WILDWOOD

PROPERTY
MANAGEMENT
COMPANY

CORPORATE FRAUD
POLICY 2019-2021

ACC-421 Auditing & Forensic Accounting

 WILDWOOD PROPERTY MANAGEMENT’S REPUTATION AS AN
ETHICAL COMPANY IS ONE OF OUR MOST VALUABLE ASSETS AND IS
CRITICAL TO OUR SUCCESS.
KEY ETHICAL PRINCIPLES OF OUR CODE OF CONDUCT THAT GUIDE OUR ACTIONS
• Integrity - our behavior, being honest, having clear, strong moral values and keeping our commitments.
• Objectivity - decisions based on facts, not on personal beliefs or feelings, should not allow bias, conflict of
interest or undue influence of others.
• Professional competence and due care - maintain a professional work environment and comply with
company policies. Treat customers, colleagues, and partners ethically at all times.
• Confidentiality - protection of confidential company information, and nonpublic information entrusted to
us by employees, customers and other business partners.
• Professional behavior - treat one another with fairness and dignity, conduct should meet high standards for
professionalism and integrity.
PURPOSE OF A FRAUD
POLICY

To provide a framework for all

Employees, including management, in
the prevention, detection, reporting
and management of fraud and
corruption in the workplace,
including within its partners, vendors
and clients.
BEGINS WITH YOU!
 TRAINING AND KEY TAKEAWAYS
• All employees trained annually on the Code
of Ethics and Conduct, supplemented by
additional online and in-person training
• Communications to provide guidance and
raise awareness on ethics and compliance
issues faced in the workplace.
• Training on the company’s approach to fraud
and corruption, how to recognize corrupt
practices, and the mechanisms available for
reporting corrupt activity
• Takeaways from training
• Types of fraud
• Red Flags and Controls - How to prevent
fraud or determine if fraud may be occurring
• How to spot behavior patterns and changes
in lifestyles that might indicate social pressure
to commit fraud
• The importance of reporting fraud,
corruption and illegal practices
TYPES OF FRAUD THAT CAN BE FOUND IN OUR BUSINESS

• Repair and maintenance billing • False expenses

• Theft by deception - individual uses false pretenses • Misuse if company assets
to gain control of someone’s property
• Alterations of financial or other records
• Embezzlement - theft or misappropriation of funds
• Misuse of computer records which includes
placed in one's trust or belonging to one's
manipulating programs or data
employer.
• Money laundering
• Housing Fraud
• Procurement fraud
• Kickbacks, false claims and bid rigging for
development of future projects • Corruption schemes - Conflicts of Interest,
Bribery, Economic Extortion
• Collection of rent
• Payroll and time sheet submission
• Payment of invoices from vendors and customers
• Deposit of revenues received
 RED FLAGS
IDENTIFYING RED FLAGS IS CRITICAL TO THE SUCCESS OF DETECTING AND PREVENTING FRAUD

• Significant change in lifestyle: New wealth

• Addiction:
• Gambling, drug addiction, infidelity
• Criminal background
• Chronic legal problems
• Dishonest behavior in general
• Beat the system: Break rules commonly
• Dissatisfaction with job

Essentials of Corporate Fraud, T L

Coenen, 2008, John Wiley & Sons
Statistics: ACFE
 Every employee needs to understand
what drives a person to fraudulent
FRAUD DETECTION AND activity.
RESPONSE POLICIES

• Fraud Committee will work with all

employees on how to mitigate any possible
fraud, identify suspected fraudulent activity as
well as communicate the policies relative to
response to suspected fraud Tips are the
• Investigation Committee oversees and leading
coordinates any and all investigations of detection of
suspected fraud, is responsible for all fraud.
evidentiary collection and documentation,
performs a full risk assessment
• Report on fraudulent activity and
investigations, results of investigations to be
given to the Board of Directors

2014 REPORT TO THE NATIONS ON OCCUPATIONAL FRAUD AND ABUSE

 CONTROLS AND
RESPONSIBILITIES
EMPLOYEE RESPONSIBILITIES
• Be aware of the importance of reporting fraud,
corruption and illegal practices
• Be aware of the mechanisms available for reporting
corrupt activity
• See something wrong, suspect fraudulent activity,
SAY SOMETHING
• Be vigilant and pro-active
• Use reporting hotlines if necessary, report
concerns to management, or a Fraud Committee
representative
MANAGEMENT RESPONSIBILITIES
• Supervision, policy enforcement, training and
communication
• Accounting & reconciliation procedures and
processes
• Surprise audits by Internal Audit
• Listen to concerns from employees about
fraudulent behavior – do not dismiss it as being a
challenge to authority or a threat
• Lead by example
 BENEFITS, COSTS AND CONCLUSION

With occupational fraud incidence on the rise in both number and frequency, it is imperative for Wildwood
Property Management to implement fraud policies. The financial loss, reputation being damaged, and the loss of
our customers trust is very serious and could lead to the failure of the company. The Fraud Policy is beneficial to
the company and will assist us in detecting and preventing fraud. Not implementing a Fraud Policy is more costly
to Wildwood Property Management than having one in place.

Wildwood Property Management must have fraud awareness and prevention policies in place to help in averting
losses that come with the commission of a fraudulent activity. Our stakeholders (homeowners, investors, and
shareholders rely on us to manage their properties. We must ensure compliance from all employees, including
management, board of directors and others that do business with us as vendors and suppliers.

As Frank L. Varanavage, CPA and Certified Fraud Examiner said “Fraud can blindside a company and it can come
from any direction. When it comes to fraud, there is no prejudice. It can be large or small, external or internal. It
can come from a high-level executive or from low level staff. It can be a brand-new hire, or an employee who has
worked for the company for several years.”
 RESOURCES
• Essentials of Corporate Fraud, T L Coenen, John Wiley & Sons, 2008

• Tommie W. Singleton, A. J. (2010). Fraud Triangle. In A. J. Tommie W.Singleton, Fraud Auditing and Forensic Accounting
Hoboken: John Wiley & Sons, Inc

• John Bendermacher, C. R. (2017). Global Perspectives and Insights Volume 8. The Institute of Internal Auditors, Inc.
Retrieved from https://na.theiia.org/periodicals/Public%20Documents/GPI-Distinctive-Roles-in-Organizational-
Governance.pdf

• Frank L. Varanavage, C. C. (2018, February 13). Fraud Prevention – Do You Have the Right Policies in Place? Kreischer
Miller: https://www.kmco.com/resource-center/article/leading-edge/fraud-prevention-do-you-have-the-right-policies-in-
place/

• Fraud. (n.d). Retrieved from Legal Dictionary: https://legaldictionary.net/fraud/

• The Three Line of Defense Retrieved from https://na.theiia.org/standards-

guidance/Public%20Documents/PP%20The%20Three%20Lines%20of%20Defense%20in%20Effective%20Risk%20Manage
ment%20and%20Control.pdf

• RTTN Retrieved from https://www.acfe.com/rttn/docs/2014-report-to-nations.pdf

• Jim Oakes, CFE, CFCI https://www.fraud-magazine.com/article.aspx?id=4294986384