Corporate Financial Integrity Policy - Guidance Notes

1. Purpose

This guidance supports the Corporate Financial Integrity Policy and will set out the arrangements which will apply to staff, students, and associates who either incur costs while carrying out University business, have use of a University Corporate Card, or are in receipt of/or offering, gifts and hospitality.   The Corporate Financial Integrity Policy should be used as reference throughout the guidance document.

Corporate Financial Integrity is supported by other university policies and procedures, they are:

  • Financial Regulations.
  • Procurement Strategy.
  • Purchasing and Procurement Guidance.
  • Anti-Bribery and Corruption Policy.
  • Sustainable Travel Policy.
  • Personal Relationships at Work Code of Conduct.

All employees, students and associates who incur business costs or are in receipt of/or offering gifts and hospitality, must familiarise themselves with the associated policies and guidance

2. Corporate Card

This section outlines the circumstances in which it would be appropriate to issue an employee with a university credit card or a pre-loaded debit card (corporate card), the application process and guidance of usage, including cardholder responsibilities.

2.1 Who Qualifies?
Corporate cards are issued to employees who travel frequently or whose job role requires it at the discretion of the Director of Finance, Infrastructure and Corporate Services or their nominee.

2.2 What can you purchase?
The cards are only available for business use and are to be used predominantly for expenses, such as;

  • Travel subsistence costs such as: meals; away from home transfers (if not available to book on Travel Management Solution); and parking.
  • Personal incidental expenditure.
  • Business Entertainment (as defined under section 5 Gifts & Hospitality).

Cardholders must not use the cards for:

  • The purchase of general goods or services, such as – books, IT equipment/accessories, subscriptions, conferences, or internet purchases. All such purchases must be directed to the purchasing team.
  • Any personal purchases.
  • Cash Advances, the only exemption is where pre-approval has been granted by a senior manager due to travel location, however where possible, pre-loaded cards must be used.
  • Travel and accommodation – unless in exceptional circumstances, all bookings must be made with the University’s Travel Management Solution (TMS) Click Travel. Such circumstances would include where there is an issue with the TMS preventing an urgent booking. (See section 3 for further information).
  • Any purchases deemed non-allowable by the Director of Finance, Infrastructure and Corporate Services will be deducted from salary. An appeal against such a decision can be made to the Principal whose decision will be final.

Corporate card expenditure is restricted to the categories listed above because of HM Revenue & Customs (HMRC) regulations. Under these regulations, credit cardholders can incur such expenditure without a tax liability arising providing adequate controls exist to monitor expenditure. Using the Corporate card to incur items of expenditure out-with the allowable expenditure categories puts the University at risk of non-compliance and also compromises the University’s Financial Regulations.

2.3 How to apply?
An employee’s line manager (with senior manager approval) should email purchasing@abertay.ac.uk requesting the issue of a corporate card and explaining the reason for the request. Where additional information is required, finance will request the relevant information from the employee/requesting department to allow the application to be progressed.

If approved and once the corporate card is ready for collection, Finance will contact the employee and agree the collection arrangements. When receiving a card, the cardholder must sign the standard statement of responsibility.

2.4 How to use?
Cardholders should obtain pre-approval of purpose of spend, such as hospitality or additional travel subsistence. Evidence of this pre-approval and all receipts detailing spend are required to be uploaded into the relevant portal, currently the SDG2 (Smart Data) system by the 10th of each month. For the avoidance of doubt, pre-approval is required for the overall event and not each individual item of expenditure.

A listing of all transactions will be available via the SDG2 Smart Data website: https://www.smartdata.lloydsbankcommercial.com/sdportal/home.view

Cardholders are required to review all transactions noting VAT where charged, confirm the budget code, attach copies of receipts plus pre-approval and submit for approval to the budget holder.

2.5 Cardholder Responsibility
The cardholder is responsible for the safety of their card, it must be kept in a safe place and if lost, must be reported immediately to the issuing bank and to accountspayable@abertay.ac.uk . Cardholders must not divulge their card details to another person.

Cardholders must ensure that all expenditure is incurred wholly, necessarily and exclusively in the performance of the duties of employment.

Every expense paid via a card must be supported by a valid detailed, complete and legible receipt.

Cardholders must provide justification for all transactions and should expect to be challenged if they fail to do so. There must also be a clear explanation regarding the reason for every line of expenditure on the credit card statement. Similarly, be able to demonstrate when, where and, why expenditure has been incurred.

Where business entertaining costs have been incurred, cardholders must ensure that following information is uploaded along with their receipt in support of the claim:

  • The names of the attendee(s).
  • The organisation which they represent.
  • The purpose of the entertainment (e.g. entertaining visiting speaker).

3. Expenses

This section outlines the circumstances in which expenses can be claimed along with guidance on how to submit an expense claim.

3.1  Costs that can be reimbursed as a business expense include:

  • Travel and accommodation subsistence that is not covered by the Travel Management Solution/Team, such as Meals and Drinks.
  • Hospitality/Business entertaining, noting that further rules/guidance is within this document.
  • Personal Incidental Expenses, incurred due to overnight stays. (see 4.2).

Please review section 5 Gifts & Hospitality for further details on what can and cannot be claimed for, along with Annex 1 for rates payable for travel and subsistence.

3.2 What you can claim for:

  • Expenses you have incurred on public transport, taxis or accommodations where these have not been booked and paid for in advance.
  • Staying with friends and relatives. If you stay with friends or relatives while away on university business, you can claim an amount as a contribution towards the costs incurred by your hosts (see annex 1).  The allowance is in lieu of hotel costs which might otherwise be claimed and applied to both UK and overseas trips.  You should note that payments in relation to staying with friends/relatives will be paid via monthly payroll and will therefore be subject to tax and national insurance.
  • Subsistence – to cover the cost of meals/drinks (excluding alcohol) consumed while away on university business (see also 3.10).
  • Mileage allowance for the use of your own car, motorcycle, or cycling on university business. Where the journey begins and ends at home you may claim the whole cost of the journey provided that it was carried out wholly for business purposes and that it was necessary to travel from/to home rather than the University base. 
  • The commission costs of purchasing foreign currency required for business travel.
  • Costs associated with vaccinations and other necessary medical requirements, for business travel.
  • Expenses incurred when, for business purposes, it is appropriate to provide hospitality, including reasonable amounts of alcohol, for external customers or other important supporters of the University. [see also 3.9].
  • The cost of accessing an airport lounge where waiting time at an airport between connecting flights exceeds 4 hours.
  • The cost of gratuities/tips at a reasonable level, as specified within section 5.5 of this document.

 

3.3 What you cannot claim for?

Expenses which cannot be claimed include, but are not restricted to:

  • Hotel facilities which are not included in the standard cost of the hotel, e.g. spa treatments, mini bar contents, pay per view movies.
  • Any penalties or fines that an employee incurs during travel e.g speeding or parking fines or excess luggage weight.
  • The cost of any alcohol included within a subsistence claim, other than as part of hospitality for business purposes with an external person (non Abertay University employee).
  • The cost of meals, etc. which are included in accommodations costs or conference fees.
  • Over the counter medication (pain relief, cough medicines etc.). Such medication is deemed to be inherently personal in nature and not uniquely associated with business travel.
  • Annual membership of airport lounges.
  • Passport renewal fees.

 

3.4 Submitting a Claim

Post Travel - To claim reimbursement of expenses you must complete a Time and Expense Claim on the relevant portal, currently iTrent.  Claims for the reimbursement of expenses must be approved by your line manager.  The approver must check the claim and ensure all receipts are included.  Any subsequent changes to the claim must be reapproved by the approver. 

Time and Expense Claim relating to a trip must only be used for items which cannot be paid for in advance by the University.  All other purchases must follow normal University purchasing procedures.

 

3.5 Timing of Submission of Claims

You should submit any claims to the Finance Department within one month of your return to the University.  Claims submitted thereafter may not be accepted.

 

3.6  Payment of Claims

Expense claims will be paid along with your salary on the last working day of each month by Finance directly into your bank account.  Payment of any claims will be detailed on your wage slip. 

 

3.7 Receipts

All claims should be supported by receipts.  A receipt must identify:

  • The date of purchase.
  • The vendor name.
  • Itemised list and unit price of the purchased items.
  • The total amount paid.
  • VAT number (where applicable).

If you do not attach a receipt, this may mean that the item is disallowed from the claim or may require to be subjected to employment taxation.  A credit/debit card slip may not be accepted as a receipt, see 3.8 for exemption.

 

3.8  Claims without receipts

As noted above all claims are required to be supported by a receipt, however it is recognised that there may be instances where this is not possible or not required, these instances are:

  • If you are unable to obtain a receipt for an item of expenditure, such as a taxi fare in a non-English-speaking country, or
  • If you are to use a credit/debit card as a means of payment, such as London Underground, Edinburgh trams – In this instance a screenshot of payment could be used as evidence.
  • Where external funding providers do not require receipts to be submitted. – If you are unclear whether this applies, please check with relevant senior managers in advance of any purchases.

              

3.9  Claims for business-related hospitality for external guests

For claims related to the provision of business-related hospitality, the following information (as required by HMRC) must be shown on the claim form:

  • The names of the attendee(s).
  • The organisation which they represent.
  • The purpose of the entertainment (e.g. entertaining visiting speaker).

Wherever practicable, hospitality should be provided using existing University Facilitates.

 

3.10 Claims for subsistence

Subsistence covers the cost of meals/drinks (other than those which fall within the definition of business-related hospitality – see above), consumed while away on university business.  You should provide original receipts for all claims and those receipts should identify:

  • The date of purchase.
  • The vendor’s name.
  • An itemised list and unit price of the purchased items.
  • The total amount paid.
  • The VAT number (where applicable).

 

3.11 Claims for more than 1 Traveller

Ordinarily you should only claim travel costs for yourself. Where a claim is made for multiple people, all others including designation should be listed.

 

3.12 Partner’s travel and subsistence

If you travel on business with your partner, the University will normally only reimburse expenses which you yourself incur.  However, where a traveller  has support needs, e.g. related to health or disability, such that would be unreasonable  to expect them to travel alone, (early approval must be sought from a senior manager and Finance should be notified in advance) their spouse/partner can claim expenses as detailed in this policy to accompany the traveller on their business trip with a supporting statement from their GP or consultant.

 

3.13 Personal Visits

It is not uncommon for travellers to want to extend a trip for personal reasons. In these circumstances, this must be clearly indicated on the approval form. If you intend to do this, for comparison purposes, you must obtain a baseline price for what the travel would cost without the personal element. In the event of the actual travel booked costing more than the baseline price, the excess cost will be recovered from you. The University will only meet those costs which are wholly and necessarily incurred in respect of the business element of the trip.

 

3.14 Loyalty Schemes

Any air miles or other loyalty points accumulated through University business travel belong to the University and should be applied to subsequent University business travel.

 

3.15 Trading of Travel Tickets

The University expects you to utilise the cheapest fare available. Trading of airline or other travel tickets is forbidden. It would be considered a disciplinary manner if you were to raise an order for a flight at a higher price and subsequently attempt to trade that ticket to obtain cash and to travel on a cheaper ticket booked by yourself.

 

3.16 Reimbursement of Travel Claims- Responsibility of Claimants and Authorisers

The primary responsibility for compliance with this process rests with the individuals requesting reimbursement for the business expense and those who are approving them.

4. Rules applying to Claims and Responsibilities of Claimant and Approver

4.1 General

This section of the guidance sets out the rules applying to claims whether that be via use of a corporate card or submitting an expenses claim, where appropriate, to the procedures described in the preceding sections.

This guidance applies to all University employees, and where appropriate to students and all others engaged in University business who incur expenses which the University has agreed to reimburse. It applies to all expenditure, incurred by the University, or on behalf of the University, irrespective of the source of funding.

In the interests of value for money and the appropriate use of public funds, you are expected to be prudent in your spending, and those authorising claims are required to be diligent in their review and approval of expenses. You must therefore ensure that economy, efficiency and effectiveness are achieved in respect of all expenses incurred whilst undertaking University business.

Under the rules laid down within the University’s Financial Regulations, University employees and all others engaged in University business will be reimbursed for the actual cost of expenses incurred that are wholly, exclusively and necessarily in the performance of University business.

If you submit, or attempt to submit a false claim, or to make a claim covered by reimbursement elsewhere, this will be treated as a serious disciplinary offence. You should be aware that travel and expense claims are potentially disclosable under the Freedom of Information Act.

In cases where there is a discrepancy between the terms of this guidance and the conditions of funding from a Research / External sponsor, then the more restrictive policy will apply.

 

4.2 Specific Rules

Personal Incidental Expenses - You can be reimbursed for certain expenses which arise as a consequence of working away from home, but which are not incurred in the performance of work duties - for instance: laundry (applies only to long trips where items are required during the trip); or WiFi access. An HMRC exemption allows the University to reimburse these personal incidental expenses up to a certain limit (see Annex) without deduction of tax. If the allowed expenses exceed the maxima the whole claim becomes taxable.

You should provide details of actual expenses incurred on via iTrent and you should provide receipts where possible.

 

4.3 Your responsibilities as a claimant

As a claimant, you must be familiar with this process and supporting policies in order to ensure compliance and to ensure prudent spending of the University’s funds. If you are claiming expenses to be charged to a sponsored project, you must also be familiar with the particular expense conditions of that project. You are responsible for obtaining all proper documentation for each expense.

Typically, this documentation will be a receipt that identifies the expense and reflects proof of payment. And you are also responsible for adequately documenting the business purpose for each expense (i.e. what / when / why / where). (Although the business purpose of an expense may be obvious to the claimant, it may not be to the expense authoriser or 3rd party reviewer).

When submitting the claim form, you are declaring that:

  • To the best of your knowledge, the expense is compliant with this process and supporting policies and if the expense is to be charged to a sponsored award, that the expense is compliant with all sponsor requirements / regulations.
  • Expenditure has actually been incurred and not previously claimed from the University or any other organisation (or will be in the future).
  • Expenditure claimed has been incurred wholly, exclusively and necessarily in the performance of your duties of employment.
  • No part of the claim relates to personal expenses or private business activities.

 

Responsibilities of the claim approver if you are approving the claim, you must only do so if you are satisfied that:

  • The expenses claimed represent a valid business expense in line with this process and supporting policies and that it represents appropriate use of University or grant funds.
  • An adequate description of the expense is provided (what / when / why / where).
  • An appropriate account code is present for each expense item being claimed.
  • There is sufficient budget to cover the claim.
  • The claim is properly dated and signed by the Claimant.
  • Receipts are provided for all expenditure claimed which identifies the expense and provides proof of payment.

When approving the claim form, you are declaring that to the best of your knowledge, the claim is in compliance with this process and supporting policies, or if the claim is to be charged to a sponsored project, that the claim is also in compliance with all sponsor requirements / regulations.

If in doubt over a claim, or part of a claim, you should contact Finance for further guidance before approving the claim. Any subsequent query on a particular claim from the University’s Auditors (internal or external) or any other regulatory body will be referred, in the first instance, to you.

5. Acceptance of Hospitality and Gifts

The section of the guidance seeks to protect employees from allegations of impropriety by ensuring the acceptance or provision of gifts, hospitality or any other benefits (perceived or otherwise) is transparent and that appropriate approval and recording procedures are in place.

The acceptance of gifts, excessive or premium hospitality or other benefits can damage the University’s reputation and possibly lead to contravention of the Bribery Act 2010.  The Financial Regulations require staff of the university to declare gifts and hospitality offered or received unless they are of nominal value. 

Some roles require individuals to spend time with other organisations where it may be normal business practice or social convention to give and receive gifts or hospitality.  This can often place individuals in a difficult position; where refusal may cause misunderstanding or offence; however, to accept may give rise to questions of impropriety or conflicts of interest.  This section sets out the procedures to be followed with the aim of supporting employees maintain a high standard of propriety and professionalism and help protect individuals from accusations of impropriety.

 

5.1 Principles

The University expects employees to exercise the utmost discretion in giving and accepting gifts, hospitality or any other benefit.  Conduct of employees must not create suspicion or any conflict between their official duties, nor should they make use of their official position to further their private interests or those of others.  Particular care must be exercised where a gift, hospitality or benefit is given or offered by a person or organisation that has, or is hoping to have, a contract with the University.

Employees must not accept gifts, hospitality, or benefits of any kind from a third party where it might be perceived that their personal integrity is being compromised, or that the University might be placed under an obligation.  Employees should not accept any gift or considerations from another organisation, individual or member of the public which might reasonably be thought of as an inducement or be interpreted as an inducement or reward for doing or refraining from doing anything in their official capacity as a member of the university.

No improper advantage, favour or preference which is not generally available should be sought, accepted, or given.

Any gift, hospitality or other benefit received or given should be made openly, be fully documented, and reported appropriately to a senior manager, Director of FICS, and copied to admin support.

 

5.2 Receipt of Gifts

Gifts are anything given to someone, without the expectation of consideration or value in return.  Gifts can be in the form of money, goods, services or favours.

All offers of gifts, other than those of a very low intrinsic value (such as business diaries, calendars, pens, etc) should be declined and be reported in writing to a senior manager or nominee.  Where it is clear that declining gifts would damage the University’s business, cause offence (for example in countries that have a culture of giving to visitors), or where it is not possible to return the gift, the item should be declared to the Director of Finance, Infrastructure, and Corporate Services or nominee for determination of action.  Action may include making it available for general use by the staff of the school/department or adding the item to the school/department’s inventory.  If there is any doubt as to whether the acceptance of any item is appropriate, then the gift should either be declined, or the matter referred to a senior manager.    You should immediately report to your line manager any overt or covert offer of any gift or hospitality or other inducement which might give rise to accusations of impropriety.

Gifts of money or gift tokens must always be refused.  Any individual or organisation wishing to make donations to the University should be referred to the Stewardship and Engagement Manager.

Gifts offered to employees for members of their immediate family, relatives and friends should not be accepted.  Where gifts are offered by business associates of the University e.g employees of suppliers of goods or services who are also personal friends (or relatives), it may be reasonable to accept and declare the gift provided the principles contained within this process and supporting policies are not compromised.

Gifts offered to individuals or organisations on behalf of the University should be modest in value and appropriate to the occasion.  Permission should be sought from a senior manager or nominee before purchasing and giving the gift.

Under no circumstance should gifts or hospitality be accepted from individuals or organisations that are currently tendering or are about to tender for any contract from the University.

 

5.3 Acceptance of Hospitality

Acceptance of hospitality, provided it is reasonable in the circumstances, is allowable.  This may include meals at events such as breakfast seminars, working lunches, conferences, out of office lunches and other business meals paid for by a third party, and does not include any form of premium hospitality, e.g expensive entertainment, sporting events, luxury meals, accommodation or services.

Particular attention should be paid to circumstances where hospitality is offered to staff involved in any aspect of the procurement process as this can create an actual or perceived conflict of interest.  Advice should be sought from a senior manager in such cases.

It is recognised that the University conducts business internationally where it is customary in some cultures to offer relatively generous hospitality, and where offence would be given by rejection.  In these cases, and where an immediate decision is necessary, staff may accept the hospitality.  However, this must be declared to a senior manager or nominee on return.  The benchmark for assessing “generous hospitality” is anything in excess of what would be deemed acceptable in the UK. (noted above in the first paragraph of this section).

 

5.4 Working lunches provided by the University

Any working lunches for staff meetings should be by approved in advance by the relevant senior manager. There should be a clear business need and the meeting should not mix social and business activities. Normal practice would be for any such meetings to have an agenda, for the organiser to produce a minute/note and for the expected duration of the meeting to be at least 5 hours.

In order to comply with HMRC rules, working lunches for employees can only be claimed when lunch is consumed on university premises and is considered light (i.e. sandwiches / crisps / biscuits / soft drinks).  It must also be taken in the place where the meeting is held (i.e. a break in the meeting).  If you are responsible for arranging refreshments, supplied by the University internal facilities, in connection with a meeting or training event which is longer than 5 hours and carries on though the normal lunch break, you should ensure that the total costs are modest.

Working lunches must be sourced through Abertay’s internal facilities, and only if the internal catering provision does not have capacity may it be purchased elsewhere.  A senior manager must pre-approve external catering with supporting paperwork from the internal catering facility to verify that no capacity is available to cater for the working lunch.

It is the university’s policy that alcohol should not normally be consumed within normal working hours.  In support of this, the university will not reimburse the cost of any alcohol included within a lunchtime subsistence expense claim except in exceptional circumstances and with the prior authorisation of a senior manager.  Corporate cards should not be used to purchase alcohol for consumption during normal working hours and neither should this type of spend be invoiced to the university.  Reimbursement for such claims will not be made and the matter will be raised with a senior manager.

 

5.5 Entertainment

Necessary costs of entertaining external business contacts will be reimbursed on production of receipts. 

There will be occasions when it is appropriate to provide catering to visitors from outwith the university utilising restaurant facilities, rather than internal university resources.  In such cases the university will reimburse the costs involved including the cost of gratuities, up to a level of 10% of the total bill (15% in the USA).  However, in such cases the level of expense must be proportionate with the nature of the related business activity.

Employees in attendance must be proportionate with the number of visitors.  The University regards a maximum ratio of 3 university employees to every 1 visitor when entertaining business contacts to be proportionate for these purposes. 

Please follow the details noted above for claiming reimbursement or using a Corporate card.  Should the University be invoiced directly, the same details required for claiming must also be included on the invoice (Names of all those in attendance, their organisation, and the purpose of the meeting).  For the avoidance of doubt, all entertainment expenditure must be authorised by a senior manager before it is incurred. 

 

Annex 1 Rates payable for travel and subsistence

Rates payable for travel and subsistence (as of 1 August 2024) The below rates are a guide to what is deemed an acceptable rate, if however, the expense is likely to be in excess of the guided rate, please seek approval in advance from your senior manager.

Accommodation

Location Guidance rate per night (room only)
London £160
Rest of UK £100
Overseas £120 - £200

Subsistence

Circumstances Guidance amount claimable
More than 10 miles from home and normal place of work and absent from each for at least 5 hours spanning over a lunch break £10
More than 10 miles away from home and normal place of work and for at least 10 hours £20

Staying with a friend

Amount claimable
£30 for a single night, or £60 per trip

Personal Incidental Expenses

Circumstances Guidance rate per night
Overnight stay in UK £5
Overnight stay outside the UK £10

Mileage Rates

Vehicle First 10,000 business miles
Car/Van 45p
Motor Cycle 24p
Bicycle 20p

 

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