Trinity needs a mechanism that will minimise the risk of fraud and corruption occurring within the University and to optimise the prompt detection of these offences. The policy provides a mechanism for reporting suspicions or allegations of fraudulent and corrupt activities.

The Anti-Fraud and Anti-Corruption Policy applies to:

• All employees of the University (full-time, part-time and fixed term),
• All employees of Trinity’s wholly owned subsidiary companies,
• Researchers,
• Visiting staff,
• Adjunct appointments,
• Students (full-time and part-time) in their past and present interactions with Trinity,
• Members of the Trinity Board
• Contractors,
• Suppliers,
• Volunteers,
• External agents (including an external agent’s employees) who provide or provided services to Trinity through an official arrangement.

See section 3 of the Policy for further details.

Fraud includes, but is not limited to, acts that involve the inducement of a person to do or refrain from doing an act through dishonesty or other deception with the intention of making a gain for one self or another or of causing loss to another.

For practical purposes fraud involves the use of deception to obtain an advantage or attempt to obtain an advantage, avoid an obligation or cause loss to another party.

The term “fraud” is used to describe such acts of dishonesty as deception, forgery, extortion, theft (noting that theft has its own legal definition), conspiracy, embezzlement, misappropriation, false representation, concealment of material facts, false pretence, false accounting and collusion in the foregoing.

 See section 5 of the Policy.

A non-exhaustive list of the activities and behaviour which constitute fraud within the context of the activities undertaken by Trinity is as follows:

1. Theft or misappropriation of university assets.
2. Submitting false claims for payments or reimbursement.
3. Accepting or offering a bribe.
4. Accepting or offering a gift or other favour under circumstances that might lead to the inference that the gift or favour was intended to influence an employee's or external party’s decision-making in relation to the University.
5. Accepting an inappropriate commission from, or paying same, to a third party.
6. Colluding with vendors or third parties in providing preferred pricing or engaging in contract embellishment.
7. 'Off Books' accounting or making false or fictitious entries.
8. Knowingly creating and/or distributing false or misleading reports or data including financial reports or data.
9. Paying of excessive prices or fees where authorisation for or justification thereof is not justified or documented.
10. Research fraud (e.g. financial fraud or misuse of research funds or research equipment)
11. Computer fraud (e.g. “phishing” which are fraudulent emails or messages that trick users into giving up personal information by impersonating a trusted entity like a bank or a government agency)
12. Identity fraud (e.g. theft of personal information, like a name, address, or social security number, to impersonate the individual to access their accounts or commit crimes in their names)
13. Blackmail or extortion.
14. Violation of the University's procedures with the aim of personal gain or to the detriment of the University.

See section 5 of the Policy.

Corruption means the direct or indirect offering, seeking, or accepting of inducements, gifts, favours, payment or benefits in kind which may improperly influence the action of any person in relation to their office of employment, position or business. The corrupt person need not benefit directly from their deed; they may unreasonably use their position to secure or influence some advantage to another. Not reasonably taking action to prevent corruption also amounts to corruption.

See section 5 of the Policy.

In cases of suspected or alleged fraud or corruption to be dealt with under the Anti-Fraud and Anti-Corruption Policy, the Fraud Response Team is constituted and convened with the appropriate expertise normally by the Secretary to the College to follow up on a report received. The FRT will normally be chaired by the Secretary to the College and will comprise of the following members:

• College Solicitor
• Internal Auditor (in attendance)[1]
• Others as appropriate/required, e.g.
• Junior Dean (if undergraduate or postgraduate student implicated)
• Senior Dean (if employee implicated)
• Director of HR (if employee implicated)
• College Research Integrity Officer or Dean of Research (if alleged research fraud)
• Relevant Chief Officer (Chief Financial Officer or nominee, Vice-Provost/CAO or nominee, Chief Operating Officer or nominee)

Should circumstances arise such that it is inappropriate for the Secretary to the College to be involved, the Provost will nominate a Chair (such as the relevant Chief Officer, Senior Dean or Junior Dean). Where it is not appropriate for any other member to serve on the Panel, an appropriate replacement (either internal or external to the University) will be appointed by the Chair.

See section 6.1.3 of this policy for further details.

[1] The Internal Auditor will be “in attendance” on the Fraud Response Team as they will be involved in the investigation process and the presentation of the investigation report to the FRT.

A Reporting Person is a person within the scope of the policy who reports suspected or alleged fraud or corruption.

See section 5 of the Policy.

A Person Concerned is an individual who is the subject of the report of suspected or alleged fraud or corruption.

See section 5 of the Policy.

You should send a report in writing to the Secretary to the College by email to secretary.to.college@tcd.ie or by post in a sealed envelope clearly marked ‘Strictly Private and Confidential – Addressee only’ to the ‘Secretary to the College, West Chapel, Trinity College, Dublin 2’.

In certain limited circumstances it may not be appropriate to submit a report to the Secretary to the College, for example if there is a conflict of interest, and should such a circumstance arise, a report can be submitted to the Internal Auditor by email to intaudit@tcd.ie or by post marked ‘Strictly Private and Confidential – Addressee only’ to the ‘Internal Auditor, West Chapel, Trinity College, Dublin 2’.

You will be required to maintain the confidentiality of the report, including keeping the reporting, follow up and any investigation process confidential.

See section 6.1.1 of the Policy for further details.

You should without delay send a report in writing to the Secretary to the College by email to secretary.to.college@tcd.ie or by post in a sealed envelope clearly marked ‘Strictly Private and Confidential – Addressee only’ to the ‘Secretary to the College, West Chapel, Trinity College, Dublin 2’. The School should not conduct any investigation under any circumstances, must not discuss with the Person(s) Concerned (the student in this case), and must keep the matter confidential.

See section 6.1.1 of the Policy for further details.

As a Reporting Person, you should be able to support your report of suspected or alleged fraudulent or corrupt activity with factual information. The report should include specific details, to the extent that this information is known to you, as follows:

1. The Reporting Person’s name, position, and confidential contact details;
2. What fraudulent or corrupt activity has allegedly occurred;
3. When and where it allegedly occurred;
4. The name of the person(s) allegedly involved in the alleged fraud or corruption (if any name is known and the Reporting Person considers the naming of the person necessary to expose the matter disclosed);
5. Whether the alleged fraudulent or corrupt activity is still ongoing;
6. Whether it is alleged that the University has been put at risk or suffered a loss, such as a financial or reputational loss;
7. Whether the alleged fraudulent or corrupt activity happened previously;
8. Whether the alleged fraudulent or corrupt activity has been reported to anyone else either within the University or externally - if so, details of when/whom;
9. Whether there are any other witnesses;
10. Whether there is any supporting information or documentation;
11. How the matter came to light;
12. Any other relevant information.

See section 6.1.1 of the Policy for further details.

You should notify without delay the Secretary to the College and forward on the written report (if the report has been made verbally, you must notify the Secretary to the College without delay and the Reporting Person will be asked by the Secretary to the College to submit a written report). You must not act on the report, must not discuss with the Person(s) Concerned, and must keep it confidential. You should not disclose any information in the report or information that might identify the Reporting Person, Persons Concerned or third parties.

In certain limited circumstances it may not be appropriate to submit a report to the Secretary to the College, for example if there is a conflict of interest, and should such a circumstance arise, a report can be submitted to the Internal Auditor.

See section 6.1.1 of the Policy for further details.

The Secretary to the College will acknowledge receipt of the report to you in writing as soon as possible.

See section 6.1.2 of the Policy for further details.

Where there are reasonable grounds for concluding that there is evidence in the report of suspected or alleged fraud or corruption and that it should be dealt with under the Anti-Fraud and Anti-Corruption Policy, the Secretary to the College will convene the Fraud Response Team (FRT). You may be asked to attend meetings to provide additional information if required.

See section 6.1.3 of the Policy for further details.

If the initial assessment finds that fraudulent or corrupt activity may have occurred and an investigation is to be conducted, you will be informed by the Chair of the Fraud Response Team (normally the Secretary to the College) that an investigation is to be conducted, unless to do so would in any way prejudice the outcome of the investigation or undermine the right of the Person(s) Concerned to fair procedures.

See section 6.1.5 of the Policy for further details.

It is the responsibility of all Trinity employees and students to report any suspicions of fraud or corrupt activity without delay in accordance with the Anti-Fraud and Anti-Corruption Policy. Persons who intentionally cover up, obstruct, fail to report, or fail to monitor a fraud or attempted fraud that they become aware of, or ought to have been aware of, will be considered to be in breach of this policy and may be subject to disciplinary procedures and face other legal consequences.

See section 6.5 of the Policy for details.

If you believe that you are a victim of penalisation as a result of a report you have made, you should report the matter directly to the Secretary to the College whether or not the process is still open or has been concluded.

Penalisation means any direct or indirect act or omission which is prompted by the making of a report and causes or may cause unjustified detriment to a Reporting Person. (This definition is without prejudice to the statutory definition of penalisation contained in the Protected Disclosures Act 2014 (as amended), which applies specifically to protected disclosures.)

Anyone who conducts or threatens penalisation against a Reporting Person will be subject to disciplinary action.

See section 5 for definition of penalisation and section 6.4 of the Policy for details.

If you meet the criteria of “worker”¹ as defined in the Protected Disclosures (Whistleblowing) Policy and where the alleged fraudulent or corrupt activity falls within the definition of “Relevant Wrongdoing”² as defined in the Protected Disclosures (Whistleblowing) Policy, a disclosure may be made in accordance with that policy and you will be afforded the protections of the Protected Disclosures Act 2014 (as amended). 

¹ Individuals who wish to make a report under the Protected Disclosures (Whistleblowing) Policy must meet the statutory definition of a “worker” which is set out under heading (3) “Scope” in that Policy. In the context of Trinity, examples of workers include: employees, former employees, consultants, contractors (including contractors engaging in pre-contractual negotiations), trainees, persons on work experience, interns, part-time, full-time and casual workers, agency workers, members of the Board including non-executive members, job candidates (involved in a recruitment process ) and current or former volunteers. The worker must have acquired the information on relevant wrongdoings in a work-related context.

² See the definition of “Relevant Wrongdoings” under heading (5) “Definitions” in the Protected Disclosures (Whistleblowing) Policy.

See section 6.7 of the Policy.

Yes. The Secretary’s Office will be happy to provide support and to answer any questions you have. Please email secretary@tcd.ie and we will respond to your query.