City College Coventry (CCC) is committed to conducting all activities with honesty, integrity and in full compliance with applicable laws and regulations. CCC maintains a zero-tolerance approach to fraud, bribery, corruption and money laundering across all operations, relationships and partnerships.This policy gives effect to CCC’s obligations under the Bribery Act 2010, the Fraud Act 2006, the Proceeds of Crime Act 2002, the Terrorism Act 2000, and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. It also supports CCC’s compliance with the conditions of registration with the Office for Students, including the requirement for effective management and governance under Condition E2.The Board of Governors, through the Audit & Risk Committee, has overall responsibility for ensuring that this policy is implemented effectively and that adequate systems exist to prevent and detect fraud, bribery, corruption and money laundering.

This policy applies to all individuals acting on behalf of, or in connection with, City College Coventry in any capacity, including:❖ Members of the Board of Governors and its Committees, Subcommittees, and Panels❖ The Chief Executive Officer, the Head of Academics, and all members of the Corporate and Academic Boards❖ All employees, whether permanent, temporary or part-time❖ Contractors, consultants and agency workers❖ Students❖ Staff and representatives of partner universities engaged in activities connected with CCCWhere CCC enters into partnership arrangements with degree-awarding bodies or other institutions, the respective responsibilities for fraud prevention and reporting will be set out in the partnership agreement. CCC will seek assurance that partner institutions maintain equivalent standards of anti-fraud, anti-bribery and anti-corruption practice in respect of activities connected with CCC students and operations.

3.1 FraudAny intentional act of deception, dishonesty or abuse of position designed to secure an unlawful or unfair gain, or to cause loss to another party. Under the Fraud Act 2006, this includes fraud by false representation, fraud by failing to disclose information, and fraud by abuse of position. Examples relevant to a higher education context include: falsification of academic records, student attendance data or financial documents; misappropriation of funds or assets; false expense claims or declarations; identity fraud in admissions or assessment; and deliberate misrepresentation in regulatory returns or funding claims.3.2 BriberyThe offering, promising, giving, accepting or soliciting of an advantage as an inducement for an action which is illegal, unethical or a breach of trust. Under the Bribery Act 2010, there are four principal offences: bribing another person, being bribed, bribing a foreign public official, and failure of a commercial organisation to prevent bribery. A bribe may take many forms including cash, gifts, loans, fees, rewards or other advantages. Examples include:❖ Offering or accepting cash, gifts or excessive hospitality to influence admissions decisions, contract awards or academic outcomes❖ Providing kickbacks or inducements to secure contracts or favourable treatment from suppliers or partner institutions❖ Making facilitation payments to expedite routine government or regulatory actions3.3 CorruptionThe abuse of entrusted power for private gain, including misuse of position, influence or authority for personal benefit or to benefit others inappropriately. In a higher education context, this includes the misuse of governance or management positions to direct institutional resources or decisions for private advantage.3.4 Money LaunderingThe process of concealing the origins of illegally obtained money or property. Under the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2017, the principal offences are:❖ Concealing, disguising, converting or transferring criminal property❖ Entering into or becoming concerned in an arrangement which facilitates the acquisition, retention, use or control of criminal property❖ Acquiring, using or possessing criminal propertyHigher education institutions can be vulnerable to money laundering through tuition fee payments, particularly where large cash sums or complex international payment arrangements are involved.

4.1 Board of GovernorsThe Board holds overall accountability for ensuring that CCC has effective arrangements in place to counter fraud, bribery, corruption and money laundering. This responsibility as delineated in the Corporate and Academic Governance Framework and the Scheme of Delegation, is discharged through the Audit & Risk Committee, which is responsible for reviewing the adequacy of anti-fraud arrangements, receiving reports of suspected or actual fraud, and providing assurance to the Board.4.2 Chief Executive OfficerThe CEO has executive responsibility for the implementation and enforcement of this policy, for ensuring that adequate internal controls and risk management arrangements are in place, and for reporting significant incidents to the Board and Audit & Risk Committee.4.3 Money Laundering Reporting OfficerCCC’s designated Money Laundering Reporting Officer (MLRO) is the Finance Officer. The MLRO is responsible for receiving and assessing internal disclosures of known or suspected money laundering activity, determining whether such disclosures require a Suspicious Activity Report (SAR) to the National Crime Agency, and maintaining a record of all internal reports and any SARs submitted. All suspicions of money laundering must be reported to the MLRO. Under no circumstances should the individual concerned be informed that a report is being made, as this may constitute the criminal offence of ‘tipping off’ under the Proceeds of Crime Act 2002.4.4 Academic and Corporate Board MembersMembers of the Academic and Corporate Boards are responsible for promoting a culture of integrity within their areas of responsibility, ensuring that staff are aware of this policy and have received appropriate training, and for reporting any concerns through the appropriate channels.4.5 All StaffAll staff are expected to conduct themselves with honesty and integrity in all business dealings, to be alert to the risks of fraud, bribery, corruption and money laundering, to report any concerns or suspicions promptly, to record all gifts and hospitality in accordance with this policy, and to cooperate fully with any investigations.

CCC’s financial control framework is a key safeguard against fraud and corruption. All expenditure, contracts and asset transactions must be authorised in accordance with the financial approval thresholds established by the Board of Governors as set out in the Scheme of Delegation:Approval Authority Expenditure ThresholdBudget Holder Up to £2,500Strategic Leadership Team (Head ofCorporate & Head of Academics)Up to £50,000Chief Executive Officer £50,001 to £150,000Committees of the Board £150,001 to £250,000Board of Governors Above £250,000No individual may authorise expenditure above their delegated limit without appropriate escalation. Any attempt to circumvent these thresholds, including by splitting transactions to avoid higher levels of approval, will be treated as a breach of this policy. Dual authorisation is required for all payments exceeding £5,000.

CCC recognises that reasonable and proportionate gifts and hospitality can support legitimate business relationships. However, they must never be used to gain unfair advantage, create a sense of obligation, or improperly influence decision-making.6.1 Thresholds and RequirementsCategory RequirementGifts or hospitality under £25 No action required, but staff should exercise judgementGifts or hospitality £25 to £50 Must be recorded in the Gifts and Hospitality Register and reported to line managerGifts or hospitality over £50 Must be declined unless prior written approval is obtained from a member of Corporate or Academic BoardsAny gift or hospitality during a procurement process or contract negotiationMust be declined in all circumstances and reported immediately6.2 Gifts and Hospitality That Must Always Be DeclinedThe following must be declined in all circumstances, regardless of value:❖ Cash, vouchers, gift cards or loans❖ Any gift or hospitality offered during a procurement process or contract negotiation❖ Gifts or hospitality that could reasonably be perceived as creating an obligation or influencing a decision❖ Facilitation payments of any kind❖ Donations used as a disguise for bribery or to influence decision-making6.3 Gifts and Hospitality RegisterThe Gifts and Hospitality Register is maintained by the Chief of Staff as the Chair of the Staff & Culture Subcommittee and is subject to periodic review by the Audit & Risk Committee. All entries must include the date, a description of the gift or hospitality, its estimated value, the name of the giver or receiver, and the business context.

CCC is committed to complying with all obligations under the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2017. The following controls are designed to prevent CCC from being used, knowingly or unknowingly, for money laundering purposes.7.1 Know Your Customer ProceduresCCC will conduct appropriate identification and verification checks on all fee-paying students, with enhanced due diligence applied where there is higher risk. This includes:❖ Verification of student identity using original documentation at enrolment❖ Enhanced checks where fees are paid in cash, by third parties, or through complex payment arrangements❖ Enhanced checks for payments originating from jurisdictions identified as high-risk by HM Treasury or the Financial Action Task Force❖ Retention of identification and verification records for at least five years from the end of the business relationship7.2 Indicators of Potential Money LaunderingStaff should be alert to the following indicators, which may individually or in combination suggest money laundering:❖ Requests to pay fees in cash, particularly sums exceeding £1,000❖ Payments from unrelated third parties without reasonable explanation❖ Multiple payments from different sources for a single student’s fees❖ Students who appear indifferent to course choice or academic engagement despite paying substantial fees❖ Requests for refunds to be paid to a different account or to a third party❖ Unnecessarily complex or opaque payment arrangements❖ Reluctance to provide identification or verification documentation7.3 Reporting SuspicionsAny suspicion of money laundering must be reported immediately to the MLRO (Finance Officer). The MLRO will assess the report and, where appropriate, submit a Suspicious Activity Report to the National Crime Agency. Staff must not proceed with a suspicious transaction without the MLRO’s consent. Under no circumstances should the individual concerned be informed that a report is being made or considered.

All procurement activities and contract awards must be conducted in a fair, transparent and competitive manner, in accordance with the financial authority thresholds set out in Section 5. Specific requirements include:❖ Competitive quotations or tenders must be obtained in accordance with the Scheme of Delegation for the relevant expenditure level❖ Appropriate due diligence must be carried out on suppliers to establish that they are legitimate and of good standing❖ Clear separation must be maintained between those specifying requirements, evaluating bids and authorising contracts❖ All conflicts of interest must be declared and managed in accordance with the Conflicts of Interest Policy❖ Supplier contracts must include appropriate anti-bribery and anti-corruption clausesAny offer of a kickback, inducement or other improper advantage must be reported immediately and will result in contract review or termination as appropriate.

Where CCC enters into partnership agreements with degree-awarding bodies or other institutions, particular care is required to ensure that the integrity of shared processes is maintained. Partnership agreements should address:❖ Clear allocation of responsibility for financial controls, including fee collection, refund processes and the handling of student funds❖ Agreed procedures for the reporting and investigation of suspected fraud or irregularity affecting partnership operations❖ Mutual obligations regarding anti-bribery, anti-corruption and anti-money laundering compliance❖ Access rights and information-sharing arrangements sufficient to support audit and investigation where required❖ Provisions for review and assurance of the partner’s compliance with agreed standardsThe Head of Partnerships reporting to the Chief Executive Officer is responsible for ensuring that these provisions are incorporated into partnership agreements and that compliance is monitored on an ongoing basis.

If you suspect or become aware of any breach of this policy, you must report it immediately. Reports should be made through the appropriate channel as set out below:Type of Concern Primary Reporting Channel Alternative ChannelSuspected fraud, bribery or corruptionLine Manager or SeniorLeadership TeamWhistleblowing PolicyproceduresSuspected money laundering Money Laundering Reporting Officer (Finance Officer)Chief Executive OfficerConcerns involving senior staff or governorsChair of the Board ofGovernorsChair of Audit & RiskCommitteeConcerns involving the CEO Chair of the Board of GovernorsExternal reporting to relevant authoritiesAll reports will be taken seriously, treated confidentially, and investigated appropriately. No detrimental action will be taken against any individual who has refused to participate in fraud, bribery, corruption or money laundering, or who has made a report in good faith. Such individuals will be supported and protected during any investigation in accordance with the Whistleblowing Policy.Where appropriate, CCC will refer matters to external authorities including the police, the National Crime Agency, the Office for Students, or other relevant regulators. The decision to refer will be made by the CEO in consultation with the Chair of the Audit & Risk Committee, except in the case of Suspicious Activity Reports which are the responsibility of the MLRO.

Where an allegation of fraud, bribery, corruption or money laundering is received, the CEO will determine the appropriate course of action, which may include internal investigation, referral to external authorities, or both. Investigations will be conducted by individuals with no conflict of interest in the matter and with appropriate expertise.Breaches of this policy will be treated seriously and may result in disciplinary action up to and including summary dismissal. In the case of governors, breaches may result in removal from the Board in accordance with the Corporate and Academic Governance Framework. Criminal conduct will be reported to the relevant authorities and may result in prosecution.Where a breach involves a contractor or supplier, CCC will review the contract and may terminate the relationship. Where a breach involves a student, the matter will be handled under the Student Disciplinary Procedure.

CCC will maintain the following records to demonstrate compliance with this policy and relevant legislation:❖ The Gifts and Hospitality Register❖ Records of all staff training on this policy❖ Due diligence records for suppliers and contractors❖ Student identification and verification records (retained for at least five years from the end of the student’s engagement)❖ Records of all internal reports, MLRO assessments, Suspicious Activity Reports and investigation outcomes❖ Audit & Risk Committee minutes relating to anti-fraud mattersRecords will be retained for at least six years, or longer where required by law, regulatory obligation orCCC’s retention schedule.

All staff will receive training on this policy as part of their induction and through regular refresher training at intervals of no more than two years. Training will cover the requirements of this policy, relevant legislation, how to recognise and report fraud, bribery, corruption and money laundering, and procedures for recording gifts and hospitality.Staff in roles with higher exposure to these risks will receive enhanced, role-specific training. This includes staff involved in:❖ Finance and accounts❖ Procurement and supplier management❖ Admissions and student recruitment❖ Student fee collection and refunds❖ Governance and senior leadershipMembers of the Board of Governors and its Committees will receive training on this policy as part of their induction.Contractors and suppliers will be made aware of this policy and CCC’s expectations regarding compliance.

This policy will be reviewed annually by the Corporate Board and recommended to the Audit & Risk Committee for approval. Any significant changes will be subject to approval by the Board of Governors. The review will consider changes in legislation, regulatory guidance, best practice, the outcome of any fraud or irregularity incidents, and the findings of internal or external audit.

Version V2.0Author Chief Executive OfficerLast review date July 2026Next review due July 2027Approved by Board of GovernorsImplementation date July 2026