The fight against fraud and corruption in the context of management integrity
Pompeu Fabra University is adopting this Management Integrity Measures Plan within the context of its integrity policy with the aim of preventing and combating fraud and corruption. The Plan is intended, on the one hand, as a means of continuing and strengthening both a set of actions the university has already taken over the years and a series of procedures it already has in place. On the other hand, and with a view to appropriately and specifically addressing the risks of fraud present in any complex organization, the Plan also provides for the adoption of new measures. First, it establishes new, more systematically organized and regularly executed procedures (e.g. the requirement for the parties most closely involved in certain economic or procurement processes to sign an express Declaration of Absence of Conflict of Interest (DACI)). Second, it creates a new body, the Anti-Fraud Committee, tasked with promoting and monitoring the adopted measures, from prevention to the investigation of any type of conduct that might involve fraud or corruption. In the current context resulting from the Covid-19 crisis, the adoption of such a plan is moreover timely in terms of Regulation (EU) 2021/241 of the European Parliament and of the Council, of 12 February 2021, establishing the Recovery and Resilience Facility, and Spanish Order HFP/1031/2021, of 29 September 2021, establishing the management system for the Recovery, Transformation and Resilience Plan. Under both regulatory instruments, any funds received in this context must be appropriately managed in compliance with all applicable rules, in particular those concerning the prevention of fraud, corruption and conflicts of interest.
The Code of Ethics and guarantee mechanisms
In keeping with the aforementioned continuity, it should be noted, first, that the university already adopted a Code of Ethics in 2012, which established a set of principles that went beyond the fight against fraud and corruption insofar as they promoted ethical conduct by all members of the community. This Code was recently reviewed and a new version was approved in 2020, reinforced with guarantee mechanisms, such as the creation of an Integrity Committee and the implementation of an Ethics Hotline as a reporting channel for the purposes of Directive (EU) 2019/1937 of the European Parliament and of the Council, of 23 October 2019, on the protection of persons who report breaches of Union law. Already having such a channel in place, which ensures users’ anonymity, is undoubtedly a powerful guarantee that should help remove possibilities for generating any sort of fraud. Three of the principles included in the Code of Ethics – all of which were already present in the initial 2012 version – are particularly important in the context of preventing fraud: honesty, equality and responsibility. Honesty is essential in both the management of public funds by university officials and in the use made of university resources by students who occupy places in courses in high demand. The principle of equality is, needless to say, fundamental and has a clear impact on many of the processes managed by the university, especially in relation to procurement and ensuring free competition. As for responsibility, the Code of Ethics extends it to all three of the university community’s main component groups (teaching and research staff, administrative and service staff, and students) in all the activities they carry out at the university, emphasizing the need for transparency, objectivity, merit and ability and to avoid conflicts of interest. Finally, the Code of Ethics stresses transparency, which should also be understood as a mechanism for accountability and a guarantee that helps prevent fraud.
The values of the 2016-2025 Strategic Plan
Shortly after the Code of Ethics was drawn up, UPF also approved the 2016-2025 Strategic Plan. This Plan aimed to associate the institution’s identity with a set of essential values intended to establish it as a distinct ethical community in the increasingly global context of higher education institutions. Some of the values identified in the Strategic Plan, which is still in force today, were commitment, fairness, rigour and accountability, all of which are quite relevant to establishing UPF as an institution fully committed to practicing and promoting public integrity.
The Transparency, Integrity and Compliance Strategy (Projecte ÈTIC)
Subsequently, in September 2017, the UPF Board of Management approved the Transparency, Integrity and Compliance Strategy – also known as Projecte ÈTIC from the Catalan – which implements actions in the three closely interconnected areas for which it is named. With regard to transparency, Projecte ÈTIC has enabled progress on improving the UPF Transparency Portal, with positive external evaluations; a Transparency Advisory Board has been set up as a consultative and participation body; and a new circuit has been established for processing requests submitted in exercise of the right of access to public information. As for integrity, as noted, the 2012 Code of Ethics has been reviewed and a new, clearer Code adopted, reinforced with the aforementioned monitoring and review guarantees (Integrity Committee and Ethics Hotline). In this regard, on 28 September 2021[MHO1] , UPF also formally joined the Barcelona City Council’s Ethical and Good Governance Mailbox initiative as part of a framework protocol for cooperation with the Institute for Democratic Culture in the Digital Era to disseminate and strengthen the Mailbox as a reporting channel paradigm that guarantees confidentiality and anonymity for whistle-blowers and a pioneering tool in the fight against fraud and corruption. Under the protocol, UPF undertook to work for the benefit of the network of cities and government agencies that use the tool and, thus, to promote this network for transparency and good governance at multiple levels and advocate for the culture of good governance and transparency in public management, whilst also protecting the anonymity of corruption whistle-blowers and combating abuses that harm the general interest, as envisioned by the aforementioned Mailbox initiative. Finally, in terms of compliance, an external risk assessment was conducted in the area of personal data protection, and many of the improvement measures to emerge from the resulting diagnosis have begun to be implemented. Specifically, the present Plan aims to extend the risk assessment to all the university’s activities, with special emphasis on those susceptible to generating situations that could lead to fraud and corruption, i.e. those related to procurement, aid and other aspects of financial management, drawing on the experience of applying measures, for example, in public procurement for projects co-funded by the European Union and the risk assessments performed in that area.
The Plan as an institutional commitment to combat fraud and corruption
UPF wants to be a place free of fraud and corruption. That is why it is adopting this Management Integrity Measures Plan, intended to prevent and combat fraud and corruption at Pompeu Fabra University, which begins with an explicit statement of institutional commitment in this area by the university’s highest governing body. The Plan is structured around the four elements or stages that make up the cycle of the fight against fraud and corruption: prevention, detection, remedial action and monitoring or investigation. In terms of prevention, attention should be called to the importance of promoting the principles contained in the Code of Ethics and the institution’s commitment to public integrity; performing a risk assessment; training all staff at all levels of the organization; and carrying out information campaigns targeted at the entire university community. Furthermore, as an instrument for preventing and avoiding conflicts of interest, the Plan also includes, in Annex 1, a ‘Model Declaration of Absence of Conflict of Interest (DACI)’ quite similar to that provided for under the aforementioned Order HFP/1030/2021, which must be signed both by the public employees responsible for management, verification and payment tasks and private recipients, partners, contractors and subcontractors. With regard to detection, the Plan envisages the use of the Ethics Hotline as a reporting tool (including the possibility of anonymous reporting) and the promotion of transparency. In terms of remedial action, it creates a new body, the Anti-Fraud Committee, to be made up of the university officials responsible for key aspects due to their possible impact on fraud and corruption issues, i.e. those responsible for areas such as transparency, integrity, economic management, budgets or legal advice. The Rules of Procedure for this Committee have been approved together with this Plan and are included in Annex 2. Finally, monitoring will take the form of the preparation of an assessment report by the new Anti-Fraud Committee, the investigation of any complaints and the adoption of the corresponding measures in each case. The Plan concludes by providing for this assessment and listing the main indicators to be taken into account in performing it.
A.Pompeu Fabra University’s institutional commitment to combating fraud and corruption
(1)Commitment against fraud in the context of public integrity
As a public university that, through its Code of Ethics, has adopted the highest ethical standards, Pompeu Fabra University is committed to the proper use of public funds and the fight against fraud and corruption.
(2)The Management Integrity Measures Plan as a tool for combating fraud and corruption
a. Pompeu Fabra University is adopting the set of measures defined in this Plan as a tool for combating fraud and corruption and preventing or managing potential conflicts of interest.
b. UPF assumes the definitions of conflict of interest, fraud and corruption adopted by the European Union, in particular, as established in Regulation (EU, Euratom) 2018/1046 of the European Parliament and of the Council, of 18 July 2018, on the financial rules applicable to the general budget of the Union (EU Financial Regulation), and Directive (EU) 2017/1371 of the European Parliament and of the Council, of 5 July 2017, on the fight against fraud to the Union’s financial interest by means of criminal law.
(1)PM1. Promotion of the principles included in the Code of Ethics
The university, acting through the Integrity Committee, will periodically carry out actions to disseminate the principles set out in the Code of Ethics and promote public integrity amongst all members of the university community.
(2)PM2. Risk assessment
a. The university will periodically review and assess the risks of fraud and corruption that might arise in its activity as a result of the actions of its staff in the performance of their duties.
b. This risk assessment, which must make it possible to detect the most sensitive points susceptible to generating fraud or corruption, will be conducted internally by the university, with the involvement of staff from all categories and, especially, those staff with the deepest knowledge of the most critical processes.
(3)PM3. Staff training
a. The university will schedule training actions for all its staff on preventing fraud and corruption.
b. The university will periodically schedule practical training actions on budget accounting and public procurement adapted to UPF’s tools and aimed at the staff who use them.
c. The university will schedule training actions, aimed at staff who receive bids and participate in the study of proposals, on detecting the signs of tender manipulation flagged by fair competition bodies.
d. Staff who have to sign a Declaration of Absence of Conflict of Interest (DACI) must complete at least one compulsory training course on this subject, preferably prior to signing the DACI and, in any case, within one year of signing it.
(4)PM4. Information and advice for the university community on matters of fraud and corruption
a. The university will promote information tools, aimed at the university community as a whole, to foster knowledge of the types of conducts that can facilitate fraud and corruption and the various scenarios in which a conflict of interest may arise and the ways to avoid it.
b. The university will periodically carry out information and awareness-raising campaigns to promote the prevention of conduct that could facilitate situations of fraud, corruption or conflict of interest.
c. The university will ensure that all academic and administrative units are advised on combating fraud and corruption by means of both internal and external mechanisms. In particular, in the processing of small contracts, it is necessary to disseminate the Guide for Drafting Memoranda of Justification. These memoranda must include: a precise definition of the needs to be met; a description of the recipients of the services to be contracted; and a justification of the suitability of the contracted services to meet the stated needs. Furthermore, they must refrain from justifying the tender simply by citing a lack of or insufficient means, etc.
d. The university will specifically facilitate online access to and consultation of the rules for preventing and combating fraud and corruption.
(5)PM5. Conflict of interest
a. Persons involved in public procurement or grant award processes must sign a Declaration of Absence of Conflict of Interest (DACI). This includes the head of the contracting/awarding authority, the staff responsible for drafting the tender documents/rules and calls, any experts involved in evaluating the applications/bids/proposals, the members of application/bid/proposal evaluation committees, and the members of any other collective decision-making bodies involved in the process. In the case of collective decision-making bodies, all parties involved may make this declaration at the start of the meeting, in which case it will be recorded in the corresponding meeting minutes. Likewise, those recipients who, under the requirements for a grant, have to carry out activities that pose a potential conflict of interest must sign the DACI. The managing unit must include the DACIs in the corresponding files.
The model DACI to be signed by these persons is included as Annex 1 of this Plan.
b. The university must ensure strict compliance with the corresponding regulations, including, in particular, the following precepts:
- Chapter VI, Title III, entitled ‘Duties of public employees: Code of Conduct’, of the Spanish Basic Statute of Public Employees Act, i.e. Articles 52 (Duties of public employees: Code of Conduct), 53 (Ethical principles) and 54 (Principles of conduct).
- Spanish Law 19/2014, of 29 December 2014, on transparency, access to public information and good governance.
- Catalan Decree 8/2021, of 9 February 2021, on transparency and the right of access to public information.
- Article 23 of Spanish Law 40/2015, of 1 October 2015, on the legal regime governing the public sector, concerning abstention.
- Article 64 of Spanish Law 9/2017, of 8 November 2017, on public contracts, transposing into Spanish law Directives 2014/23/EU and 2014/24/EU of the European Parliament and of the Council, of 26 February 2014.
c. The university will communicate and inform all staff of the obligation to sign a DACI in the event of participating in a process that so requires, as well as of the basic content thereof and of any modifications made to it.
(6)PM6. Management planning measures
The university will define the appropriate profiles for each position, including the knowledge and skills required, especially as regards budget accounting and public procurement, for the performance of the corresponding duties.
The university will plan its contracts sufficiently in advance, endeavouring to avoid the award of urgent contracts and justifying, in sufficient detail, the use of the exceptional procedures provided for by law. Likewise, the planning must allow them to be tendered through open procedures rather than unadvertised negotiated ones so as to foster competition.
The university must generalize preliminary market consultations in contracts with an estimated value of more than €50,000.00, which must be carried out transparently, so that any interested company can participate, making any information exchanged through such consultations public, safeguarding any technical or commercial information that potential bidders designate as confidential.
In the case of recurring purchases, the use of the framework agreements or dynamic purchasing systems provided for under the law must be encouraged.
(1)DM1. Use of the UPF Ethics Hotline
a. The UPF Ethics Hotline, a reporting channel open to the university community and the public at large that affords the maximum guarantees for the protection of whistle-blowers in accordance with Directive 2019/1937, may receive and process reports concerning situations of fraud, corruption or conflicts of interest.
b. As the body responsible for supervising the UPF Ethics Hotline, the Integrity Committee may transfer to the Anti-Fraud Committee, at any time during the processing of such reports, those aspects of the report received containing indications of fraud, corruption or conflicts of interest, so that the latter can study it and take the corresponding measures.
c. In order to ensure full transparency, tender specifications, bidder profiles and guidelines for applying for grants must include the address of the UPF Ethics Hotline, as well as a description of how it works and its guarantees.
(2)DM2. Procurement measures
a. The university will create the position of ‘public procurement officer’, responsible for supervising and advising the contracting units on technical requirements, solvency and award criteria adapted to specific needs, and the detection of situations of potential fraud or corruption.
b. The university will promote use and knowledge of the Guide for Drafting Memoranda of Justification, which establishes the need to: (i) indicate the reasons for the choice of award criteria and how they will make it possible to evaluate bids in such a way as to ensure that the best offer is obtained; (ii) clearly define the weighting assigned to each award criterion and the evaluation rules to be applied, so that all bidders know the evaluation method to be used when preparing their bids; and (iii) clearly define the proportionality between the solvency conditions and the subject matter of the contract.
c. In order to ensure proper use, the Administrative Procurement Unit will be tasked with the regular monitoring of small contracts by means of setting up computer alerts or appointing a specific body for this purpose.
d. For contracts with an estimated value of more than €500,000.00, the public procurement officer or corresponding person in charge must carry out an economic study that justifies the cost calculation in detail, indicating the methods used to determine it. In all other cases, the public procurement officer will supervise the memorandum of justification for the tender, in which the contracting unit must detail the calculation of the contract costs. In all files, the public procurement officer will analyse and suggest, where appropriate, specific parameters and values that make it possible to assess the abnormal or disproportional nature of any bids.
e. Any incidents that may arise during the performance of the contract or from the agreed circumstances (improvements, special conditions for performance, etc.) must be recorded in the file, by means of the final report for the contract signed by the contract manager.
f. In order to ensure objectivity and transparency in the evaluation of bids, the university will ensure the appointment of staff specialized in the subject matter of the contract amongst the committee members.
(3)DM3[K2] . Measures in the area of economic management
a. A review must be conducted of a sample of the products obtained and their costs in order to assess whether the work has been delivered and ensure that no unnecessary expenses have been incurred.
b. The Budget and Finance Service will be tasked with regularly monitoring accounting and expenditure management.
c. A body must be designated to carry out sampling checks in order to detect whether a service other than that contracted has been received.
(1)RM1. Creation of the UPF Anti-Fraud Committee
a. The university will have an Anti-Fraud Committee, specialized in combating fraud and corruption, that also helps prevent conflicts of interest that might arise in connection with the institution’s activity. The Anti-Fraud Committee may conduct its activities in the areas of prevention, detection, remedial action and monitoring.
b. The Anti-Fraud Committee’s members must include UPF officials with knowledge of the areas most closely linked to the adoption of measures to prevent, detect, remedy or prosecute situations of fraud, corruption or conflicts of interest.
c. Cases of fraud identified by the Anti-Fraud Committee will be referred to the rector to be reported to the Spanish National Anti-Fraud Coordination Service and the Catalan Anti-Fraud Office.
(2)RM2. Control instruments
a. In order to detect whether a service or good other than the one contracted may have been obtained and, where applicable, to take the appropriate remedial measures, a body will be designated to perform sample checks.
b. Pompeu Fabra University's annual account audit monitors the execution of the budget and reports on the results thereof, making observations and recommendations concerning those aspects considered to be in breach of the regulations.
(3)RM3. Enhancing transparency and good governance
a. UPF will adapt, within one year of the approval of this Plan, its Regulations for implementing legislation on transparency and the right of access to public information at Pompeu Fabra University to Catalan Decree 8/2021, of 9 February 2021, on transparency and the right of access to public information.
b. UPF will update, within one year of the approval of this Plan, its Regulations governing the Service Charter, approved by resolution of the Board of Governors of 4 April 2001, adapting it to the new legislation, in particular, Spanish Law 19/2014, of 29 December 2014, on transparency, access to public information and good governance.
E.Monitoring and prosecution measures
(1)MM1. Assessment report of the Plan by the UPF Anti-Fraud Committee
a. The Anti-Fraud Committee is responsible for assessing and monitoring this Management Integrity Measures Plan, to which end it will submit an annual report to the Board of Governors and the Board of Trustees.
b. The Anti-Fraud Committee will review the Management Integrity Measures Plan at least every two years.
(2)MM2. Monitoring mechanisms
a. Any situation susceptible to being considered fraud, corruption or a conflict of interest brought to the attention of the Anti-Fraud Committee must be studied and investigated. Where necessary, the Committee may propose the adoption of the appropriate precautionary and remedial measures, as well as the suspension of the affected procedures, where this has not already occurred.
b. The contracting authority must inform the competent competition authorities about any conduct by tenderers that it might detect, during the processing of the procurement files, that may have been intended to or had the effect of preventing, restricting or distorting competition.
(1)Party responsible for the assessment
The measures contained in this Plan will be assessed by means of indicators. The annual report to be submitted by the Anti-Fraud Committee to the Board of Governors and the Board of Trustees will include a section on the evolution of these indicators.
The following indicators will be used for the Plan’s assessment:
- Indicator PM1: Number and types of information actions to disseminate and promote the principles of the UPF Code of Ethics.
- Indicator PM2: Availability of the corresponding risk analysis report.
- Indicator PM3: Number and types of training courses scheduled and delivered and number of participants in the training courses.
- Indicator PM4: Number and types of information campaigns or actions on fraud and corruption.
- Indicator PM5: Number of DACIs signed.
- Indicator PM6: Number of tenders carried out by the university.
- Indicator PM7: Number of tenders carried out by the university by means of the urgent procedure.
- Indicator PM8: Number of tenders carried out by the university with an estimated value of more than €50,000.
- Indicator PM9: Number of tenders carried out by the university with an estimated value of more than €50,000 with a preliminary consultation.
- Indicator DM1: Number of reports received through the university’s Ethics Hotline referred to the Anti-Fraud Committee.
- Indicator RM1: Date of the Anti-Fraud Committee’s first meeting. Number of Anti-Fraud Committee meetings.
- Indicator MM1a: Date of submission of the Anti-Fraud Committee’s report.
- Indicator MM1b: Date and document of the Anti-Fraud Committee’s review of the Plan.
- Indicator MM2a: Number of investigations conducted by the Anti-Fraud Committee.
- Indicator MM2b: Number of reports made by the contracting authority to the competition authorities.
Annex 1. Model Declaration of Absence of Conflict of Interest (DACI)
In order to ensure impartiality in the aforementioned contracting/grant procedure, the undersigned, as a participant in the process of preparing and processing the file, hereby declares:
One. That s/he is aware of the following:
1. Under Article 61.3, ‘Conflict of interests’, of Regulation (EU, Euratom) 2018/1046 of the European Parliament and of the Council, of 18 July 2018 (EU Financial Regulation), a conflict of interest exists where the impartial and objective exercise of the functions of a financial actor or other person is compromised for reasons involving family, emotional life, political or national affinity, economic interest or any other direct or indirect personal interest.
2. [Applicable to procurement files only] Article 64 ‘Fight against corruption and prevention of conflicts of interest’, of Spanish Law 9/2017, of 8 November 2017, on Public Contracts, aims to prevent any distortion of competition and ensure transparency in the procedure and equal treatment of all candidates and tenderers. It defines ‘conflict of interest’ as any situation in which staff in the service of the contracting authority who are involved in carrying out the tender procedure or could influence its outcome have a direct or indirect financial, economic or personal interest that might appear to compromise their impartiality and independence in the context of the tender procedure.
3. Article 23, ‘Abstention’, of Law 40/2015, of 1 October 2015, on the legal regime governing the public sector, establishes that ‘authorities and staff in the service of public agencies to whom any of the circumstances indicated in the following section apply’ must refrain from taking part in the procedure. These circumstances are:
a)Having a personal interest in the matter in question or in another matter the resolution of which might be affected by the resolution of the matter in question; being a director of an interested company or entity; or having pending litigation with an interested party.
b)Having a marital bond or equivalent de facto situation or kinship within the fourth degree of consanguinity or second degree of affinity with any of the interested parties, with the directors of interested companies or entities, or with the advisors, legal representatives or agents involved in the procedure, as well as sharing a professional office or being associated therewith for the purpose of advice, representation or agency.
c)Close friendship or manifest enmity with any of the parties mentioned in the previous paragraph.
d)Having participated as an expert or witness in the process in question.
e)Having a service relationship with a natural or legal person directly interested in the matter, or having rendered professional services of any kind, in any circumstances and in any place to such a person in the last two years.
Two. That s/he is not in a situation that could be classified as a conflict of interest as defined in Article 61.3 of the EU Financial Regulation and that none of the grounds for abstention set out in Article 23.2 of Spanish Law 40/2015, of 1 October 2015, on the legal regime governing the public sector, that might affect the tender/award procedure apply to his or her person.
Three. That s/he undertakes to inform the contracting authority/awarding body, without delay, of any situation of conflict of interest or grounds for abstention that might arise.
Four. That s/he understands that a Declaration of Absence of Conflict of Interest that is shown to be false will entail the disciplinary/administrative/judicial consequences established in the applicable regulations.
Five. That s/he completed, on ........., the training provided by the university on preventing fraud and corruption. / That s/he is registered for the ......... edition of the training provided by the university on preventing fraud and corruption scheduled to be held on ........., and that s/he will include the certificate of attendance in the file upon completing it. / That s/he will register for the ......... edition of the training provided by the university on preventing fraud and corruption in order to complete it within a period of one year, and that s/he will include the certificate of attendance in the file once s/he has completed it.
(Date and signature, full name and identity document number)
Appendix 2. Rules of procedure for the Pompeu Fabra University Anti-Fraud Committee
Article 1. Creation of the Anti-Fraud Committee
The Pompeu Fabra University Anti-Fraud Committee has been set up within the framework of the Management Integrity Measures Plan as an instrument giving concrete form to the university’s commitment, as a public institution, to the fight against fraud and corruption.
Article 2. Composition of the Anti-Fraud Committee
1. The UPF Anti-Fraud Committee is made up of the secretary general, who chairs it; the general manager; the chair of the Economic Affairs Committee of the Board of Trustees; the chair of the Integrity Committee; the head of the Legal Counselling Service; and an officer from the Economic Resources, Recruitment and Property Area, who will be appointed by the chair and will act as secretary, in a non-voting, advisory capacity.
2. The Anti-Fraud Committee may invite other UPF or external officials, experts or individuals to participate in its meetings and work.
Article 3. Functions of the Anti-Fraud Committee
The UPF Anti-Fraud Committee has the following functions:
a)To promote the actions provided for in the Pompeu Fabra University Management Integrity Measures Plan, monitor and evaluate them, and review the Plan every two years.
b)To promote the adoption of best practices for preventing and combating fraud, favouritism and corruption at the university that help improve the quality of the services provided by UPF.
c)To investigate possible cases of irregular use or allocation of public funds.
d)To promote the adoption of measures to effectively prevent, detect and resolve any conflicts of interest that may arise, as well as conducts through which employees make private use of information to which they have access as a result of their professional duties.
e)To evaluate and propose the incorporation of integrated IT tools for data mining and data enrichment for identifying risks and conducting management verifications (such as ARACHNE) or of automated alert indicator systems.
f)To maintain an up-to-date list of the main risks to which the university is exposed.
g)To assess the effectiveness of the measures taken to prevent and combat fraud and corruption at the university and approve the modification thereof where necessary.
h)To prepare an annual report with the results of the Plan’s assessment.
i)To perform any other function assigned to it under the regulations or with which it is tasked by UPF’s governing bodies.
Article 4. Coordination and collaboration with other agents
The Anti-Fraud Committee shall coordinate with other UPF bodies and collaborate with the agents involved in the fight against fraud and corruption, in particular, the following bodies and organizations:
a) The Integrity Committee, especially in handling and investigating those reports reaching it through the Ethics Hotline concerning situations that could lead to fraud or corruption.
b) The UPF Ombuds Office, especially in relation to those complaints that might reveal the existence of some type of fraud or corruption.
c)The Catalan Anti-Fraud Office, in its actions concerning UPF.
Article 5. Frequency of meetings and adoption of resolutions
1. The Anti-Fraud Committee shall meet, in an ordinary session, at least once a year to assess the Management Integrity Measures Plan and approve the corresponding report.
2. In any case, it shall meet for an extraordinary session whenever a potentially fraudulent situation requiring its intervention arises or at the request of at least one third of its members.
3. The adoption of resolutions by and the operation of the Committee will be governed by the rules provided for in the Rules of Procedure for the Board of Governors.
Article 6. Investigation procedures
Investigation procedures shall have the following stages:
One. Analysis to determine whether the suspected fraud is admissible.
a) In the event of inadmissibility, a decision explaining the grounds for this inadmissibility shall be sent to the whistle-blower or complainant, who may appeal the decision before the rector.
b) In the event of admissibility, the Committee shall request information from the affected body, unit and/or persons and shall interview potential witnesses and/or third-party stakeholders about the reported facts receiving such internal and/or external advisory services as it deems fit. It will then issue a report, within in a maximum of 3 months from receipt of the report or complaint, which period may be extended on justified grounds for up to 2 additional months. This report shall be forwarded to the rector together with information on the actions taken.
Two. In view of the report, the rector will convey the result of the investigation to the whistle-blower or complainant and, where applicable, when the case has not been closed, to the Spanish National Anti-Fraud Coordination Service and the Catalan Anti-Fraud Office.
All statements, actions, document requests, reports and interviews will omit all data related to the identity of the whistle-blower or complainant, where known.
Sole final provision. Entry into force
These Rules of Procedure shall enter into force, once they have been approved by the Board of Governors, the day after their publication on UPF’s Seu Electrònic [online office].