund who works in the Park Office.
If the negotiation is successful, the details of proposed rents and letting
arrangements are set out as Heads of Terms and submitted to our solicitor and
copied to both our professional advisors and to the Finance Manager prior to
completion of legal agreements. The rent levels are in reality determined by the
price charged being charged in the market for space in Guildford and the
surrounding area.
Receiving and giving bribes
It is also important to note that:
 Steve Baker as the Development Director who has been responsible for all
new build construction since 1986 has over this whole period and has dealt
with many building contracts and employed many building contractors has on
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no occasion been offered a bribe or has received any suggested of a bribe in
any way.
In the same period Malcolm Parry has neither been offered or made an offer
or given a potential or actual tenant or a planning officer, a bribe in relation
to securing planning permission or letting buildings.
We confirm that at no time during our (Parry and Baker) employment for the
University of Surrey have we given bribes either personally or on behalf of
the University.
We have never come across any suggestion from any planning officer or
councillor that they may be receptive to a bribe.
In no case would either of us (Parry and Baker) benefit financially from
bribing a Council Official or Councillor as our salaries and any performance
related payments are not in any way linked to securing planning permissions.
We have not been offered bribes or any form of inducement in order to
provide a prospective tenant at the Surrey Research Park with a lower rent
than that which should be paid.
No bribe has ever been offered or invited by a tenant in over 30 years of
letting in exchange for paying higher rent to the University, nor has there
been a request for paying a lower rent.
Professor Stephen Baker, Development Director (Surrey Research Park)
and Dr. Malcolm Parry, Director of Surrey Research Park
PROCUREMENT – RISK ASSESSMENT AND ADEQUATE PROCEDURES
Introduction
This is a summary of the checks and balances in place at the University of Surrey in
order to minimise the risk of bribery in connection with procurement activity, staff
and suppliers. This summary is post the 2012 restructure of Finance Department and
the effective date (1st April 2012) for the Purchasing Policy and Purchase Card Policy
submitted to the Executive Board on 27th March 2012.
This summary excludes building, engineering and associated professional contracts,
for which alternative checks and balances exist (see Director of Estates and Facilities
Management for details).
System/Process Checks and Balances
Procurement activity at the University is highly devolved at the lower level (below
£50,000) which means that Faculties and Departments may place Agresso purchase
orders for individual requirements that do not exceed £50,000. Aside from the
reduced risk of bribery commensurate with lower value requirements, the main
checks and balances are:

All purchase orders above £250 require approval of the budget holder.
Where the demander is also the budget holder, either a second person must
raise the requisition or a second person must approve the requisition. Self
approval of requisitions is limited to £250.

All purchase orders above £5,000 require a minimum of 3 competitive
written quotes.

All purchase orders for certain commodities, such as consultancy and IT
requirements, are routed for additional approval by the responsible support
department, whatever the value of the requisition.

A further workflow is being designed to require additional approval where an
individual demander raises a number of sub-£50,000 orders in a short space
of time whose aggregate value is above £50,000.

Deliveries against all purchase orders must be made to Central Distribution
for onward internal distribution.

Orders placed via the University Purchase Card are limited to £5,000.
Purchase Card statements must be approved by the budget holder or
someone other than the card holder.
For higher value requirements (£50,000 and above), further checks and balances
apply in addition to the above:

Requirements are routinely advertised on the University’s eTendering portal,
In-Tend (https://in-tendhost.co.uk/universityofsurrey/aspx/Home) or in the
Official Journal of the European Union (OJEU).

Formal tenders are invited, received (via In-Tend) and evaluated in a
systematic way. Detailed files are maintained of all key documents and
decisions. Such files are available for audit (and have been audited).

Reasons for key decisions (supplier selection and award) are communicated
to all bidders and advertised on In-Tend/OJEU where appropriate.

Milestone/advance payments are strictly limited and, where agreed, are
linked to deliverables/achievement which are signed off by the Project
Board/Executive where appropriate.
Reporting Checks and Balances
All University non-pay spend is allocated a commodity code in order that routine
reports can identify spend by particular commodity areas. Such routine reports also
break down spend by supplier. Reporting provides further checks and balances:

A full report of all spend by commodity/supplier is run at the end of each year
and circulated to the Value for Money (VFM) Committee. The Director of
Procurement uses this report to interrogate areas of spend that have not
been actively managed and identify any clusters of spend with suppliers that
might otherwise not attract attention.

The VFM Committee uses the full report to task the Director of Procurement
to investigate (conduct “deep dive” investigations) on particular areas of high
spend.

The Director of Procurement frequently runs reports by supplier and user for
particular commodities where the overall spend is large, diverse and/or not
actively managed.
Staff Checks and Balances
Procurement staff activity is closely monitored by the Director of Procurement who,
in turn, is monitored by the Director of Finance and the VFM Committee.
Supplier Checks and Balances
Suppliers are required to comply with University terms and conditions and
prequalification requirements that place responsibility on suppliers to comply with
the provisions of the Bribery Act 2010.
Summary
The University operates higher levels of procurement control, the higher the risk of
bribery. High degrees of transparency, reporting and monitoring also exist which
help deter bribery and allow potential areas of corrupt activity to be scrutinised.
In summary, the above represents a proportionate response to the risk of bribery in
relation to the University’s procurement activity.
Robin Hunt
Director of Procurement
INTERNATIONAL RELATIONS – RISK ASSESSMENT AND ADEQUATE PROCEDURES
Potential risk area: relationship brokerage
There is a risk that brokers of international partnerships may enjoy monopoly status.
In addition, there may be political interference. One solution is to ensure that Surrey
negotiators work as teams. A further solution, typically relevant in the process of due
diligence would be to advise potential partners in writing or verbally that all draft
agreements and discussions are ‘subject to approval and scrutiny by the University’s
legal advisers’.
Potential risk area: non-cash gifts
The presentation of such gifts is extremely widespread in international partnership
work, particularly but not exclusively in Asia. Receipt of such gifts should be declared
in appropriate logs [maintained in the Secretariat under the Ethical Conduct Code].
Where gifts appear to deviate from standard gifs (e.g. University stationery) efforts
should be made to decline. Where this is impossible, the gifts should be declared.
Where gifts need to be reciprocated these should be University branded gifts of an
appropriately reasonable value.
A gift register should also be established in the IRO.
Professor Colin Grant
Pro Vice-Chancellor (International Relations)
REGISTRY – RISK ASSESSMENT AND ADEQUATE PROCEDURES
Student admissions
There is a risk that students, or the parents or other sponsors of students will
attempt to influence admissions decisions; however the risk is low. In response, the
University operates an institution-wide Admissions Policy. All admission decisions
are made against this policy. Initial admissions decisions are scrutinised by at least a
second party. The tiering of admissions decisions is a protection against malpractice,
among other matters).
Degree classification and other academic results
There is a risk that students, or the parents or other sponsors of students, will seek
to influence degree classification or other academic results. In response, decisions
on these matters are made in committee by groups of academics. Initial decisions
are reviewed by External Examiners, who bring extra-institution oversight to
proceedings. Recommended decisions are thereafter agreed at the University level,
again by committee. The University operates formal procedures for the
management of complaint and appeal against academic decisions. These are
managed by different areas of the University to those making initial decisions and,
again, are decisions made in committee (by panel).
Dr David Ashton
Vice-President and Registrar
ESTATES AND FACILITIES – RISK ASSESSMENT AND ADEQUATE PROCEDURES
The types of activities with EFM revolve around procurement of services and capital
works. The procurement of both are covered by the University standing orders
much of which was updated many years ago to prevent fraudulent activity.
The Estate Committee is an important part of the process of evaluation and
performance management and therefore governance process. The committee has in
the past questioned the team about the apparent over use of individual contractors
and consultants. The principle which has been followed is primarily based on
multiple signatories at each stage and transparent recording and reporting. All
tenders are sealed and opened at a tender board and any anomalies are noted (see
standing orders).
The procurement of capital works follows the following paths:
Stage/ Process/ Activity
Threat and Management of Risk
Development of the brief for
capital works.
The brief will be signed off by the client and
different sections of the estate team and therefore
targeted selection of product or direction by an
individual is eliminated or drastically reduced.
Selection of design team.
Depending on value the Director of Estates and
Facilities, the Development Director and/ or the
Chairman of the Estate Committee (depending on
value) agree the design team with the Project
Manager. Over a certain value the consultancy is
tendered and may even be progressed through the
EU journal.
Selection of Contractors and
tendering of the works and
selection of equipment.
Similar to above.
The design is taken to a level where the contractor
has limited flexibility in introducing beneficial
products to either him or where it would benefit
individuals through preferential selection. At least
three members of staff would need to be involved.
The Project Manager, the QA, the Clerk of Works
and the maintenance representative.
Monitoring of the works to
ensure actual contracted
goods are installed.
The team monitor and therefore bribery to accept
substandard work would not go unnoticed and
would be challenged.
Selection of Contractors on
minor and small works and
service contracts and repairs.
This area is at higher risk than most due to the high
volume of small value activity. The selection of
favoured contractors and suppliers is the highest
risk for some form of favour to the employee.
 The department has a comprehensive,
transparent and fully integrated Works order
system that allows detailed interrogation of
small works and projects.
 Monthly reports and aggregated reports on the
placing of orders are produced by Finance
Department will indicate a high usage of a
contractor, what the project was and staff are
asked to explain this.
 The introduction of the tendered Measured
Term Contract (MTC) means that nearly all of
the small works are undertaken by one
contractor against a schedule of tendered rates
and is monitored by an external Quantity
Surveyor. Staff who work outside of this have
to demonstrate why the MTC contractor has
not been used.
Any anomaly can be tracked and monitored.
Staff bribing contractors or
consultants to receive
favours.
This is a very difficult area however the wide
involvement of staff in projects means that it would
be difficult to hide favours.
All staff are asked to let us know of any conflict of
interest where they may require building works
within their own property and are using contractors
or consultants who work for the University.
Transparency in these situations reduces risk and
reputational challenges.
Staff or close relatives
providing services to the
University
All staff must comply with the standing orders and
conflict or interest must be notified.
This is not allowed within our department unless
there are special reasons such as technical related
and single source supply and even then controls
would be put in place to prevent any favoured
treatment or benefit.
Mr Derry Caleb
Director of Estates and Facilities