Financial regulations

The following detailed procedures listed at 1 to 14 below form part of these Financial Regulations:

1. Policy for the reimbursement of travel and other expenses (for Staff and Governors)
2. Policy for the reimbursement of travel and other expenses of external Examiners/Advisors/Experts and Assessors
3. Policy for the payment of fees to external Examiners/Advisors/Experts and Assessors
4. Policy for reimbursement of candidates’ interview travel and other expenses
5. Procurement strategy
6. Procurement policy
7. Value for money strategy
8. Procurement card procedures
9. University terms and conditions for purchasing
10. Risk management policy
11. Public interest disclosure (whistle blowing) policy
12. Data protection policy
13. Declarations of interest policy
14. Anti-bribery policy

The policies at 1 to 11 can be found on our finance webpage.

The policies at 12 to 14 and further policies and guidance can be found on our policies and regulations webpage.

1. Introduction

1.1 The University of West London

1.1.1 The University of West London (the University) is a Higher Education corporation created under the provisions of the Education Reform Act 1988, as amended by the Further and Higher Education Act 1992. Its structure of governance is laid down in the Instrument and Articles of Government. The University is accountable through the Board, which has ultimate responsibility for the effectiveness of its management and administration. The Instrument of Government and the Articles of Government can be found on our Governance page.

1.1.2 The University was originally founded as the Lady Byron School in 1860. The University as it exists today was formed from the merger of Ealing College of Higher Education, Thames Valley College of Higher Education, the London College of Music and Queen Charlotte’s College of Health Care Studies. In 1991, this new entity was inaugurated as the Polytechnic of West London.

1.1.3 The University was formed in July 1992 when the Privy Council bestowed full University status and consented to the name change to Thames Valley University. With the consent of the Privy Council the name was changed in August 2010 to The University of West London.

1.1.4 The University acquired DSL in 2019 and Ruskin College in July 2021. These entities, along with the University of West London Commercial Limited, form the UWL group. These Regulations apply to all activities of the University and to its wholly owned subsidiary companies.

1.1.5 Under the provisions of the Education Reform Act 1988, the University is established as an exempt charity. This means that the University enjoys all the privileges of charitable status (including exemption from income and corporation tax on most of its activities) without being required to submit accounts to the Charity Commissioners. Consequently, the University has no charity registration number.

1.1.6 The University receives grant funding from the Office for Students (OfS) and the Education and Skills Funding Agency (ESFA) and income from contractual arrangements with UK Research and Innovation (UKRI) and the National Health Service (NHS). The University also receives significant public funding through the support provided to its students in the form of tuition fee loan through the Student Loans Company (SLC).

1.2 Purpose of the regulations

1.2.1 To conduct its business effectively, the University needs to ensure that it has sound financial management systems in place and that they are strictly adhered to. Part of this process is the establishment of Financial Regulations (the Regulations) which set out the financial policies of the University.

1.2.2 Financial Regulations provide the basis for sound financial control for the University. They are of added significance as SLC and grant funding depends up on compliance with the OfS Conditions of Registration, and the associated Public Interest Principles. This means there must be effective risk management, control, and governance arrangements in place. Financial Regulations are a core component of such a system.

1.2.3 The purpose of these Regulations is to provide effective control over the University’s resources and assets and to ensure the proper use of finance and resources for the achievement of the University’s strategic plan and business objectives by ensuring:

1. Financial viability and sustainability
2. Regularity, propriety and Value for Money (VFM)
3. Effective financial controls over the use of public funds
4. Compliance with all legal and fiscal obligations
5. The safe keeping of assets

1.2.4 These Financial Regulations have been prepared in accordance with the following requirements of the OfS Conditions of Registration, particularly those conditions with relate to financial issues as follows:

1. Condition D: Financial viability and sustainability
   • Being financially viable.
   • Being financially sustainable.
   • Having the necessary financial resources to provide and fully deliver the higher education courses as it has advertised and as it has contracted to deliver them.
   • Having the necessary financial resources to continue to comply with all conditions of its registration.
2. Condition G: Accountability for fees and funding
   • A provider in the Approved (fee cap) category must charge qualifying persons on qualifying courses fees that do not exceed the relevant fee limit determined by the provider’s quality rating and its access and participation plan.
   • The provider must comply with any terms and conditions attached to financial support received from the OfS and UK Research and Innovation (UKRI) under sections 41(1) and/or 94(2) of HERA.
   • Payment of annual registration fee and other OfS fees in accordance with regulations made by the Secretary of State.
   • Payment of fees charged by the designated bodies.

1.3 Status of the regulations

1.3.1 These Regulations were approved by the Finance Committee on 16 January 2023. They may only be amended with the prior approval of the Finance Committee which is responsible for maintaining a continuous review of these Regulations through the Chief Financial Officer. The Audit and Risk Committee has oversight and assurance of these Regulations through the internal audit process.

These Regulations are subordinate to the University’s Instrument and Articles of Government and to any restrictions contained within the OfS Regulatory Framework and the OfS Terms and Conditions of Funding.

1.3.2 These Regulations are also subject to the provisions of:

1. The Companies Acts and applicable accounting standards
2. The Charity Commission regulations
3. English law

1.4 Scope of the regulations

1.4.1 These Regulations apply to all activities of the University and to its wholly owned subsidiary companies.

1.4.2 These Regulations:

1. Assign responsibility for the management and co-ordination of financial matters within the University.
2. Form the basis of the regulatory mechanism by which the University manages its business.
3. Clarify responsibilities.
4. Provide a control framework within which staff are required to operate and within which decisions are made.

1.4.3 Procedures relating to specific areas of financial administration may be approved by the Vice-Chancellor’s Executive (VCE). These detailed financial procedures are referred to in these Regulations and should be complied with as if they are part of these Regulations. In instances where such procedures conflict with these Regulations, these Regulations will have precedence.

1.5 Compliance with the regulations

1.5.1 Observance of and compliance with the Regulations and detailed financial procedures is compulsory for all staff employed by the University and by its subsidiary companies, either employed directly or through contractual arrangements in the UK or overseas. This applies when their appointment is funded by the University directly or from grants or other funds. The Regulations must also be complied with by all contractors, consultants and governors of the University.

1.5.2 Failure to observe these Regulations and attempts to circumvent them may be grounds for disciplinary action being taken against the individual in accordance with the University’s Staff Disciplinary Procedure and Policy and possibly for the institution of criminal proceedings. View the University’s Staff Disciplinary Procedure and Policy.

1.5.3 It is the responsibility of the Chief Financial Officer to ensure that the Regulations are annually updated and published on the University’s website and that information relating to the Regulations and any amendment is effectively and efficiently communicated to staff.

1.5.4 It is the responsibility of members of the Senior Management Group to ensure that all staff under their jurisdiction are made aware of the existence and content of these Regulations. These regulations should be read in conjunction with other Institutional Policies, Procedures and Guidance.

1.5.5 Questions about the interpretation of these Regulations will be referred to the Vice-Chancellor and the Chief Financial Officer.

1.6 Legal requirements

1.6.1 For legal purposes, the full and correct name of the University is "The University of West London Higher Education Corporation".

1.6.2 Although the University has no registered office, the address for the delivery of legal documents is:

Office of the Vice-Chancellor, The University of West London, St Mary’s Road, Ealing, W5 5RF

1.6.3 Unless instructed otherwise, all formal legal documents should be marked for the attention of the University Secretary and Chief Compliance Officer.

1.6.4 The University Secretary and Chief Compliance Officer will advise on all matters relating to the use of the University's name and address.

1.7 The Board of Governors

1.7.1 The Board is responsible for ensuring the effective governance and management of the affairs of the University. The Board determines the educational character and mission of the University and sets its general strategic direction. It is also directly responsible for ensuring the financial sustainability of the University and setting the budget for expenditure. The full details of the responsibilities of the Board are set out in the University's Articles of Government which can be found on our Governance page.

1.7.2 The overall University governance structure is shown in a chart which can be found on our Governance page.

1.7.3 The University is committed to best practice in all aspects of corporate governance. The University endeavours to conduct its business in accordance with:

1. The seven ‘Nolan Principles’ of public life, as set by the Committee on Standards in Public Life (selflessness, integrity, objectivity, accountability, openness, honesty and leadership)
2. The OfS Public Interest Governance Principles
3. The CUC Code of Practice in Governance

The OfS may place conditions of the University’s registration where it considers there is a failure to address the risks of ineffective governance where public funding is put at risk. The University’s governance structures are, therefore, designed to ensure they are line with the OfS Regulatory Framework.

1.8 Delegation

1.8.1 To perform its responsibilities effectively the Board delegates specific powers and processes to Committees of the Board and to the Vice- Chancellor as Chief Executive of the University. These are set out in the Scheme of Delegation which can be found on our Governance page. The Board has also delegated responsibilities in accordance with the Articles of Government and established the following Committees of the Board of Governors.

Audit and Risk Committee:

The Audit and Risk Committee is an independent Committee of the Board responsible for the adequacy of the University’s internal control systems, advising the Board on internal and external audit matters, the adequacy and effectiveness of the University’s risk management arrangements and for forming an opinion on the University’s arrangements for promoting efficiency, economy and effectiveness to secure Value for Money (VFM) in all areas.

Finance Committee: 

The Finance Committee of the Board is responsible for monitoring and receiving financial strategies, the monitoring of the overall financial performance of the University and for advising the Board on financial matters.

The Governance and Nominations Committee:

Nominations Committee makes recommendations to the Board on governance issues, the appointment of new governors and advises the Board on the appointment of the Chair of the Board, the Vice-Chancellor and the University Secretary and Chief Compliance Officer (who also acts as Clerk to the Board).

Remuneration Committee:

The Remuneration Committee reviews the performance and determines the salaries of the Vice-Chancellor and Senior Post Holders.

Student Liaison Committee:

The Student Liaison Committee advises the Board on its statutory obligations regarding the Students’ Union, considers matters raised by student representatives and advises the Board on important student-related policy matters.

Workforce Advisory Committee   

The Workforce Advisory Committee advises the Board on all strategic issues relating to the workforce of the University. The Committee supports the University in identifying issues relating to teaching quality and the capacity, well-being, and the engagement of employees, and advises on appropriate strategies for reward, recognition, and development of a diverse workforce.

The Further Education Board

The Further Education Board ensures the strategic oversight of the University’s Apprenticeship and FE provision. The Board also acts as Trustees of Ruskin College.

The Terms of Reference and Membership for each Committee are set out on our Governance page.

1.8.2 Financial responsibilities of the Board and its committees

1.8.3 The Board is responsible for ensuring that the University has systems to assure the Board that the institution is meeting the finance related conditions of the OfS Regulatory Framework as well as the conditions of funding as set by regulatory and funding bodies and other major institutional funders which include the requirements of the OfS Terms and Conditions of Funding. These include:

1. A robust and comprehensive system of risk management, control and corporate governance.
2. Regular, reliable, timely and adequate information to monitor performance and track the use of public funds. This is to ensure that the public funds are used for proper purposes and that VFM is achieved, in line with the OfS Public Interest Principle 12, which can be found on the OfS website.
3. Effective arrangements to assure the quality of data submitted to HESA, OfS and other funding bodies. Strategic and financial plans to manage its activities to remain sustainable and financially viable. Arrangements to consider OfS’s assessment of the University’s risk status and plans to mitigate those risks.

1.8.4 The Finance Committee considers and makes recommendations to the Board on the annual estimates of income and expenditure (the budget) and tuition fees. It oversees the ongoing financial performance of the University, considers the financial accounts and approves these Financial Regulations.

1.8.5 The Audit and Risk Committee is responsible for considering issues of risk management and the control environment. It considers and makes recommendations on the annual accounts and financial statements. It is responsible for submitting an Annual Report on its activities throughout the year which, following consideration by the Board in November each year, is submitted to OfS alongside:

1. The internal auditors’ annual report which outlines the findings of each audit, gives an overall opinion on governance, management of risks, systems of internal control and VFM within the University.
2. The external auditors’ Annual Management Report which details any significant accounting and control issues arising from the audit of the Financial Statements.

1.9 Responsibilities of the Vice-Chancellor

1.9.1 The Vice-Chancellor is the Head of the University, its Chief Executive and the Accountable Officer who is responsible for the leadership of the academic affairs and executive management of the University.

1.9.2 The Vice-Chancellor is:

1. The Accountable Officer who reports to OfS on behalf of the University.
2. Personally responsible to the Board of Governors, under the OfS terms and conditions of funding, for ensuring compliance with the terms and for providing assurances to OfS to that effect.
3. Responsible for the proper and effective operation of controls for the efficient and effective management of the University’s income, expenditure, assets and liabilities.

1.9.3 Under the OfS Regulatory Framework and the Conditions of Funding the Vice-Chancellor, as Accountable Officer, is responsible for:

1. Advising the Board on the discharge of its responsibilities under OfS Regulatory Framework and jointly responsible with the Board of Governors for ensuring that responsibilities are discharged.
2. Advising the Board if, at any time, any action or policy under consideration by them appears to the Vice-Chancellor to be incompatible with the OfS Regulatory Framework or the Terms and Conditions of Funding.
3. Ensuring that funds received from OfS and other public bodies are used in accordance with the purposes for which those funds were given and in compliance with the conditions attached to them.
4. Informing the Chair of the Board, the Chair of the Audit and Risk Committee and the Chief Executive of OfS of any variance in the financial position which is material to the University’s sustainability and of any serious fraud or accounting breakdown which comes to light.
5. Ensuring that the Annual Accountability returns are submitted to OfS on time.

1.9.4 The Vice-Chancellor and/or the Chair of the Board may be required to appear before the Public Accounts Committee on matters relating to regularity, propriety or VFM relating to grants to the University, together with the Chief Executive of OfS and the Permanent Secretary and Principal Accountable Officer for the Department for Education.

1.9.5 In the long-term absence of the Vice-Chancellor, the Deputy Vice-Chancellor in consultation with the Chair of the Board will determine who shall assume the Vice-Chancellor’s responsibilities and the University Secretary and Chief Compliance Officer in their role as Clerk to the Board must ensure that OfS is made aware immediately of who is the acting Accountable Officer.

1.9.6 Senior Executives

1.9.6.1 The Officers of the University and the Senior Post Holders in addition to the Vice Chancellor are: the Deputy Vice-Chancellor, the Senior Pro Vice-Chancellor, the Pro Vice-Chancellors, the University Secretary and Chief Compliance Officer, the Chief Financial Officer, the Associate Pro Vice-Chancellor, the Chief Information Officer, the Director of Strategic Planning, the Director of Property Services and the Director of Human Resources and Organisational Development.

1.9.6.2 The Chief Financial Officer is responsible for providing strategic and commercial advice to the Vice-Chancellor, developing the University’s financial strategy including securing the necessary investment to support the University’s strategic plan, the security of the University’s assets and managing the day-to-day financial affairs of the University to deliver the Budget.

1.9.6.3 The University Secretary and Chief Compliance Officer is responsible to the Vice-Chancellor and the Chair of the Board for all legal matters, the operation of good governance and for compliance with regulatory and statutory compliance. They are also responsible for internal audit and risk management, reporting to the Audit and Risk Committee on these matters.

1.9.6.4 The Deputy Vice-Chancellor and the Pro Vice-Chancellors are responsible for the operational and strategic issues relating to their designated areas of responsibility.

1.9.6.5 The Associate Pro Vice-Chancellor and Director of Strategic Planning are responsible for ensuring the integrity of the University’s data returns to the OfS and HESA. The Director of Strategic Planning is responsible for the HEBCI return to the HESA. The Director of Human Resources and Organisational Development is responsible for staff HESA returns. The Dean of Academic Partnerships is responsible for the ESFA return.

1.9.7 Executive Committees

Vice Chancellor’s Executive

1.9.7.1 The main Executive Committee is the VCE. The VCE is responsible for the strategic planning and the academic focus of the University and for the drafting and approval of all key corporate documents, including the strategic plan and its associated strategies. The VCE is also responsible for the operational management of the University and ensures that the work of various Committees is properly co-ordinated and communicated. The VCE meets weekly and is chaired by the Vice-Chancellor. Its membership comprises the officers of the University.

1.9.7.2 The membership of VCE can be found on the Our People page. 

Senior Management Group

1.9.7.3 The wider forum for leading operational matters is the Senior Management Group (SMG). Meetings cover a mix of strategic and operational matters and serve as an important vehicle for communication, both upwards and downwards. The SMG meets monthly and is chaired by the Vice-Chancellor. Its membership comprises:

• Members of the Vice-Chancellor’s Executive
• Heads of Professional Services
• Heads of School/Colleges

Further details, including membership, can be found on the Our People page. 

1.9.7.4 The VCE is supported by the following Management Groups:

• Estates and Capital Projects Group

• IT Strategy Group

• Health, Safety and Welfare Committee

• Sustainability Management Board

• Recruitment Monitoring Group

• Vacancy Management Group

• Information Governance Group

• Prevent Group

These Committees are chaired by the Vice-Chancellor or nominee and comprise members of the VCE and other academic and professional support staff who are appointed by the Vice-Chancellor. All meetings are formally minuted.

1.10 Financial responsibilities within the University

1.10.1 Day-to-day financial administration is delegated to the Chief Financial Officer, who is responsible to the Vice-Chancellor for:

1. Developing the financial strategy and ensuring financial sustainability.
2. Financial leadership and financial control across the University.
3. Establishing the policies and controls that ensure long-term financial sustainability.
4. Ensuring that funding is available to meet day-to-day operational needs and to support the infrastructure requirements over the long term.
5. Ensuring that new borrowing arrangements meet the OfS criteria set out in the Regulatory Framework.
6. Ensuring that surplus funds are invested to give the maximum return, consistent with the Finance Committee’s requirement for minimising risk.
7. Ensuring the highest standards of stewardship, probity and accountability through robust financial processes and controls.
8. Preparing the annual Budget and financial forecasts and ensuring that satisfactory systems of financial control and financial administration are in place to deliver these.
9. Setting course fees, discounts, bursaries and waivers and maximising income, from both the public and private sectors.
10. Preparing the annual Financial Statements for the University and all its subsidiary companies.
11. Implementing strategic procurement processes to meet the needs of the University which provide VFM and are sustainable.

1.10.2 The University Secretary and Chief Compliance Officer is Clerk to the Board and is responsible for the day-to-day operation of governance, OfS regulatory matters and ensuring that appropriate procedures are followed, as well as ensuring that the University’s legal responsibilities are met, including freedom of information and data protection compliance. They are responsible for risk management and the reporting to the Audit and Risk Committee of the key risks to achieving the strategic objectives of the University.

1.10.3 Budget Holders are appointed by and responsible to the Vice-Chancellor for the financial control and management in their delegated areas of responsibility (for further details see section 2.7). They are advised by the Chief Financial Officer and supported by the finance team. They must ensure the proper use of funds in accordance with these Regulations.

1.10.4 All members of staff should be aware of these Regulations and in particular the delegations of authority and responsibility for:

1. Security of the University’s property
2. Avoidance of loss
3. The need for regularity, propriety, economy and VFM

1.10.5 All members of staff must notify the University Secretary and Chief Compliance Officer or the Chief Financial Officer immediately of any financial irregularity, or any circumstance suggesting the possibility of irregularity, affecting the financial procedures, cash or other property of the University. Confidentiality will be given to those raising such concerns. It is grounds for disciplinary action if anyone knowingly makes a false or malicious allegation. Read the Public interest disclosure policy (whistleblowing) for more information. 

1.11 Audit

1.11.1 OfS requires all Higher Education institutions to have an effective, independent internal audit function which reports to the Audit Committee and at least annually to the Board and the Accountable Officer. The University must also appoint External Auditors to review the financial accounts. The internal and external auditors are appointed by the Board on advice from the Audit and Risk Committee.

1.11.2 The internal and external auditors have unrestricted access to all records, assets, personnel and premises and are authorised to obtain such information and explanations as they consider necessary for the performance of their duties. The University may from time to time be subject to audit by OfS, the National Audit Office, His Majesty's Revenue & Customs (HMRC) and other auditors. In relation to apprenticeships and further education grants the University may also be subject to financial assurance and funding audits from the ESFA.

1.11.3 The duties of the internal and external auditor are in accordance with advice set out in the CUC Audit Committee Code of Practice, the University’s Audit Code of Practice, and the Audit & Assurance Council Statements of Auditing Standards. The University’s Audit Code of Practice may be accessed online: UWL Audit Code of Practice.

1.11.4 The external auditor will report annually, in a management letter, on any significant accounting and control issues arising from the audit.

1.11.5 The internal auditor’s duties and responsibilities must be in accordance with advice set out in the University’s Audit Code of Practice. The main responsibility of internal audit is to provide the Board via the Audit and Risk Committee with assurances on the adequacy and effectiveness of the University’s arrangements for: Risk management, control, governance, and economy, efficiency and effectiveness (VFM).

1.11.6 The annual internal audit programme proposed by the internal auditors is based on the risks identified from the University’s Strategic Risk Register. The Audit and Risk Committee agree the audit programme in consultation with the University’s internal and external auditors and the Vice-Chancellor.

1.11.7 The internal auditor also complies with the Audit & Assurance Council auditing guideline Guidance for Internal Auditors.

1.11.8 Non audit services may be commissioned from the internal or external auditor, in accordance with normal rules for procurement, subject to confirmation from the auditor that there is no conflict of interest and Audit and Risk Committee Chair approval per the University’s Audit Code of Practice.

1.11.9 The University Secretary and Chief Compliance Officer on behalf of the Board of Governors should inform the OfS of the removal or resignation of internal or external auditors.

2. Principles

2.1 Code of ethics

2.1.1 The University is committed to the highest standards of openness, integrity, and accountability. It has approved a Code of Ethics which members of the University are required to abide by at all times

2.1.2 The University seeks to conduct its affairs in a responsible manner, having regard to the following Nolan Principles of Public Life, established by the Committee on Standards in Public Life, which members of staff at all levels are expected to observe:

1. Selflessness: You should take decisions solely in terms of the public interest. You should not do so to gain financial or other material benefits for yourself, your families, or friends.
2. Integrity: You should not place yourself under any financial or other obligation to outside individuals or organisations that may influence you in the performance of your duties.
3. Objectivity: In carrying out public business, including making public appointments, awarding contracts, or recommending individuals for rewards and benefits, you should make choices on merit.
4. Accountability: You are accountable to the public for your decisions and actions and must submit yourself to whatever scrutiny is appropriate to your office.
5. Openness: You should be as open as possible about all decisions and the actions that you take. You should give reasons for their decisions and restrict information only when the wider public interest clearly demands.
6. Honesty: You have a duty to declare any private interests relating to your public duties and to take steps to resolve any conflicts arising in a way that protects the public interest.
7. Leadership: You should promote and support these principles by leadership and example.

2.1.3 Staff with responsibility for the administration and management of University’s funds must never use their office for personal gain.

2.1.4 No member of staff should authorise payment for University funds, including the claiming of expenses, to be made for the benefit of themself or to a family member.

2.1.5 Staff must declare an interest in compliance with the terms of the Declarations of interest policy if they are involved in the placing of a contract or recruitment of staff where they have an interest in the other party.

2.2 Conduct of conduct

2.2.1 It is in the interest of the University, its students and staff, that all staff maintain acceptable standards of behaviour and abide by the rules and regulations of the University. Cases of alleged misconduct or breach of University rules and regulations, including these Regulations, may be dealt with in accordance with the University’s Staff Disciplinary Procedure which can be found on the policies and regulations webpage.

2.3 Declarations of interest

2.3.1 The University Secretary and Chief Compliance Officer is responsible for maintaining a register of declarations of interest for the Board of Governors and VCE members.

2.3.2 Governors and staff are responsible for ensuring that entries in the register relating to them are kept up to date regularly and promptly. Failure to declare interests to the University Secretary and Chief Compliance Officer is a disciplinary matter.

2.3.3 Interests which must be reported to the University Secretary and Chief Compliance Officer include, but are not limited to:

• i) Employment outside the University.
• ii) Appointment of a supplier where the member of staff/Governor has both an input to the decision and a financial or personal connection with the supplier.
• iii) Acceptance of hospitality and gifts (see section 2.16).

2.3.4 Guidance on whether a matter is reportable should be sought from the University Secretary and Chief Compliance Officer. Further details can be found in the Declarations of Interest Policy on the policies and regulations webpage.

2.3.5 The boards of directors of the University's wholly owned subsidiary companies are required to adopt the University's Regulations and procedures for the declaration and registration of interests, benefits and gifts.

2.3.6 Private work undertaken by individuals must not conflict with their employment by the University. Approval must be sought from both the relevant Budget Holder and the VCE in accordance with the Declaration of Interests Policy. Individuals are expected to fully commit all of their working time to the University, as specified in their contract of employment. No non-University activities may be carried out on University premises and use University facilities or equipment.

2.3.7 Any work, either paid or unpaid, outside the University is considered a potential conflict of interest (as defined in the Declaration of Interests Policy) and must not interfere with a member of staff’s contractual obligations to the University.

2.3.8 Staff are required to notify their Head of School / Department of any employment or engagement which they intend to undertake whilst in the employment of the University (including any such employment or engagement which commenced before their employment under this contract). They must also declare it through MyView and the declaration will be considered by the VCE. They will then be notified of the University’s consent or objection to undertaking such additional activities or employment. Such consent may only be given by VCE members.

2.3.9 Employees may, on occasions, be in a position where a conflict of interest arises such as if the supplier is a friend, the supplier is related to the employee, or the employee has a financial interest in the organisation, then the employee may be perceived as having been offered present or future benefit.

2.3.10 If the employee believes that a conflict of interest is possible, they must declare that interest through MyView in accordance with the Declaration of Interests Policy. If in doubt the employee should seek guidance from the University Secretary and Chief Compliance Officer, the Chief Financial Officer or the Head of Procurement.

2.4 Theft, fraud, bribery, money laundering and irregularities

2.4.1 The University is responsible for ensuring the establishment and maintenance of systems of internal control for the prevention and detection of fraud, irregularities and corruption. Internal audits assess the adequacy of these arrangements on a regular basis and ensure that there are adequate procedures in place to prevent corrupt business practices.

2.4.2 Any person who offers, promises, or gives an advantage (bribing another person) or who requests, agrees to receive or accepts an advantage (being bribed) shall be in contravention of these Regulations and may also commit an offence under the Bribery Act 2010.

2.4.3 The University will not tolerate fraud, corruption or abuse of position for personal or institutional gain. The University is legally responsible if it fails to prevent bribery and can be automatically prosecuted for this strict liability offence. The University’s Anti-Bribery Policy supports the University’s compliance with the Bribery Act 2010 and can be found on the policies and regulations webpage.

2.4.4 The Bribery Act 2010 applies to transactions carried out by or on behalf of the University both within the UK and worldwide. There are potential criminal sanctions for individuals and entities in the event of a breach.

2.4.5 Any person who has reason to believe that a fraudulent irregularity with financial implications for the University has taken place, or is about to take place is responsible for informing the University Secretary and Chief Compliance Officer or the Chief Financial Officer, who will investigate and report on any such matter. Internal and external auditors will be informed of the occurrence of all instances of fraud or irregularity. Staff in breach of these regulations with respect to fraud, theft or irregularity will be subject to a full investigation and Disciplinary Procedures.

2.4.6 A significant theft, fraud or irregularity involving sums over £25,000 must be reported by the Vice-Chancellor to the Audit and Risk Committee.

2.4.7 A report must also be made by the Accountable Officer or the University Secretary and Chief Compliance Officer on their behalf to the OfS in accordance with the OfS requirements on reportable events.

2.4.8  It is the responsibility of the Chief Financial Officer to ensure that:

1. Staff involved with the receipt and payment of money are aware of the risks of fraud and money laundering and aware of the University’s Anti-Bribery Policy and the consequences of breach of the Bribery Act 2010.
2. Systems and processes are designed to minimise the risk of fraud and/or money laundering.
3. Action plans are in place in the event of any fraud or money laundering being identified.

2.5​​​​​​ Public interest disclosure (whistleblowing)

2.5.1 The Public Interest Disclosure Act 1998 gives legal protection to staff against being dismissed or penalised by their employers as a result of disclosing suspected malpractice, inappropriate circumstances or certain other concerns which are both serious and are likely to be of wider public interest.

2.5.2 All Higher Education institutions are required to have appropriate channels through which staff and students can make allegations about perceived irregularities in the running of the University or the activities of colleagues within the University. Provided the allegation is made lawfully, without malice and in the public interest, the position within the University of the individual making the allegation will not be jeopardised. Where an individual discovers information which they reasonably believe shows malpractice or wrongdoing within the organisation then this information should be disclosed without fear of reprisal and may be disclosed independently of line-management or other arrangements.

2.5.3 The Public Interest Disclosure (Whistleblowing) Policy is designed to allow individual staff, students, and members of the Board to raise at a high level their concerns or to disclose information which the individual believes show malpractice. This policy can be found on the policies and regulations webpage.

2.5.4 The Board has designated the University Secretary and Chief Compliance Officer in their capacity as Clerk to the Board as the person to whom a disclosure should be made in the first instance. If the disclosure relates to the University Secretary and Chief Compliance Officer, then the disclosure should be made to the Vice-Chancellor. If the disclosure implicates the University Secretary and Chief Compliance Officer and the Vice-Chancellor, the disclosure should be made to the Chair of the Audit and Risk Committee.

2.5.5 If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. If, however, an individual makes malicious or vexatious allegations, and particularly if they persist in making them, disciplinary action may be taken against the individual in question (in accordance with the relevant staff/student procedure).

2.5.6 The University may also consider taking disciplinary action if the individual is considered to have made allegations for the purposes of personal gain, has unreasonably bypassed the University’s internal procedures, or has failed to maintain confidentiality during the internal procedures.

2.6 Risk management

2.6.1 The Board acknowledges the existence of inherent risks and is committed to managing the key risks that pose a significant threat to the achievement of the strategic plan and financial health of the University. It has overall responsibility for ensuring that there is a Risk Appetite Statement and Risk Management Policy.

2.6.2 The University’s full Risk Management Policy and Risk Appetite Statement, which forms part of these Financial Regulations is set out at:

Risk Management Guidance November 2021 (.pdf, 250kb)

Risk Appetite Statement (.pdf, 315kb)

2.7 Delegations of authority

2.7.1 Certain responsibilities rest with the Board and cannot be delegated; these are set out in the Articles of Government. The University Secretary and Chief Compliance Officer is responsible for ensuring that there is a clear Scheme of Delegation where delegations have been made and that it is available to all staff. The Scheme can be found on the Governance webpage.

2.7.2 The Board delegates certain responsibilities, relevant to these Regulations, to the Finance Committee including the approval of these regulations as set out in the Finance Committee’s Terms of Reference.

2.7.3 The Board delegates responsibilities for the day-to-day management of the University to the Vice-Chancellor. In turn, the Vice-Chancellor appoints and delegates executive authority to Budget Holders to act within their approved budgets. The Vice-Chancellor also delegates the chairing of internal committees at their discretion.

2.7.4 The delegation for the commitment of University funds or resources is specific to Budget Holders and their nominated delegates.

2.7.5 The general principles applying to the arrangements for delegation are as follows:

1. Officers of the University are not permitted to exceed the authority delegated to them without the prior approval of the Board.
2. Budget Holders may delegate financial responsibilities and approvals to specific members of staff with the agreement of the Chief Financial Officer to enable the practical operation of day to day activities. The Budget Holder will ensure that a written record setting out the name of the nominee and the limits of the authority delegated to them is made and a copy provided to the Chief Financial Officer.
3. Where neither the designated officer nor a named nominee is available to give their approval, authorisation must be given by a designated officer at a higher level.
4. In determining the authorisation process that will be required for a transaction, the total (gross) value of the transaction in sterling must be used.
5. The limits of authority (see paragraph 2.7.10) are expressed in Sterling. Where an agreement requiring authorisation is expressed in a foreign currency, for the purposes of authorisation, the total value in sterling should be calculated using the exchange rate which applies on the day on which the authorisation is given.

2.7.6 The Chief Financial Officer maintains a formal list of all Budget Holders who are delegated to commit resources of the University and their nominated alternates. Only those on this list have the authority to approve commitments, either by signing or electronic approval. Under no circumstances are electronic passwords to be shared to enable other staff to make approvals.

2.7.7 Contracts, which are formal agreements to purchase goods, services, works, consultancy, or external income generating activities over a designated period, subject to specific terms and conditions, can only be signed on behalf of the University by the University Secretary and Chief Compliance Officer or other University officers or governors as set out in the Scheme of Delegation.

2.7.8 There is no delegation by the Board for the approval of establishing companies or for investment in shares apart from investments in shares for companies established as part of the Westmont Enterprise Hub.

2.7.9 Failure to observe these strict lines of delegation may result in disciplinary action in accordance with the University’s Staff Disciplinary Policy and Procedure which can be found on the policies and regulations webpage.

2.7.10 Further details, including the thresholds for limits of approval, are set out in the Scheme of Delegation which can be found on the Governance webpage.

2.8 Signing of contracts and use of the University seal

2.8.1 Contracts which use the University’s standard terms and conditions may be signed by the responsible party (for example, contracts for room hire which are let under standard terms and conditions previously agreed with the Legal Department). If in doubt, please consult the Head of Legal.

2.8.2 It is essential that the University Procurement Policy is followed when committing any funds. Procurement procedures must be followed by all staff and any departure from these rules will result in disciplinary action. It is the responsibility of all Budget Holders to draw this to the attention of all staff likely to become involved with the procurement of goods or services.

2.8.3 All contracts signed for or on behalf of the University must be signed by the University Secretary and Chief Compliance Officer and a register kept. In the absence of the University Secretary and Chief Compliance Officer contracts may be signed by the Vice-Chancellor, Deputy-Vice Chancellor or the Chief Financial Officer as set out in the Scheme of Delegation. A copy of all signed contracts must be kept for the period required by the Records Retention Policy.

2.8.4 The application of the seal of the University shall be authenticated by two signatures as set out in the Scheme of Delegation.

2.8.5 The Board has authorised the Vice-Chancellor and the University Secretary and Chief Compliance Officer to authenticate the application of the seal of the University.

2.8.6 The University Secretary and Chief Compliance Officer will be responsible for making appropriate arrangements for the safe keeping of the seal.

2.9 Status of Schools and professional service departments

2.9.1 Areas within the University, for example Schools and professional service departments, are not recognised as having a legal status which is independent of the University. Consequently, the University's full legal name must appear on any document through which Schools and central service departments seek to establish a contractual relationship between the University and another party.

2.10 Negotiations and the creation of legal relations

2.10.1 Members of staff conducting negotiations on behalf of the University may do so only within the limits of the authority devolved to them under these Regulations. They must ensure that such negotiations, written or verbal, do not create a contractual relationship between the University and another party in advance of the issue by the University of an official purchase order or the formulation and signature of a formal contract. Use of the term ‘Subject to Contract’ is recommended in correspondence containing contractual negotiations in order to avoid the unintentional formation of contracts.

2.11 Guarantees and indemnities

2.11.1 The University will not give any guarantees or indemnities incurring contingent liabilities other than those in the normal course of business.

2.11.2 Employees of the University must not sign any disclaimer, form of indemnity or guarantee or other document which transfers legal liability onto the University (except where these are contained in the University’s standard terms and conditions). Any such document must be signed by the University Secretary and Chief Compliance Officer or as otherwise specified in the Scheme of Delegation.

2.11.3 All members of the University must consult with the University Secretary and Chief Compliance Officer concerning the terms of any guarantee or indemnity which the University has been requested to give.

2.11.4 Approval for any guarantee or indemnity will only be given once a risk assessment has been carried out. Approval will only be given by the Vice-Chancellor or the Chief Financial Officer, with a report being made to the Finance Committee at the earliest opportunity.

2.11.5 The Chief Financial Officer maintains a record of all guarantees and indemnities given by the University included within the contract register.

2.12 Academic partnership agreements

2.12.1 For the purposes of these regulations an ‘Academic Partnerships Agreement’ is deemed to be either:

1. A validation agreement where the University recognises a course by another institution (who has the contractual relationship with the student) to lead to a University award or academic credit.
2. A subcontract agreement is where the University has approved a third-party organisation to deliver a course on the University's behalf leading to a university award.

2.12.2 Where the status of a proposed agreement is unclear, advice must be sought from the University Secretary and Chief Compliance Officer.

2.12.3 The terms and conditions of business and the financial implications of these and the academic partnership agreements to which they are to apply will be approved by the VCE.

2.12.4 All academic agreements shall specify the University's regulations and procedures with which the delivering organisation subject of the agreement will be required to comply.

2.12.5 Approval/signature for all academic agreements (including `Memoranda of Agreement') will be by the University Secretary and Chief Compliance Officer or as otherwise specified in the Scheme of Delegation.

2.12.6 All academic partnership agreements must be lodged with the University Secretary and Chief Compliance Officer.

2.13​​ External legal services

2.13.1​​ The appointment of external legal advisers is made in compliance with Public Sector regulations.

2.13.2 The University’s external legal advisers will only be instructed by the University Secretary and Chief Compliance Officer, the University’s Head of Legal, the University’s Data Protection Officer, the Chief Financial Officer, the Director of Property Services, the Director of Human Resources and Organisational Development and their specific nominees.

2.13.3 Any legal documents which must be signed to initiate proceedings in Courts or Tribunals (other than those covered under section 6.2.5 of this document relating to credit control) must be authorised by the University Secretary and Chief Compliance Officer.

2.14 Approval of the terms and conditions of business to apply to contracts and agreements

2.14.1 The terms and conditions of business of the University and its wholly- owned subsidiary companies must take account of the University's Regulations, current legislation and the requirements of the University's insurers and will ensure that no term or condition is overly onerous to the University or its wholly owned subsidiary companies or unacceptable to University management.

2.14.2 The financial implications of all such terms and conditions and of the contracts or agreements to which they are to apply will be assessed by the Chief Financial Officer.

2.14.3 The Chief Financial Officer is responsible for ensuring that the University’s terms and conditions for purchasing are robustly prepared and available to all staff, suppliers and potential suppliers. The terms and conditions for purchasing are set out on the University’s website on the Finance and Insurance page.

2.15 Confidentiality, data protection and information security

2.15.1 All financial and commercial information and records of the University are confidential and must not be disclosed to anyone who is not authorised to have access to them.

2.15.2 The University Secretary and Chief Compliance Officer is the University’s Freedom of Information Officer and any request for information under the Freedom of Information Act must be referred to them immediately upon receipt for the required timescales for response to be met.

2.15.3 All staff must ensure that any financial or other information which they hold, either manually or on computer, is kept secure and that access to it is controlled in accordance with the relevant requirements of GDPR and the Data Protection Act (2018) and in accordance with the University’s Data Protection Policy. The University Secretary and Chief Compliance Officer is the Data Protection Officer for the University.

2.15.4 All confidential information and personal data must be kept securely in accordance with the Information Security Policy. Under this policy, staff must observe the appropriate technical and security measures. Under no circumstances should passwords for computer access or approval be shared. It is the responsibility of the staff member to keep these confidential.

2.15.5 The University’s Data Protection and Information Security Policies can be found on the policies and regulations webpage.

2.16 Gifts, donations and hospitality

2.16.1 The offer of a gift, favour or hospitality from whatever source (contractors, suppliers service providers, students and others) is to be treated with extreme caution to protect:

1. The reputation of the University; and
2.  Staff and Governors personally

Even if offered and accepted in good faith, others may misunderstand the intention behind the gift, favour or hospitality which may lead to questions of impropriety and/or conflict of interest.

2.16.2 Governors and staff are personally responsible for ensuring that they conduct themselves with integrity, impartiality and honesty at all times to ensure that their conduct does not create suspicion of any conflict of interest between official duty and private interest.

2.16.3 Staff acting in an official capacity who have regular contact with other organisations where such offers form part of normal business practice and/or are involved in negotiating contracts are particularly vulnerable as refusal can cause misunderstanding or offence.

2.16.4 In determining what to do in each situation the following principles should be followed:

1. A small gift which carries no risk of damage to public confidence in the University with an estimated value of under £30 may be accepted.
2. The Head of School or Director of the department must approve a gift is estimated at costing more than £30 and less than £50.
3. The University Secretary and Chief Compliance Officer must approve and sign off gifts of over £50.
4. All gifts over £30 should be reported and approved through the MyView system.
5. If in any doubt err on the side of caution and if necessary, individuals should seek advice from their line manager, the University Secretary and Chief Compliance Officer or the Chief Financial Officer.
6. Staff must not give the impression to any member of the public, to any organisation with whom they deal or to their colleagues, that they have been, or may have been, influenced by a benefit to show favour or disfavour to any person or organisation.
7. If an unsolicited gift of a substantial nature is received from a contractor, it should be immediately returned to them with a polite explanation that the University's rules do not allow their acceptance.
8. Offers of hospitality exceeding conventional hospitality (for instance attending, in an official capacity, a social event organised by another body for promotional or influential purpose) should be declined. The following forms of hospitality should be avoided:
   1. Inducements that could lead to the signing of a contract between the University and a supplier, contractor or consultant.
   2. Substantial offers of social functions, travel or accommodation.
   3. Repeated acceptance of meals, tickets and invitations to sporting, cultural or social events, particularly from the same source.
   4. Significant hospitality offered in substitution for fees for broadcasts, speeches, lectures or other work done.

2.16.5 Occasionally, exceptional circumstances arise where there may be a case for an individual to accept the gift or favour on behalf of the University. In such circumstances the University Secretary and Chief Compliance Officer will make the final decision on the advisability of accepting or refusing such gifts or favours. Such gifts or favours should remain the property of the University and be used wherever possible to support the work of the University.

2.16.6 In exceptional circumstances, the University Secretary and Chief Compliance Officer may determine that it is not possible to use a gift or favour to support the University's work. In such instances retention of the gift may be authorised by the Vice-Chancellor, or, in the case of the Vice-Chancellor, by the Chair of the Board of Governors. If retention of the gift is authorised t he recipient may be asked to make a cash bequest to the University. Alternatively, the University Secretary and Chief Compliance Officer may arrange for the gift to be presented to a local charity. Whatever the outcome the central register on MyView must record what happened to the gift or favour.

2.16.7 To protect individual members of staff and avoid accusations of conflict or impropriety, the University Secretary and Chief Compliance Officer will keep a central register of gifts, favours including donations and hospitality through MyView, as well as record of instances regarded as exceptional. In addition, the Chief Financial Officer is responsible for maintaining financial records in respect of gifts and donations made to the University and starting claims for recovery of tax where appropriate.

2.16.8 The payment of a donation or gift to any charity or other worthy cause by the University is not normally acceptable and such payments require the approval of the Vice-Chancellor.

2.16.9 The University may take disciplinary and/or other appropriate action against any member of staff who accepts any benefit as an inducement or reward that leads them in an official capacity to:

1. Take any action, or not to take action.
2. Show favour, or disfavour, to anyone.

2.17 Philanthropic income and fundraising

2.17.1 All fund-raising initiatives on behalf of the University are the responsibility of the Director/Head of the Office of Development and Alumni Relations (ODAR).

2.17.2 ODAR is responsible for:

1. The submission and coordination of all proposals for philanthropic gifts to individuals and organisations.
2. The prompt banking, receipt and stewardship of all gifts, including gifts in kind to the University.
3. All gifts, including legacies, will be administered (where reasonably practicable) in accordance with the wishes of the donor or their delegated representative.

2.17.3 Staff must inform the Development and Alumni Department about any discussions with potential donors or commercial supporters before a proposal to a donor is made to ensure it is in accordance with the University’s Donations Acceptance Policy.

2.18 Usage of IT resources

2.18.1 All staff must ensure that IT resources provided by the University, including services, networks and equipment, are used in accordance with the University Information Security (including Acceptable Use) policy:

Staff must not undertake activities that are:

• Intended to cause harm or distress
• Illegal or unlawful
• In violation of university policies, or those of third parties whose services the University offers
• Take up excessive resources
• Jeopardise the integrity or security of UWL services, networks or equipment
• Intended for personal gain or to compete with the Universities business

2.18.2 Monitoring arrangements operate routinely with the express aim of monitoring compliance and in accordance with the law.

2.18.3 Allegations of misuse of the Acceptable Use of Information Assets policy will be investigated and dealt with in accordance with the University’s disciplinary procedures.

2.18.4 Use of University equipment and systems for personal use must be kept to minimum, reasonable levels.

2.19​​​​​​​ Environmental sustainability

2.19.1 Members of the VCE will take decisions having regard to the University’s long-term environmental sustainability. Decisions will be taken after having considered the appropriate/relevant issues from the following areas:

1. Embedding environmental sustainability in the curriculum
2. Further developing strategies for recycling, energy saving and energy efficient buildings
3. Enhancing the existing Green Transport activities
4. Gaining Fair Trade status
5. Increasing sustainability criteria in Procurement
6. Reducing the use of paper and other resources
7. Ensuring that all opportunities for recycling are taken
8. Considering life-cycle costs of capital acquisitions

2.19.2 Members of staff are expected to act reasonably in their day-to-day activities in terms of saving energy costs, saving paper etc. The wilful misuse and/or wastage of resources may be regarded as a disciplinary matter in accordance with the University’s Staff Disciplinary Policy and Procedure which can be found on the policies and regulations webpage.

2.19.3​​​​​​​ The Chief Financial Officer is responsible for ensuring that the University has a sustainable procurement policy. The sustainable procurement policy is set out on the University’s website on the Finance and Insurance page.​​​​​​​

3. Accounting arrangements

3.1 Financial year

3.1.1 The University’s financial year runs from 1 August until 31 July the following year. There are 12 accounting periods based on calendar month ends.

3.2 Basis of accounting

3.2.1 The Financial Statements are prepared under the historical cost convention and in accordance with the Statement of Recommended Practice (SORP) on Accounting in Further and Higher Education Published by Universities UK and the accounts direction published each year as a circular letter by OfS.

3.2.2 Financial Statements of the University are prepared to comply with:

1. UK Generally Accepted Accounting Practice (UK GAAP).
2. The Statement of Recommended Practice on Accounting in Further and Higher Education.
3. Applicable accounting standards.
4. Best practice.

3.3 Accounting records

3.3.1 The Chief Financial Officer is responsible for the retention of financial documents. The University is required by law to retain the following prime documents (in paper or electronic form, as appropriate) for six years:

1. Copy purchase orders
2. Paid purchase invoices
3.  Copy sales invoices
4. Bank statements
5.  Payroll records
6. Tender opening forms
7.  Tenders
8. Contracts

3.3.2 Retaining copies of items (i) to (viii) above is the responsibility of the Chief Financial Officer and retaining copies of contracts is the responsibility of the University Secretary and Chief Compliance Officer.

3.3.3 In accordance with all current statutory requirements and with the University’s Records Retention Policy available on the policies and regulations page, the Chief Financial Officer ensures that there are appropriate arrangements for the retention and back-up of all financial electronic records.

3.3.4 Members of staff are responsible for ensuring that retention arrangements comply with any specific requirements of funding organisations and the University’s Data Protection Policy which can be found on the policies and regulations page.

3.3.5 Additionally, for auditing and other purposes, other financial documents should be retained for three years or as determined by the funder.

3.3.6 It is the responsibility of the Chief Financial Officer to ensure that copies of the University’s Financial Statements are available on the University’s website. These can be found on the finance and insurance page.

3.3.7 It is the policy of the Finance Department to use electronic records and electronic data transfer whenever possible and to minimise the use of paper records and paper-based processes.

4. Financial control

4.1 Budgetary control and reporting

4.1.1 The Board approves the annual estimates of income and expenditure (the Budget) and may not delegate this responsibility.

4.1.2 The Vice-Chancellor and the Chief Financial Officer are responsible for preparing the Budget for consideration by the Finance Committee and the Board and for the management of Budget and resources, within the limits approved by the Board.

4.1.3 The Chief Financial Officer is operationally responsible for implementing systems and processes to enable effective budgetary control as well as the preparation of monthly management accounts and forecasts.

4.1.4 To encourage an enterprise culture and incentivise Budget Holders, the Vice Chancellor has discretion to allow the retention of a budget surplus as a result of such activity by teaching departments and professional service departments.

4.1.5 The Chief Financial Officer produces:

1. A monthly flash report on year-to-date income and expenditure no later than five working days after the close of the previous accounting period
2. Monthly management accounts which report the year-to-date revenue position and the full year forecast no later than ten working days after the close of the previous accounting period.

4.1.6 The monthly management accounts are presented to the VCE and the Senior Management Group. The Finance Committee review the most recent management accounts at each meeting and may request additional reports as required.

4.1.7 The Vice-Chancellor as Accountable Officer is responsible for informing the following of any material adverse change in the financial position of the University, significant fraud or major accounting breakdown:

1. The Chair of the Audit and Risk Committee
2. The Chair of the Board
3. The internal auditor
4. The external auditor
5. The Chief Executive of OfS.

4.2 Preparation and approval of the budget

4.2.1 The Board will annually consider and approve a Budget such that the total expenditure does not exceed the total income, and which protects the financial sustainability of the University.

 4.2.2 The Chief Financial Officer is responsible for preparing each year an annual revenue Budget for the following year for consideration by the Finance Committee before submission to the Board. The Budget, once agreed by the Vice- Chancellor, is presented to the Finance Committee and then the Board for approval before 31 July.

4.2.3 The Chief Financial Officer must ensure that the University Budget is supported by detailed School and professional service department budgets which can be delivered by the Budget Holder.

4.2.4 Each year, as part of its strategic planning process and OfS reporting requirements, the University prepares a long-term financial plan and financial forecasts covering the current and subsequent four financial years. The Chief Financial Officer is responsible for preparation of the plan. The plan, once agreed by the Vice-Chancellor, is presented to the Finance Committee for consideration and recommendation to the Board for approval.

4.3 Preparation and approval of School and professional service department budgets

4.3.1 The Vice-Chancellor is responsible for the management of all School and professional service department budgets and resources. Budget Holders are appointed by the Vice-Chancellor as appropriate for the effective operation of the University on the advice of the Chief Financial Officer.

4.3.2 The control of income and expenditure within an approved School or professional service department budget is the responsibility of the designated Budget Holder. This responsibility includes:

1. The efficient and effective allocation and use of resources.
2. The monitoring of expenditure and income against budget.
3. Managing within the budgetary resources allocated to them.
4. The implementation of course costing to cover all existing courses and proposals for new courses.
5. Forewarning the Chief Financial Officer immediately of any financial problems with the budgets under their control.

4.3.3 Once the School and professional service department budgets for the year have been approved, they may be amended by senior members of the Finance Department. The only exception relates to transfers of expenditure and income between School and professional service department budgets and such transfers require the approval of the Chief Financial Officer.

4.3.4 Unspent revenue budgets cannot be carried forward to the following year.

4.3.5 Each Budget Holder is responsible for managing their designated budgets.

4.3.6 Expenditure by Schools, Colleges and professional service departments over budget not matched by increases in income or reductions in income not matched by expenditure reductions require the approval of the Chief Financial Officer and the Vice-Chancellor. Under achievement of surplus/deficit by Budget Holders that cannot be matched by overachievement elsewhere will deteriorate the University’s overall position and Budget Holders may be required to explain the position to the Finance Committee or the Board. If a School or professional service department budget is at risk of over-spending the Vice-Chancellor may withdraw responsibility for the budget from the Budget Holder.

4.3.7 The Budget Holders meet formally at least monthly with their Finance Manager to review:

1. Financial performance to date
2. Estimated financial performance for the rest of the year

4.3.8 If a revenue budget is forecast to be overspent and the Budget Holder is not taking steps to bring that Budget back in line, then the budget responsibility will be taken by the Chief Financial Officer.

4.3.9 Once School and professional service department budgets have been approved, Budget Holders may commit resources of the University against budgets, in accordance with these Regulations and within the delegations for expenditure set out the Scheme of Delegation Policy and the Procurement Policy:

• Scheme of Delegation
• Procurement Policy

4.4 Capital budgets (including property transactions)

4.4.1 The capital programme includes all expenditure on land and buildings, equipment, IT systems and infrastructure, furniture and associated costs whether funded by capital grants or by the University.

4.4.2 To provide a formal approach to the overall approval, direction and management of the University’s major capital project programmes and reduce the risk to the University, the Estates Capital Project Group meets monthly. The Group, which is chaired by the Vice-Chancellor, reviews progress against milestones on all capital programmes and reviews the expenditure against Budgets.

4.4.3 A Steering Group is formed for all significant projects to reduce risk by ensuring the project is coordinated across the University.

4.4.4 The Chief Financial Officer will draw up a capital budget annually. The proposed capital programme will identify known and likely projects for the next year and will be consistent with the University's strategic plan and its Estates Strategy.

1. The total expenditure on capital programmes is approved by the Board when approving the revenue Budget.
2. The allocation of the budget between projects is approved by Estates and Capital Projects Group which will request business cases as appropriate to support decision making.
3. In the case of transactions (including acquisitions or disposals) involving gross sums in excess of £1.0m the Chief Financial Officer and the Director of Property Services present a full investment appraisal to the Finance Committee.
4. At the conclusion of such projects the Chief Financial Officer submits to the Finance Committee a report giving full information on the outcome of the project.

4.4.5 The Chief Financial Officer will, in the preparation of the revenue Budget, take account of the implications of capital expenditure (for example any new or increased maintenance and running costs resulting from a project and related depreciation).

4.4.6 Once approved, Budget Holders may commit expenditure against these budgets in accordance with the University’s Delegation of Authority for expenditure on goods, services and works set out in the Scheme of Delegation and the Procurement Policy which can be found at:

• Scheme of Delegation
• Procurement Policy

4.4.7 All capital expenditure is monitored by the Chief Financial Officer.

4.4.8 All budgets for IT and associated expenditure are held and managed centrally by the Chief Information Officer. The Chief Information Officer will allocate expenditure according to priorities after consultation with the Vice-Chancellor and the IT Strategy Group.

4.4.9 No IT equipment, software or associated services may be procured without approval from the Chief Information Officer.

4.4.10 All budgets for the maintenance and upgrading of the Estate, including works to classrooms and studios required by Schools and Colleges, are held and managed centrally by the Director of Property Services. The Director of Property Services will allocate expenditure according to priorities after consultation with the Vice-Chancellor.

4.4.11 Unspent capital budgets can be carried forward with the approval of the Chief Financial Officer; this prevents potentially wasteful expenditure prior to yearend and permits strategic procurement, particularly in the case of large projects.

4.4.12 Following completion of a capital project a final report is submitted to the Estates Capital Project Group, covering actual compared with budgeted expenditure.

4.5 Research and enterprise activities

4.5.1 Research and enterprise income refers to the income the University receives outside the OfS income, SLC income (non-partner related) and student fees. Research and enterprise activity has a wide definition and will include work for commercial organisations as well as work where the University is able to charge a fee for a discrete piece of work funded by the University’s Funding Bodies or the EU.

4.5.2 Under the Terms and Conditions of funding with OfS, the University should aim to recover the full cost of its activities.

4.5.3 Research and enterprise activity is expected to produce a significant contribution to the University’s surplus, after allowing for the full cost of overheads, including professional service allocations.

4.5.4 All proposals for new research and enterprise activities must be fully costed and require the approval of the Chief Financial Officer.

4.5.5 The Finance Department will support the preparation of the costings and provide staff costs and central allocation costs.

4.5.6 Contracts must always be put in place for external income generating activities, between the third party and the University or wholly owned subsidiary, if appropriate. Such contracts must be put in place in advance of the commencement/delivery of such activity. The contracts are signed on behalf of the University by the University Secretary and Chief Compliance Officer and as per the Scheme of Delegation. A register of all contracts is maintained.

4.5.7 When new income-generating activity is set up, the Chief Financial Officer must be consulted to consider whether:

1. The activity is financially viable.
2. The activity constitutes trading which might be subject to Corporation Tax and, therefore, should be conducted through a University subsidiary.

4.6 Research income

4.6.1 Where applications are to be made to outside bodies for support for research projects or where contracts are to be undertaken on behalf of such bodies, it is the responsibility of the Budget Holder to ensure that the financial and resource implications have been fully reviewed and approved per the UWL Research Bids Authorisation Process.

4.6.2 The Budget Holder must ensure that the full economic cost of such research activity is established via discussions with the relevant Finance Manager and the Research Department in accordance with OfS Guidelines (G2).

4.6.3 Any IT bids or purchases as part of research income must be approved by the CIO.

4.7 Grant and contract conditions

4.7.1 Many grant-awarding bodies and contracting organisations stipulate conditions under which their funding is given. A breach of such terms and conditions in relation to UKRI and OfS grants will be a breach of the OfS Conditions of Registration (G2). In addition, there are often procedures to be followed regarding the submission of interim or final reports or the provision of other relevant information. Failure to respond to these conditions may mean that the University will suffer a financial penalty. It is the responsibility of the Budget Holder to ensure that such conditions are met and any loss which does arise will be charged to the Budget Holder’s department.

5. Treasury management

5.1 Policy

5.1.1 Treasury management comprises the management of all cash, money market investments and borrowings in connection with the cash and funding resources of the University and the control of associated risk.

5.1.2 All treasury management involves risk and potential reward. The objective is to maximise earnings from investments commensurate with the mitigation of risk and the maintenance of security. For borrowings, the objective is to minimise cost while maintaining the stability of the University’s position by sound debt management techniques. In both instances, the overriding principles are to avoid risk and to maximise return.

5.2 Investment management

5.2.1 The Finance Committee approves the Investment Policy which prescribes investment periods, investment limits per counterparty and credit rating thresholds.

5.2.2 The Chief Financial Officer is responsible for compliance with the Investment Policy by monitoring the credit ratings of approved counterparties, advising the Finance Committee and the Audit and Risk Committees of investment opportunities and perceived investment risks and advising any requirements to revise credit rating limits.

5.2.3 The University is committed to invest its surplus cash funds on a responsible basis. The University’s Investment Policy is guided by ethical values and the need to manage Environmental, Social and Governance (ESG) risks in achieving this objective. The University will not invest in organisations who primarily demonstrate:

• Institutional violations of human rights, including the exploitation of the workforce and use of child labour
• Discriminatory practices
• Explicit environmental damage
• Bribery and corruption

5.2.4 The University will only invest in institutions which have an appropriate Standards and Poor’s (S&P) rating as outlined in the Investment Policy.

5.2.5 The University Investment Policy can be found on the policies and regulations page.

5.3 Debt management and borrowing

5.3.1 The Chief Financial Officer is responsible for ensuring that borrowing proposals put to the Finance Committee are at competitive rates and offer appropriate flexibility, both for the long-term needs and day-today shortfalls.

5.3.2 Prior to entering any borrowing or investment transaction, it is the responsibility of the Chief Financial Officer to be satisfied (by reference to the University’s external legal advisors, where appropriate) that the proposed transaction does not breach any legal statute or external regulations and further takes account of the University’s rules and requirements and the OfS Conditions of Registration.

5.3.3 Prior to entering any borrowing arrangements, including facilities, it is the responsibility of the Chief Financial Officer to consult the Board of Board. In considering whether to enter any new borrowing, the Board will be required to consider whether this affects the University’s ability to meet the financial condition D of registration with the OfS. All arrangements for secured borrowings, regardless of value, must be authorised and executed under seal and will be subject to the prior approval of the Board.

5.4 Appointment of bankers and delegation for operation of accounts

5.4.1 The Board is responsible for the appointment of the University’s bankers, lenders and other professional financial advisers on the recommendation of the Finance Committee.

5.4.2 The Finance Committee is responsible for approving:

1. The opening of bank accounts.
2. Bank mandates.
3. Entering borrowing facilities, including the giving of security over any of the University’s assets.

5.4.3 The Chief Financial Officer is responsible for:

1. The day-to-day operation of the bank accounts.
2. Ensuring that all University bank accounts are in the name of “The University of West London”.
3. Drawings against approved borrowing facilities and repayment to borrowing facilities.
4. Ensuring that borrowings meet the banks’ covenant requirements and remain within the general consent level granted by OfS.

5.4.4 The Finance Committee approve the mandates and named officials for the bank accounts. The policy is to have two lists of authorisers:

1. List A: Vice-Chancellor, Deputy Vice-Chancellor, Pro Vice-Chancellors, Chief Financial Officer, Deputy Chief Financial Officer, Senior Finance Members.
2. List B: Finance Managers

The signature requirements are as below:

• BACS multiple payment runs, including purchase ledger over £5,000,000 and up to £10,000,000 - Two authorisers, both from List A
• BACS multiple payment runs, including purchase ledger up to £5,000,000 - Two authorisers, at least one from List A
• Payroll BACS payments - Two authorisers, at least one from List A
• Cheques and individual BACS/CHAPS payments up to £25,000 - Two authorisers, from List A or B
• Cheques and individual BACS/CHAPS payments over £25,000 and up to £250,000 - Two authorisers, at least one from List A
• Cheques and individual BACS/CHAPS payments over £250,000 - Two authorisers, both from List A

5.4.5 Drawings against approved borrowing facilities and repayments to borrowing facilities require the authorisation of the Chief Financial Officer or the Deputy Chief Financial Officer.

5.4.6 It is the policy of the Finance Department to:

1. Avoid the issuing of cheques wherever possible, paying by BACS and sending remittance advices by email.
2. Avoid CHAPS payments wherever possible, charging the cost of making such payments back to the appropriate Budget Holder.

6. Income, banking and cash

6.1 Fees, discounts and waivers

6.1.1 Tuition fee proposals are approved by the VCE and then by the Board in accordance with any fee limits set by government.

6.1.2 Fee discounts must be for specific schemes and require the approval of the VCE. Discounts for staff related schemes require the approval of the VCE.

6.1.3 Fees may only be waived or partially waived by the Chief Financial Officer on a discretionary basis.

6.2 Grants, fees and income

6.2.1 Budget Holders are responsible for notifying the Chief Financial Officer of all sums due to the University as a result of activities undertaken by their respective departments immediately after the activity has been completed.

6.2.2 The Chief Financial Officer is responsible for ensuring that appropriate procedures are in operation to ensure that the University collects all income and grants to which it is entitled and in particular:

1. For raising all sales invoices (Budget Holders must not issue their own invoices).
2. That amounts are received at the agreed amounts and by the due dates.
3. For the security and prompt banking of all receipts.
4. That all income received is banked gross and payments are not disbursed from receipts.
5. For ensuring the correct application of VAT if appropriate to sales invoices.
6. For ensuring that adequate segregation of duties is established for all staff involved in the collection and handling of cash and cheques.
7. That debts are collected from students.

6.2.3 The Director of Strategic Planning and the Business Intelligence and Strategic Planning Manager will maintain a record of all persons registered as students at the University.

6.2.4 The Chief Financial Officer is responsible for the establishment and operation of an efficient and effective debt control system. To assist students with paying their fees the University offers payment plans and early settlement fees.

6.2.5 The referral of uncontested civil debts to debt collecting agencies or the initiation of County Court proceedings up to a ceiling of £20,000 is the responsibility of the Chief Financial Officer.

6.2.6 Bad debts are only written off with the approval of the Chief Financial Officer. Any write off-of over £25,000 is advised to the Finance Committee.

6.3 Banking and cash

6.3.1 All monies received b y any department from whatever source must be recorded by the Finance Department daily, together with the form in which they were received, for example cash, cheques, BACS, and other negotiable instruments.

6.3.2 All monies received must be paid to Finance Office promptly. Failure to pass all monies to Finance Office as soon as possible will result in disciplinary action.

6.3.3 Cheques and financial instruments must be made payable to the appropriate University account.

6.3.4 No cheque or financial instrument made payable to the University may be credited to an account which does not belong to the University.

6.3.5 The Chief Financial Officer is responsible for the safe custody and transit of all monies received in Finance Office, including the provision of adequate safes and for ensuring that arrangements comply with the requirements of the University's insurers.

6.3.6 All sums received must be paid in and accounted for in full and must not be used to meet miscellaneous departmental expenses or to make any other payments.

6.3.7 Cheques are never to be cashed out of money received on behalf of the University or by the Finance Office.

6.3.8 Staff responsible for the handling and custody of cash must comply with the following procedures:

1. All monies and other valuable items must be held in cash drawers or boxes which must be locked when not in use.
2. Cash must not be counted in public view or left unattended, even temporarily.
3. Unauthorised persons must not be allowed into income receiving points or the Finance Office.
4. Monies received must be balanced daily and paid into the bank on the same day or if this is not possible this must be done by the next working day.
5. Safes must be kept locked at all times except when in use to deposit or receive monies or other items.
6. Post-dated cheques must not be accepted for payment.

6.3.9 Cash, cheques and credit card receipts must not be sent through the University’s internal mail service, these should be taken immediately to the Finance Office.

6.3.10 Payees of cheques must be listed individually on paying-in slips.

6.3.11 All operational bank accounts must be reconciled at least monthly.

6.3.12 Electronic petty cash floats may be maintained at the discretion of the Chief Financial Officer to meet minor payments and disbursements. Such floats are the responsibility of the member of staff to whom they are entrusted. The Chief Financial Officer will maintain a record of all petty cash arrangements.

6.3.13 Payments from petty cash must not exceed £100 for any one purchase and must be supported by appropriate invoices or receipts.

6.3.14 Petty cash must not be used for:

1. Personal expenditure and loans to employees or students.
2. Cashing personal cheques.
3. The payment of wages or salaries (including overtime and one-off casual payments for work done, whether to employees or other persons).
4. The payment of any bill or invoice in respect of which a University purchase order has been issued.
5. Entertainment and hospitality.
6. The reimbursement of staff travelling and subsistence expenses.

6.4 ​​​​​​Cash budgeting and forecasting

6.4.1 The Chief Financial Officer is responsible for maintaining up-to-date cash forecasts. These are prepared monthly and cover at least one year ahead.

7. Expenditure

7.1 Salaries and wages

7.1.1 The University will employ a member of staff only where a financial provision has been made within the approved budget. The request to recruit must be approved by the Budget Holder, the relevant HR Partner and the relevant Finance Manager. All agreed requests then go to the VCE for final approval.

7.1.2 The Chief Financial Officer is responsible for all payments of salaries to all staff and for keeping all records relating to payroll including those of a statutory nature.

7.1.3 The following requires approval by the Budget Holder, Finance and HR and authorisation by VCE:

1. Employment of staff by the University, either on a permanent or fixed term basis, including replacement of leavers.
2. Variations to existing contracts.
3. The engagement of temporary staff.
4. Honorarium payments.

7.1.4 All employees must have a contract of employment, signed by the Director of Human Resources and Organisational Development or delegate, the Chief Financial Officer or the Vice-Chancellor; and the Human Resources Department (‘HR’) must retain a copy in accordance with the Records Retention Policy.

7.1.5 Schools or Professional Service Departments may only recruit temporary hourly paid lecturing staff after approval has been given by HR (as to proof of right to work in the UK) and Finance (as to funding availability) using the on-line Hourly Paid Lecturer (HPL) system. Budget Holders are responsible for ensuring that commitments do not exceed budget without prior agreement from the Chief Financial Officer in consultation with the Vice-Chancellor which will only normally be given in the following circumstances:

1. Additional teaching income above that identified in the Budget has been secured.
2. Demonstrable savings are made elsewhere, e.g., on permanent staff costs.

7.1.6 The policy of the University is to minimise the number of staff hired through recruitment agencies. However, there may be circumstances where agency temporary worker staff are required and provide a VFM solution to recruitment. The following steps should be followed:

1. Approval is required through VCE.
2. Where possible UWL Temps (University students seeking work experience) should be engaged.
3. Any arrangements using agency staff are for short-term expediencies and should not under any circumstances continue for more than one year.

7.1.7 The Chief Financial Officer is responsible for determining in accordance with HMRC regulations and guidance whether a person should be paid via the payroll or as a supplier and should be paid by invoice. Employees and workers are always paid via the payroll. The Chief Financial Officer is also responsible for informing HMRC of all payments.

7.1.8 The Director of Human Resources and Organisational Development is responsible for keeping the Chief Financial Officer informed of all matters relating to staff for payroll purposes, in particular:

1. Appointments, resignations, dismissals, secondments and transfers.
2. Absences for sickness or other reason, apart from approved leave.
3. Changes in remuneration.
4. Information necessary to maintain records of service for pension, income tax and national insurance

7.1.9 Budget Holders must inform the Director of Human Resources and Organisational Development in writing and within two days when any employee submits a notice of termination or a circumstance arises which affects the employment and/or pay of a member of their staff, such as maternity or long-term sick leave.

7.1.10 The Chief Financial Officer is responsible for day-to-day pension matters, including:

1. The timely payment of staff contributions to various authorised pension schemes.
2. Preparing returns to various pension schemes.

7.1.11 The Director of Human Resources and Organisational Development is responsible for determining contractual (and auto enrolment) eligibility for membership of pensions schemes. HR shall inform the Chief Financial Officer when deductions should begin or cease for staff.

7.1.12 The Chief Financial Officer shall ensure that adequate internal controls exist, which ensure that the University correctly accounts for all remuneration due to employees and that the related taxes deducted are accurate and submitted to the appropriate bodies within the required timescale. The payroll accounts are reconciled to the general ledger each month.

7.1.13 No deductions from a member of staff’s salary will be made unless the Payroll department holds a signed authority from the member of staff.

7.1.14 It is the policy of the University that all its employees take their annual leave entitlement within the 12-month period to which it relates. Prior agreement must be given by the employee’s line manager for the dates taken. Holiday not taken will be lost at the end of the annual leave year, except that a maximum of five days may be carried forward to the next leave year with the prior written agreement of the line manager.

7.1.15 All employees are required to record their holiday requests on the online MyView system and line managers are responsible for the prompt and reasonable acceptance or rejection of requests. Failure to record annual leave on MyView may be treated as a disciplinary matter in accordance w i t h the University’s Disciplinary Policy and Procedures, which can be found on the policies and regulations page.

7.1.16 Neither the University nor any of its wholly owned subsidiaries will make loans to staff, except for loans for travel costs. Such loans are intended to cover annual season ticket costs (or similar) and require the approval of the Chief Financial Officer. The loans are repayable from salary over a 12-month period or earlier if the employee leaves employment of the University and HMRC rules will be applied.

7.1.17 The University and its wholly owned subsidiary companies may, in exceptional circumstances make payments to employees in advance of their salaries. All such payments require the prior written consent of the Chief Financial Officer and will be conditional on:

1. The amount requested being equal to or less than the following month's net salary.
2. The amount of the advance being recovered in full from the following month's salary.

7.1.18 All severance arrangements must be approved by the Vice-Chancellor and the Director of Human Resources and Organisational Development who will issue a Settlement Agreement to the member of staff, a copy of which must be passed to the Chief Financial Officer. Severance for senior staff must be approved by the Remuneration Committee.

7.1.19 A member of staff may be requested to perform duties over an extended period beyond the scope of the post in which they normally work. In such cases, the responsible Budget Holder may propose an acting up payment which must be authorised by the VCE. Any authorised payment should reflect individual circumstances, the level of responsibility and the period involved. Such payments are paid though the payroll with the deduction of tax and national insurance, if appropriate, the deduction of pension contributions.

7.1.20 Support staff at grade 6 and below are eligible for overtime payments which are only paid with the prior agreement of the Budget Holder for the School/Professional Services Department.

7.1.21 The Chief Financial Officer reports monthly expenditure on staff costs to Budget Holders. The Finance Managers and Management Accountants support Budget Holders with forecasts for staff costs.

7.1.22 The Chief Financial Officer and the Director of Human Resources and Organisational Development will ensure that all employee records are safeguarded and comply with the provisions of the data protection legislation.

7.2 Purchasing of goods, services and works

7.2.1 All purchasing decisions made by University staff, no matter how small, have an impact upon whether the University maximises value or unnecessarily loses value. The Chief Financial Officer is responsible for ensuring that the University’s Procurement Policy aligns with the University’s strategic objectives, minimises risks and delivers a positive impact for the University as approved by Finance Committee. The Procurement Policy can be found on the finance and insurance page.

7.2.2 The Chief Financial Officer is responsible for producing the VFM strategy to support staff to secure and enable measurement of University effectiveness in all business areas. VFM is closely linked to affordability and the University works to ensure that it does not levy additional costs on top of tuition fees for the students. The University provides VFM for students through considered expenditure. The VFM strategy is approved by the Audit and Risk Committee.

7.2.3 The University considers itself to be subject to UK Public Procurement Regulations which are implemented in the UK as Public Contracts Regulations 2015.

7.2.4 The University is contractually bound to suppliers once a purchase order has been approved by the supplier.

7.2.5 For the reasons in paragraphs 7.2.3 to 7.2.4 the Procurement Policy must be compiled with by all staff and any departure from this Policy will result in disciplinary action. It is the responsibility of all Budget Holders to draw the key provisions of the Procurement Policy to the attention of all staff likely to become involved with the procurement of goods or services. The Procurement Policy is approved by the Chief Financial Officer who is responsible for ensuring that proper procedures exist for the control and monitoring of expenditure against approved budgets.

7.2.6 No member of the University may make a commitment on behalf of the University which would cause either capital or revenue budgets approved by the Board to become overspent.

The text below sets out the thresholds for obtaining quotes and tenders:

Aggregated expenditure including VAT and Actions required:

• Up to £4,999 - One written or verbal quotation
• £5,000 to £24,999 - At least two written quotations
• £25,000 to £49,999 - At least three written quotations
• £50,000 and above - Tender exercise managed by Strategic Procurement

7.2.7 All orders must be placed using the contracts negotiated by the Strategic Procurement Department where possible.

7.2.8 Any contract with a monetary value of over £1 million requires the approval of the Board. There are delegated authorities to senior staff and Budget Holders to approve purchases for amounts below £1m and these are:

Monetary limits (excluding VAT) and delegation:

• Up to £5,000 - Budget Holder or nominated Delegate
• £5,001 to £250,000 - Budget Holder + Chief Financial Officer or Deputy Chief Financial Officer 
• £250,001 to £1m - Vice-Chancellor + Budget Holder + Chief Financial Officer or Deputy Chief Financial Officer
• Over £1m - Finance Committee

Full details are on the Scheme of Delegation on the website.

7.2.9 Where orders for the supply of one product or service will exceed the UK Procurement thresholds in any contract period, the expenditure is subject to the Public Contracts Regulations and a tender process must be carried out in conjunction with the Strategic Procurement Department.

7.2.10 The following objectives are set out in the procurement strategy in the Procurement Policy:

• Objective 1: Provide optimum Value for Money (VFM) for all aspects of University expenditure through sourcing, supply, performance monitoring and embedding a VFM ethos in everyday management decision making.
• Objective 2: Introduce and embed category management for all strategic non-pay expenditure. Analyse non staff expenditure and apply appropriate procurement strategies to deliver VFM and reduce commercial risk.
• Objective 3: Improve best practice awareness and use throughout the University at all levels of expenditure to achieve optimum VFM by providing guidance to devolved procurement staff on:
  • Relevant procurement information on policy and UK procurement/Public Contracts Regulations
  • Consortium, Crown Commercial Service (CCS) and other collaborative procurement opportunities.
  • The latest procurement techniques and best practice in the procurement field.
  • Contract performance monitoring to support and deliver optimum VFM.
• Objective 4: Encourage and promote co-operation and communication between devolved procurement expertise and Strategic Procurement in order to better influence total University expenditure.
• Objective 5: Improve, embed and monitor overall procurement performance. Build an ethos of continuous improvement throughout the procurement infrastructure to support and deliver continued savings where possible.
• Objective 6: Promote collaboration by pursuing and developing co-operative relationships between the University and external procurement stakeholder bodies such as SUPC (Southern Universities Purchasing Consortium), LUPC (London Universities Purchasing Consortium), Crown Commercial Service (CSS) and other public and non-public sector bodies.
• Objective 7: Embed sound ethical, social value and environmental policies within the procurement function at both a strategic and devolved level and is detailed in the University’s Procurement Policy.

7.2.11 The following principles set out in the Procurement Strategy must be followed:

1. Purchases of goods and services can only be made by the issue of a properly authorised purchase order or use of a Procurement Card where appropriate.
2. Electronic purchase orders must be raised and authorised before the commitment is made with the supplier.
3. Under no circumstances should the raising and approval of the purchase order be left until receipt of invoice.
4. No artificial fragmentation of orders is allowed whereby authorisation can be given at a lower level than is appropriate.
5. Staff who are authorised to approve the purchase of goods, services and works on behalf of the University must make every effort to ensure that value for money is obtained.

7.2.12 The University’s General Conditions of Purchase are set out on the purchase orders and are available on the finance and insurance page. 

7.2.13 It is the responsibility of the Chief Financial Officer to ensure that these are kept up to date and are appropriate. Agreements with suppliers are not to be made under any other terms and conditions, such as earlier payment settlement, except with the approval of the Chief Financial Officer. Alternative or amended terms and conditions may be agreed when considered and evaluated in a tender exercise, subject to approval and review by the University’s Legal Department.

7.2.14 Acceptance of inducements of a personal nature will lead to disciplinary action. All staff of the University are required to notify any declarations of interest to the Chief Financial Officer and to the University Secretary and Chief Compliance Officer in respect of any aspect of the procurement process and to consult if in any doubt. See section 2.3.

7.3 Payment of creditors

7.3.1 The issue and acceptance of a purchase order constitutes a contract between the supplier and the University. Accordingly, once the goods or services have been properly delivered or executed, the University is contractually liable to pay the invoice.

7.3.2 The Chief Financial Officer is responsible for ensuring that the University’s payments systems are designed so that:

1. Payments to suppliers are made by the due dates.
2. Advantage can be taken if appropriate of preferential payment opportunities.

7.3.3 The Finance Department will make payment against invoices and account for VAT where the invoice has a VAT registration number. The Finance Department will not make payment against pro-forma invoices. The University encourages suppliers to submit electronic invoices via Parabillis EIT process, although paper invoices are still acceptable.

7.3.4 The Late Payment of Commercial Debts (Interest) Act 1998 was introduced to allow small businesses to charge interest on late payments by large organisations or public bodies. This allows interest to be charged at 8% above the Bank of England base rate. In view of the penalties in this Act, the General Conditions of Purchase state that all invoices a r e sent by suppliers to the scanning company address quoted on the purchase order. Budget Holders and their staff must not request that invoices are sent directly to departments.

7.3.5 If the ordering department has a concern about an invoice, it is the responsibility of the ordering department to liaise with the supplier. However, the ordering department must advise the Accounts Payable section of the Finance Department and keep them updated. Accounts Payable will liaise with the supplier’s credit control department to reduce the risk that the supplier will instigate legal proceedings against the University. If Accounts Payable are not informed and this leads to additional costs and/or reputational damage, the member of staff may be disciplined.

7.3.6 Delegation of authority for approval of invoices against a purchase order is at the discretion of Budget Holders.

7.3.7 Goods and services should not be paid for in advance or ahead of the University’s standard 30-day terms, unless there are exceptional circumstances, e.g., discounts, and the change is approved by the Chief Financial Officer.

7.3.8 Credit arrangements require the prior approval of the Chief Financial Officer. Approval will be given only after successful credit checks have been made.

7.3.9 Suppliers requesting a signed credit agreement should be contacted by the end user to identify why a credit agreement is required. Accounts Payable can approve the signing of a credit application form (in limited circumstances).

7.4 Procurement cards

7.4.1 Procurement Cards enable staff to make purchases against a card which has been issued for their use. The cards have restrictions relating to types of purchase and monetary limits; these vary between card holders.

7.4.2 Procurement Cards are issued with the approval of the Chief Financial Officer to specific staff for the purchase of low value items.

7.4.3 Budget Holders will comply with the restrictions on the cards set by Strategic Procurement.

7.4.4 Cardholders are required to sign an agreement for use of the cards which specifies (inter alia):

1. Cardholders are responsible for keeping an online Transaction Log and for sending the receipts to the Finance Department.
2. Cardholders will use the cards solely for the purpose of University expenditure and under no circumstances for personal expenditure.
3. Expenditure must be made within approved budgets.

7.4.5 The full details relating to Procurement Card Procedures are on the finance and insurance page. 

7.5 Staff expenses

7.5.1 It is the policy of the University that employees are reimbursed for reasonable expenditure incurred exclusively and necessarily in the performance of their duties.

7.5.2 Employees must exercise prudence and discretion in their expenditures and consider the business need and reasonableness of any expense. Employees should keep expenditure to a minimum without incurring risk to themselves or impairing the efficiency of the University.

7.5.3 Employees should seek the approval of their Budget Holder before incurring expenses. All air, sea, car, or rail travel for a single or return trip over £100 requires the prior written approval of the Chief Financial Officer. The University reserves the right to refuse to reimburse any excessive expenditure where the expenditure has not had the prior approval of the Budget Holder. All travel is to be booked through an approved supplier of the University.

7.5.4 Authorised signatories approving expenses have a duty of care to the University to reject claims that are not reasonable and justified.

7.5.5 Following receipt of valid expense claims the Chief Financial Officer is responsible for prompt payment of the claimed amount.

• Supporting receipts and vouchers must be submitted with a claim. Credit card vouchers are not acceptable as these do not enable the University to recover any VAT. If VAT is claimed a supporting voucher with the supplier VAT reference must be submitted.
• Claims received by the Finance department not correctly authorised will be returned to the claimant, and authorised claims considered unusual will be returned to the authoriser.
• Subsistence allowances are not claimable; the actual costs incurred should be claimed.
• Standard class travel may be claimed. Business class or first- class travel requires the approval of the Vice-Chancellor.
• Parking fines, congestion charge fines and speeding fines are not reimbursed.
• Travel expense claims must be claimed from the staff member’s normal place of work and not from the home address. See the finance and insurance page. 

7.5.6 Breaches of policy, abuse and inappropriate claiming/authorisation of claims under the staff expenses policy will be treated as a serious offence. They will be investigated and may lead to disciplinary action.

7.5.7 Claims must be made promptly; where expenses are claimed which were incurred more than three months before the claim was submitted, payment will not be made.

7.5.8 The staff expenses policy is approved by the Chief Financial Officer and is set out on the finance and insurance page. 

7.5.9 Claims are made using the on-line MyView system. Paper claims are not accepted from staff. Reimbursement is made monthly through the payroll system and cheques are not issued.

7.5.10 A daily supplement is payable for overseas travel where the member of staff is overseas for over two weeks; the supplement is taxable. Details can be found on the policies and regulations page. 

7.5.11 Staff must ensure that they abide by the University’s Driving at Work Policy.  

7.6 Fees and expenses of external examiners, advisers, experts and assessors

7.6.1 The policy for payment of external examiners, advisers, experts and assessor fees and expenses is approved by the Chief Financial Officer and is set out on the finance and insurance page. 

7.6.2 It is the responsibility of staff in the schools to approve the claims for fees and expenses promptly and for the Finance Department to pay these promptly on the receipt of properly authorised documents that comply with the relevant policy.

7.7 Interview candidates’ expenses

7.7.1 The policy for interview candidates’ expenses is set out on the finance and insurance page. 

7.7.2 It is the responsibility of line managers to approve the claims promptly in line with the University’s policy and for the Finance Department to pay them promptly on the receipt of properly authorised documents that comply with the policy. Payments are only made by BACS transfer.

8. Tax

8.1 Responsibility

8.1.1 The Chief Financial Officer is responsible for maintaining the University's tax records, making all tax payments, receiving tax credits and submitting tax returns by their due date as appropriate.

8.1.2 The Chief Financial Officer is responsible for minimising the taxation liabilities of the University and for ensuring that the University remains compliant with the rules of HMRC.

8.1.3 The Chief Financial Officer is responsible for advising Budget Holders in the light of guidance issued by the appropriate bodies and relevant legislation as it applies to the University, on all taxation issues. Therefore, the Chief Financial Officer will issue instructions to departments on compliance with statutory requirements including those concerning VAT, PAYE, national insurance and corporation tax.

8.1.4 Contact with HMRC for University purposes is only made by the Chief Financial Officer or a specific delegate. This relates to VAT, PAYE, national insurance and corporation tax.

8.2 Status for tax purposes

8.2.1 The University is an exempt charity and is not liable for corporation tax on any of its activities which fall within the terms of its charitable status.

8.2.2 The University is registered for VAT. (VAT number - 578 3378 88)

8.2.3 The University's wholly owned subsidiary companies operate as commercial organisations and are liable to corporation tax. The companies have their own corporation tax and VAT registrations.

9. Fixed assets and investments

9.1 Policy

9.1.1 Fixed assets comprise land and buildings owned or leased by the University, furniture, fixtures and fittings, equipment, plant and vehicles. Only individual fixed assets costing £10,000 or more are capitalised, although items costing less may be capitalised as part of a larger single project.

9.1.2 The Director of Property Services is responsible for ensuring adequate security over the assets owned or leased by the University and for maintaining up-to-date plans of all buildings owned or leased by the University and its wholly owned subsidiary companies and will inform the Chief Financial Officer of the current replacement value of all buildings for which insurance is required.

9.1.3 Budget Holders are responsible for the safe keeping of any equipment, cash and other assets of the University which are under their control.

9.1.4 Fixed assets are only purchased from the agreed capital budget.

9.2 Asset register

9.2.1 The Chief Financial Officer is responsible for maintaining the Fixed Asset Register.

9.2.2 Expenditure/purchases to be identified as fixed assets and recorded in the Asset Register include:

1. Land and buildings.
2. Non-computing equipment for individual assets with a cost of £10,000 or above including VAT.
3. All computing equipment (including ancillaries purchased with the computer), printers, communication devices, servers etc.
4. Capital projects (including professional fees and furniture, fixtures and fittings purchased as part of the capital project).
5. Motor vehicles.

9.2.3 The purchase of assets may be funded from grants, but (subject to any grant conditions) these assets are the property of the University. The assets should be purchased in compliance with the Procurement Policy and recorded in the Asset Register as appropriate. The assets will be maintained by the University with the provision of relevant software licences, if appropriate. The individual member of staff using the asset will not be liable for personal taxation on such funding.

9.3 Motor vehicles

9.3.1 All motor vehicles which are the property of the University must be registered in the name of the University.

9.3.2 All administration relating to the vehicles are the responsibility of the Director of Property Services who:

1. Maintains records of vehicle registrations, road tax, MOT inspections and insurance.
2. Ensures that motor vehicles are always roadworthy, and that at all times, statutory requirements including those concerning the carriage of goods and passengers are complied with.
3. Ensures that the vehicles are driven only by members of staff who hold a valid driving licence and who meet the requirements of the University's insurers.

9.3.3 More detail is contained in the Driving University Vehicles Policy.

9.4 Information technology (IT), telecoms equipment and software

9.4.1 IT Services is responsible for keeping records of all IT, telecoms and related equipment, software licences and service contracts.

9.4.2 All purchasing of IT, telecoms and related equipment and software and services is only to be made by IT Services using preferred suppliers and in line with the Procurement Policy. All assets so purchased are the property of the University. This applies regardless of the source of funding, whether through research grant, National Teaching Fellowship funds or funded by a School or Professional Services (subject to the terms of funding).

9.4.3 IT equipment and facilities will normally be provided in line with IT Services’ standard technology and provisions. Requests for provision outside of these areas, or where a facility would not normally be provided, will require the submission of a written justification for consideration by IT services.

9.4.4  IT services is responsible for:

1. The allocation of IT, telecoms and related equipment and software.
2. Determining the most appropriate IT solutions and kit to be supplied, having regard to cost and the need to optimise services.
3. The provision of all IT services and facilities used by the University, including Internet or externally based application and data services.
4. The reallocation, refurbishment or disposal of IT and related equipment, as per section 9.6.

9.4.5 Property Services in collaboration with IT Services shall provide all printing, copying and scanning facilities, and their supplies and maintenance, for the University, in accordance with the Printing and Print Management Policy which can be found on the policies and regulations page.

9.4.6 Staff owe a duty of care for University IT assets that are allocated to them, including mobile and portable devices. Devices must be kept safe and secure, access to University systems through them controlled and any University data held on them must be stored securely and confidentially and in accordance with The Acceptable Use of Information Assets Policy. The University reserves the right to withdraw or not replace IT facilities that have not been appropriately used or cared for.

9.4.7 Where staff use personally owned devices for University business, the same considerations apply, in that access to University systems and any University data stored on them must be secure and controlled as set out in the Remote Working Guidelines. The University reserves the right to inspect and/or wipe any University data held on personal devices.

9.4.8 The University will not purchase or reimburse the purchase of any software, ‘apps’ or other facilities or services for personally owned devices. In some cases, ‘work at home’ copies of University-purchased software may be available, via IT Services and subject to conditions. This applies to both new equipment and equipment previously purchased through other Budgets

9.5 Loans of equipment

9.5.1 Equipment and material that is the property of the University may be loaned to employees of the University or of its wholly owned subsidiary companies to support them with their work for the University or to students to support their University and related studies. All loans must be authorised as follows:

• Up to £5,000 - Budget Holder
• £5,001 to £10,000 - As immediately above plus the Chief Financial Officer
• Over £10,000 - As immediately above plus the Vice-Chancellor

9.5.2 The Budget Holder for the equipment is responsible for keeping a record of all equipment on loan and for ensuring its safe return by the appropriate date or when the member of staff leaves their employment with he University.

9.6 Disposal of assets

9.6.1 No sale, disposal or write-off of University assets may be made unless it has been approved as follows:

• On all disposals - Budget Holder
• £5,000 to £50,000 - As immediately above plus the Chief Financial Officer
• £50,001 to £500,000 - As immediately above plus the Vice-Chancellor
• £500,001 to £1,000,000 - As immediately above plus the Finance Committee
• Over £1,000,000 - As immediately above plus the Board

9.6.2 Budget Holders are responsible for advising the Finance Department about all disposals so that the fixed asset register can be updated.

9.6.3 Advice on the proceeds to be obtained from disposals should be sought from the Chief Financial Officer.

9.6.4 Disposal of assets must meet regulatory requirements and the Waste, Electrical and Electronic Equipment Directive (WEEE). To ensure that these regulations are complied with, all IT and related equipment must be returned to IT Services. Other electrical equipment must be returned to the Facilities Department. Revenue budgets of Schools and Professional Service departments must allow for the costs of disposal.

9.6.5 The University does not normally sell or give IT equipment t o staff working at or leaving the University. If there is a requirement for a member of staff to have IT equipment at home to help with their work, this will be provided by the University and remain under ownership of the University.

9.6.6 The University will not dispose of any IT equipment directly to students, charities or other good causes. IT Services are only permitted to dispose of IT equipment to registered WEEE recycling and disposal agents.

9.6.7 Any disposal of land or buildings and any transfer of land or buildings to a wholly owned subsidiary company of the University will require the approval of the Board and will be in accordance with the requirements of these Regulations and with the OfS Terms and Conditions of Funding.

9.6.8 The disposal of land or buildings purchased with the aid of public funds will require the prior approval of OfS.

10. Subsidiary companies and joint ventures

10.1 Policy

10.1.1 In certain circumstances it may be advantageous to the University, for fiscal reasons, to establish a company or a joint venture to undertake services on behalf of the University. Any member of staff considering the use of a company, or a joint venture should first seek the advice of the Chief Financial Officer.

10.1.2 The Board is responsible for approving the establishment of all companies or joint ventures, following consideration by the Finance Committee (unless it is through the Westmont Enterprise Hub – ‘the Hub’). It is the responsibility of the Board to appoint directors of companies wholly or partly owned by the University as outlined in the Scheme of Delegation.

10.2 Declaration and registration of interests

10.2.1 The board of directors of the University’s wholly owned subsidiary companies are required to adopt the University's Regulations and procedures for the declaration and registration of interests, benefits and gifts and will make a report to the Finance Committee confirming that they have done so.

10.2.2 Any sponsorship and charitable donation could give rise to a potential conflict of interest if it will:

1. Have an impact on any other material transaction
2. Influence a current bidding/tendering exercise
3. Be seen as a reward for the awarding of a contract or other benefit provided by the University

10.3 Reporting

10.3.1 Where the University is the majority shareholder in a company the directors of that company:

1. Must submit, via the Finance Committee, an annual report to the Board.
2. Must submit business plans or budgets as requested to enable the Finance Committee to assess the risks to the University.
3. Must appoint the University's internal and external auditors to such companies.
4. Arrange for the company’s financial year to be the same as that of the University.

11. Westmont Hub operations

11.1 The Board approved the establishment of Innovate@UWL, a company limited by shares, which was established in order to hold the investments made in companies incubated by the Hub.
 
11.2 The investments in incubated companies will normally be made in kind and consist of the incubation support provided by the Hub and for this, the University will be granted a 12% stake in the incubated company. All intellectual property (IP) will be vested in the incubated company.

11.3 Where the investment is in a spin out company for the exploitation of staff generated IP, the IP will be invested in the company for a stake of up to 49%.

11.4 The University will enter into agreements with companies once an appropriate business model and incubation plan has been agreed with the incubatee. or staff member to be considered by a panel including the DVC and the Chief Financial Officer acting as Directors of Innovate@UWL. The agreements will be signed by one of the Directors of Innovate@UWL.

11.5 The University will normally sell its stake within five years or sooner where it is advantageous for the University to do so.

11.6 The University may invest up to £50k in a company where it is considered that there is substantial potential in the proposal up to a maximum aggregate of £200k of any such investments per year. All monies for such investments should come from external donations for this purpose or enterprise funds. All such investments must be reported to the Finance Committee.

12. Intellectual property

12.1 Any matter or thing capable of being patented under the Patents Act 1977, which is made, developed or discovered by an employee (either alone or with colleagues), whilst in the performance of their normal duties, must be disclosed to the University and, subject to the provisions of the Patents Act, is the property of the University.

12.2 All records, documents and other papers which pertain to the finance and administration of the University and which are made or acquired by employees in the course of their employment, are the property of the University. The copyright in all such original records, documents and other papers belongs to the University.

12.3 The copyright in any work or design compiled, edited or otherwise created by an employee with a contract of equal to or more than 0.5 Full Time Employee (FTE) as a scholarly work produced in furtherance of their professional careers shall belong to the University.

12.4 The copyright in any work or design compiled, edited or otherwise created by an employee with a contract of less than 0.5 FTE as a scholarly work produced in furtherance of their professional careers shall belong to the employee, however the University will normally be assigned a nonexclusive royalty free license for the use thereof.

12.5 ‘Scholarly work’ for the purposes of paragraphs 11.1.3 and 11.1.4 includes items such as books, contributions to books, articles and conference papers, and shall be construed in the light of the common understanding of the phrase in Higher Education.

12.6 The copyright in any material produced by employees for their personal use and reference, including as an aid to teaching, belongs to them.

12.7 However, the copyright in course materials produced by employees in the course of their employment for the purposes of the curriculum of a course run by the University and produced, used or disseminated by the University belongs to the University, as well as the outcomes from research specifically funded and supported by the University, and as well as the outcomes from all research or enterprise activity irrespective to source of funding (subject to the terms of the funding contract).

12.8 The University’s policy on Intellectual Property (IP) is on the policies and regulations page.

13. Insurance

13.1 Policy

13.1.1 As part of the overall risk management strategy all University risks are considered and those most effectively mitigated through insurance arrangements are identified.

13.2 Responsibility

13.2.1 The Chief Financial Officer is responsible for arranging adequate insurance cover for risks identified as appropriate to be insured. The Chief Financial Officer will:

1. Take out such insurance cover as necessary to mitigate risks to which the University, its subsidiary companies or its Governors or officers might be exposed.
2. Negotiate and, where possible, recover claims.
3. Review insurance strategy and all insurances annually.
4. Annually report the insurance arrangements to the Finance Committee confirming if adequate cover has been obtained and including information about risks which the University intends to bear itself

13.2.2 As a minimum, the following policies are maintained:

• Material damage to buildings and contents, including business interruption
• Employers’ liability
• Public and products liability
• Professional indemnity
• Governors, directors, and officer’s liability
• Group personal accident / travel
• Motor fleet
• Terrorism
• Kidnap and ransom
• Cyber insurance

13.2.3 Budget Holders are responsible for notifying the Chief Financial Officer immediately of:

1. Any circumstances which may materially affect the University's overall exposure or risk.
2. Information concerning property, vehicles, plant or other assets of the University which may materially affect the University's overall exposure or risk.
3. Additions, disposals and alterations to property, vehicles or other assets of the University which might affect existing insurances.
4. Any potential loss, liability, damage, or any event likely to give rise to a claim against the University or any of its subsidiary companies

13.3 Losses and claims

13.3.1 All injuries or other losses suffered by personnel on University premises (both employees, students and external visitors) must immediately be advised to the University Secretary and Chief Compliance Officer who is responsible for notifying the University’s nominated brokers without delay and advising the Finance Department. The Health & Safety Manager maintains a register of all such incidents.

13.3.2 All losses relating to physical items must be reported immediately to the Chief Financial Officer who is responsible for notifying the University’s nominated brokers without delay and maintaining a register of losses and claims.

13.3.3 Insurance claims may only be made by the Chief Financial Officer. University staff must not deal directly with the brokers or the insurers.

13.3.4 Where a loss is suffered due to a School or professional service department not implementing the appropriate security measures, the excess will be charged against their budget.

13.4 Personal property

13.4.1 The University does not accept liability for loss or damage to personal property, howsoever it is caused. Employees of the University or students or visitors who bring personal property on to premises owned by or leased to the University must ensure that they have made their own adequate insurance arrangements. This applies also to private motor vehicles brought on to or parked on University property.

14. Students’ Union

14.1 Status

14.1.1 The Students’ Union is a separate legal entity from the University. It fulfils a valuable role in representing the University’s students.

14.1.2 The Students' Union conducts and manages its own affairs and funds in accordance with the requirements of the Education Act 1994, its constitution (which is approved by the Board) and the terms and conditions of any contract or agreement between the University and the Students' Union.

14.1.3 These Financial Regulations do not apply to the Students' Union, except as far as they have been incorporated into the Students’ Union's own financial regulations.

14.1.4 The Financial Regulations of the Students' Union and any amendments to them are approved by its own Trustee Board.

14.2 Funding

14.2.1 The Students’ Union receives funding from the University in the form of a block grant plus funding for agreed services. The annual application for this grant is reviewed by the Student Liaison Committee and the Finance Committee and a recommendation made to the Board whose approval to the grant is required.

14.2.2 The Students’ Union is responsible for maintaining its own bank account and financial records, for preparing annual Financial Statements, and arranging for the audit of those statements by an appropriately qualified firm of auditors. The audited Financial Statements are presented annually to the Finance Committee and the Board.