Course F-301

Auditing

A STUDY ON THE
‘TYCO’ SCANDAL
2002
DEPARTMENT OF FINANCE
FACULTY OF BUSINESS STUDIES
UNIVERSITY OF DHAKA

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Accounting Fraud: A Study on
The ‘Tyco’ Scandal in 2002

Prepared for

Prepared by

BBA 26th Batch

Section: C
Department of Finance
Faculty of Business Studies
Universities of Dhaka

Submission Date
Thursday, December 18, 2022

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 Group Details
Group 03 (Section: C)
BBA 26th Batch
Department of Finance
Faculty of Business Studies
Universities of Dhaka

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 iii

Letter of Transmittal

December 18, 2022

Muhammad Farid Hossain Patwary

Lecturer
Department of Finance
University of Dhaka

Honorable Teacher:

Subject: Submission of the report on ‘Tyco’ Scandal

In response to the task assigned to us, the undersigned student of the BBA 26th (C) batch has
prepared the term paper of course F-301. We have used our knowledge and learning from the
classes we attended online & offline of the respective course. We tried our level best for
preparing this report. This report helped us gain more insight and knowledge on auditing & past
accounting scandals & its preventive measures.
We would be very grateful if you give your advice on our effort.

Sincerely yours,
Department of Finance
Faculty of Business Studies
University of Dhaka
On behalf of the members of the Group 03

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 Acknowledgement
It is a great honour for us, group 03, to submit this term paper to our respected course teacher,
Muhammad Farid Hossain Patwary, Lecturer, Department of Finance, Faculty of Business
Studies, University of Dhaka. We express our gratitude for assigning us to prepare the term
paper. We couldn’t have completed the term paper without guidance from our course teacher
because we faced several practical challenges. But appropriate guidance and direction by our
course teacher helped us avoid them greatly. All of the efforts ended at the desired point of the
cooperation and hard work, sincerity and seriousness of our group members. So, all of them as
well as our group members deserve a pure compliment. This is a great opportunity for us to make
a report on a topic that we have just learned which will help us to reinforce our learning. We
hope that the experience from making the term paper will help us to pursue our goal in the near
future. We also hope we will be able to learn more about the various managerial aspects through
our future courses and research opportunities.

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 Table of Contents
Letter of Transmittal...................................................................................................................................iv
Acknowledgement......................................................................................................................................v
Executive summary..................................................................................................................................vi
Chapter 1: Introduction............................................................................................................................8
1.1 Objective of the Study.................................................................................................................8
1.2 Description of the Study..............................................................................................................8
1.3 Scope of the Study.......................................................................................................................8
1.4 Need of the Study........................................................................................................................8
1.5 Limitation of the Study......................................................................................................................9
Chapter 2: Methodology...........................................................................................................................9
2.1 Team Formation................................................................................................................................9
2.2 Method Used in the Study.................................................................................................................9
2.3 Method of Data Collection................................................................................................................9
2.4 Ethical Considerations.......................................................................................................................9
Chapter 3: Overview...............................................................................................................................10
3.1 Introduction to Tyco Scandal...........................................................................................................10
3.2 How the fraud happened..................................................................................................................10
Chapter 4: The reasons for Tyco’s disreputation..................................................................................11
4.1 Auditing Procedures That Raise Questions......................................................................................11
4.2 Concerns Relating to a Conflict of Interest......................................................................................11
4.3 The Misappropriation of Company Resources by Senior Management...........................................12
4.4 Bribery.............................................................................................................................................13
4.5 Fraud in the Accounts......................................................................................................................13
4.6 Inappropriate discharge of employees.............................................................................................14
Chapter 5: How the Tyco International fraud was discovered?..........................................................15
Chapter 6: The Board of Directors & Questionable Adjustments to Tyco’s Programs.....................16
6.1 Questionable Adjustments...............................................................................................................16
6.2 Role of Board of Directors...............................................................................................................17
6.3 Role of the Subordinates..................................................................................................................18
6.4 Role of External Auditors................................................................................................................18
Findings & Conclusion............................................................................................................................18
Reference..................................................................................................................................................19

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 Executive summary
For our term paper submission, we have been authorized to report on an accounting scandal that
has occurred throughout the world. We have chosen the ‘Tyco International Scandal-2002’ & our
report findings constitute an overview of how the fraud occurred, the means and processes by it
was done, how it was discovered & the role of the company’s management & subordinates in the
fraud.

Founded in 1960s, the company expanded rapidly with its aggressive strategy of taking over of
other companies by acquiring over 3000 companies. This expansion led to a relocation of
headquarters from New York to Florida. To assist employees with this relocation, the company
initiated a low interest loan program which was meant for the tax purpose but CEO Dennis
Kozlowski and CFO Mark Swartz took millions of dollars of this loan and instead of only using
it for the stated purpose they used it to finance of their luxury lifestyle.

PricewaterhouseCoopers (PwC), the auditing firm that was charged with reviewing the financial
statements of Tyco, was unable to uncover the unlawful financial activities as they did not verify
the financial reports with the appropriate level of care and attention.

After receiving information from banking sources regarding murky transaction at the
corporation, prosecutors started looking into Tyco where it was found that the former company
CEO and Chairman Dennis Kozlowski’s personal assets were almost $600 million from the firm.
Eventually they were convicted after investigation & trial & served sentences.

At the epicenter of the unethical behavior in the company was Dennis Kozlowski & his
executives lend him backing. PwC’s failure to identify Kozlowski's illegal financial transactions
resulted the unethical business practices to continued, leading to the involvement of various Tyco
employees. Because of the auditing firm's lack of constraining influence, these practices became
difficult to stop.

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 Chapter 1: Introduction

Accounting Fraud is an unlawful manipulation of the financial statements & information to

create a false appearance of financial stability & scam & extort money. Additionally, it
comprises of the employees, accountants, or the organization who deliberately mislead the
investors and shareholders. Therefore, prevention of such frauds is mandatory to promote a
staunch & stable financial sector. In this report, the authors take insight from the ‘Tyco’ Scandal
& elaborate how the fraud was materialized & eventually exposed.

1.1 Objective of the Study

The report is conducted for academic purpose. However, another core objective of this report is
to understand the concept of accounting frauds, how it can be prevented & what measures should
be taken by the regulatory & reporting organization as it has a direct effect on the financial sector
both individually & collectively.

1.2 Description of the Study

The report elaborates the introduction to ‘Tyco’ scandal & how it happened, the reason behind
Tyco’s disrepute & how it was discovered. It further explains the motive & principles based on
the role of the directors & the external auditors.

1.3 Scope of the Study

The report is based on an international context as the main focus of this report is the ‘Tyco
Scandal 2002’.

1.4 Need of the Study

This report helps the authors to understand the concept & preventive measures regarding
accounting frauds with proper elucidation & effects. As business students, the authors must
possess the knowledge regarding auditing assurance engagement & accounting fraud counter
preventive measures.

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1.5 Limitation of the Study

Though we made a sincere effort while preparing this remain, there may remain slight limitation
or shortcoming as,

i. The report mainly focuses on the secondary data collected from various sources
regarding the scandal as there is no option to primarily collect information.

Chapter 2: Methodology
2.1 Team Formation

We formed a five-member team consisting of Rifa Tasfia, Shohan Hasan, Sumaya Afrose,
Zawadul Ahamed, Abdullah Al Wafee, divided the work & collaborated together during the
process of preparing the report.

2.2 Method Used in the Study

The study is based on non-numerical data & a qualitative approach. No quantitative approach
was taken as the data deals with theoretical aspect. We have collected the data from several
articles, news portals & accounting journals.

2.3 Method of Data Collection

Data collection was conducted using secondary data collection method which refers to collection
of data from an existing primary source.

2.4 Ethical Considerations

We considered the significant ethical factors of the report. Since the information was directly
collected from a primary source, the authors had no biasness in the report thereafter. There is no
room for manipulation either.

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 Chapter 3: Overview
3.1 Introduction to Tyco Scandal
‘Tyco International Scandal’ is the scandal and theft committed by the top executives of the
company. This fraud is said to be a classic case of mass theft and greed. The company’s the then
CEO Dennis Kozlowski, former CFO Mark swartz and others were accused of theft of $600
million through stock frauds, unauthorized loans and bonuses and falsified expense accounts.

3.2 How the fraud happened

Founded in 1960s, the company expanded rapidly with its aggressive strategy of taking over of
other companies and during the time of CEO Dennis Kozlowski the company acquired around
3000 companies. This aggressive strategy took the company to S&P 500. Due to this expansion
the company moved its headquarters and many offices from New York to Florida. Because of
this change the employees also had to shift to the new location. To help the employees with
relocation, the company started a program where the employees and executives including CEO
Dennis Kozlowski and CFO Mark Swartz could take loans with very low interest and no interest
for aiding in relocation. These top two executives, the CEO and the CFO, took illegal advantage
of this program and spent millions of dollars of the company’s money to meet their personal
expenses. There was another program of the company for the top executives called Tyco key
employee corporate loan program which provided low or no interest loans to the executives. The
Tyco key employee corporate loan program was started to help employees pay taxes who receive
substantial amount of stock compensation. This program was meant to help the executives to
help pay tax whenever the amount of tax is high or when they are unable to sell stocks because
of lock in period and then pay back the loan later when they are able to liquidate the stocks.

This loan was only meant for the tax purpose but CEO Dennis Kozlowski and CFO Mark
Swartz took millions of dollars of this loan and instead of only using it for the stated purpose
they used it to buy many personal assets like real estate, expensive artworks, yacht and pay for
the expenses of their luxury lifestyle. They also used the money to fund their personal business
and concealed about it to the company’s shareholders.

The relocation program was meant to help the employees relocate from New York to Florida and
though the CEO and CFO used a portion of the loan proceeds to buy apartments in Florida but

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used a substantial amount of the proceeds to buy luxury apartments and real estates at other
places. They used their power and jointly took $37.5 million through loan forgiveness. In the
year 2000, they undertook a program of loan forgiveness to some of the employees who had
taken loan from the relocation program. The loan was forgiven on the condition that they will not
disclose this forgiveness to anyone except for their financial and legal advisors and through this
Kozlowski and Swartz took away another $33 million. To hide the matter of their personal gain
through the loan forgiveness program they undertook different smaller actions for example,
making the company buy one of CEO Dennis Kozlowski’s older apartments by showing it as a
high value asset (increasing the value of the asset almost three times), CFO Swartz also sold his
personal assets to the company in inflated price. They lived in luxury apartments which the
company paid for but they did not pay any rent for the apartments.

They also committed fraud through sale of Tyco stock. CEO Kozlowski and CFO Swartz sold
restricted shares or shares not allowed to be sold by the executives to some of the offshore
subsidies of the company. Moreover, the bonuses that they were receiving, much of them were
unauthorize

Chapter 4: The reasons for Tyco’s disreputation

4.1 Auditing Procedures That Raise Questions
PricewaterhouseCoopers (PwC), the auditing firm that was charged with reviewing the financial
statements of Tyco, was unable to uncover the unlawful financial activities that Kozlowski had
been engaging in. It was alleged that PwC did not verify the financial reports with the
appropriate level of care and attention. As a direct consequence of this, Kozlowski's
unscrupulous business methods were allowed to continue, which led to the engagement of a
variety of employees working for Tyco. Because the auditing company was no longer providing
a restricting effect, it became increasingly difficult to put a halt to these practices.

4.2 Concerns Relating to a Conflict of Interest

The issues with conflict of interest are the primary emphasis of the case study that was done on
Tyco International. This was the core concern that the case focused on. It was discovered that the

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executives of Tyco International were involved in a variety of immoral activities. During the
time that they served on the board of directors, where they had a position of trust, they were
involved in matters that were in direct opposition to their roles. All of the offenses that they
committed demonstrated that they put their own interests ahead of the interests of the company's
owners. The following is a list of the problems that arose from a conflict that were present in the
case s. Such concerns will be elaborately addressed in the following section.

4.3 The Misappropriation of Company Resources by Senior Management

The theft of funds is a significant problem that, in this instance, resulted in a conflict of interest.
The act of stealing money from the corporation constitutes a violation of the principle of goals.
In accordance with the concept of ends, we shouldn't ever take advantage of other people in
order to accomplish what we set out to do. In this instance, Kozlowski had taken advantage of
the company by making use of company funds to satisfy his own personal desire to live an
extravagant lifestyle. As a result of the case, we were able to determine that Kozlowski had
violated the rights of his workers by using a large portion of the funds from such a program that
allowed workers to purchase company stock at a discounted price in order to purchase for
himself luxury real estate, yachts, and works of art. In addition to Kozlowski, another director
named Lord Michael Ashcroft was engaged in the theft of money from the corporation. He was
able to buy a house with money from Tyco. Their actions violated ethical standards; they had no
right to take advantage of other people for their own gain.

In addition, the breach of duty committed by the the board of directors of Tyco International was
a violation of the norms of duty because it involved the theft of corporate funds. According to the
principles of duty, every individual possesses a particular responsibility or obligation that, as a
human being, he or she ought to carry out. In this particular scenario, Kozlowski and the other
directors were tasked with fulfilling their responsibilities in order to effectively run the
corporation. However, they did a poor job managing the company since they took inappropriate
amounts of money for themselves. They were unable to execute their responsibilities as a result
of the embezzlement of funds, which breached such responsibilities. This is further evidence that
the actions that they had taken were incorrect.

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4.4 Bribery
Bribery is another moral problem that arises from the crisis involving Tyco International and its
conflicts of interest. During the course of this affair, two main instances of bribery took place. In
the first instance, Frank E. Walsh Jr., a director of Tyco International, received twenty million
dollars for his assistance in arranging the purchase of CIT Group without knowledge of the other
members of the board of directors. Following that, the second instance involves a member of
Tyco's board of directors named Stephen W. Foss, who was paid $751,101 for furnishing a
Cessna Citation airplane as well as pilot services.

As was just noted, Foss was compensated in the form of "commission" by Tyco International for
the provision of aircraft and pilot services. It violates ethical standards since Foss did not take
into account the effects that it would have on all of the affected persons. Additionally, he ought
to take into consideration other businesses that had the intention of supplying the services to
Tyco. Additionally, by doing this, he was undercutting the bidding mechanism, in the event that
Tyco used this approach to select the supplier. According to what Frank E. Walsh Jr. said, he
ought to reveal the information regarding the fees that he obtained from the agreement of the
purchase of CIT Group to the group led as well as the shareholders. Ironically, Walsh has
declined to do so, and he has instead appropriated all of the purported "fees" for his own use. He
was in violation of the law for engaging in such conduct, as he had previously disobeyed the
regulations.

4.5 Fraud in the Accounts

Accounting fraud is the third ethical problem in the Tyco case that relates to the conflict-of-
interest issue. There is a potential for a conflict of interest in this matter due to the fact that the
accountants, auditors, and administrators of Tyco undermine trust, and the degree to which their
personal interests diverge from those of Tyco's shareholders and other stakeholders is significant.
They frequently put their own interests ahead of the accuracy of the information that is reported
about the company's finances.

In this particular instance, Tyco International did not provide accurate financial information for a
number of years. The executives of Tyco who are accused of committing fraud include Dennis
Kozlowski, Mark Swartz, and Mark A. Belnick. They are accused of altering corporate records
in order to conceal an excessive amount of loan that was taken out without consent. In addition

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to this, it was discovered that Tyco participated in "financial fraud" in order to deliberately and
artificially manipulate its earnings. In this scenario, Jerry Boggess, who is the chairman of Tyco
Safety and Security, is the one who engaged in fraudulent bookkeeping practices, which
ultimately had an effect on Tyco's earnings per share. In addition to this, Dennis Kozlowski was
charged with tax evasion for avoiding slightly more than one million dollars in New York State
and local sales taxes (Andrew and Alex, 2002). In addition, Scalzo, who had been Tyco's auditor
from 1997 until 2001, found that he had failed to conduct trustworthy way in audit procedures
that related to such executive advantages, executive compensation, & related party transactions.
Scalzo came to this conclusion after auditing Tyco's financials from 1997 until 2001. In addition
to this, he participated in professional behaviour that was unacceptable 

4.6 Inappropriate discharge of employees

Kozlowski, who is the CEO of Tyco International, is not allowed to victimize his staff without a
valid reason. He failed to adhere to two fundamental guidelines on the termination of employees.
He dismissed the workers without taking into consideration how they had performed in their
respective jobs. The principle of reasonable cause has been breached by this action. In addition,
Kozlowski does not address the issue of whether or not the processes that were utilized to
terminate the employees followed due process. This is a violation of the principle of due process.
He failed to provide the employees with the notice that was required of him, and he also failed to
provide the employees who had been fired with compensation and pension benefits. In this
instance, he does not treat his workers in a manner that is fair and just. In addition, one form of
abuse of official status is demonstrated by the manner in which Kozlowski treated his
employees. He utilized his position as CEO to misuse his power by behaving unfairly and
unjustly against the workers, and he fired people at will without providing any reasonable
explanation.

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 Chapter 5: How the Tyco International fraud was
discovered?

Prosecutors started looking into Tyco in January after receiving information from banking
sources regarding a murky transaction at the corporation where it was found that the former
company CEO and Chairman Dennis Kozlowski’s personal assets were almost $600 million
from the firm. charged of scheming to evade taxes on the paintings. Three men, Kozlowski, the
former corporate Chief Financial Officer Mark Swartz and Belnick were found mainly found
guilty as they borrowed multimillion dollar loans from the corporation at low or no interest, and
in some cases, they never paid them back. The three former executives were accused by the SEC
of concealing their personal sales of Tyco stock totalling millions of dollars. The shareholders
were betrayed by the management of the company they owned. Due to the corporate thefts,
scandals, and frauds, thousands of middle-class Americans and their families have either lost
their means of work or their entire retirement life savings. Kozlowski and Swartz were accused
with fraud, grand theft, corruption, and conspiracy. If all charges against the two men are proven
true, they might each spend up to 30 years in prison. Belnick could spend up to four years in
prison after being accused of fabricating business paperwork. Tyco also claimed that it has filed
a lawsuit against Kozlowski, seeking forfeiture of all of his severance money as well as back
salary and perks totalling around $244 million since 1997. Tyco International, the manufacturer
of undersea cable, crutches, and other equipment previously sued Belnick in an effort to recoup
millions of dollars that it believes he stole.

Prosecutors claim that Kozlowski and Swartz defrauded investors of more than $400 million in
addition to their expensive expenditures by fabricating and manipulating data in proxy
statements and other documents as well as during meetings with investors, analysts, and media
representatives. They allegedly concealed the fact that they received millions of dollars in
payments and loans that were later forgiven, and they frequently submitted paperwork claiming
they were little more than $60,000 in debt. In addition, the indictment said that Kozlowski misled
investors by claiming to have faith approximately Tyco while concealing his own sale of 5.5

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million Tyco shares, which brought in $280 million for him. Swartz earned more than $125
million through the sale of more than 2 million shares of Tyco.

The two accused men fiercely contested the allegations and adamantly denied any culpability,
turning the controversy into a protracted trial. Because of a suspicious incident that occurred
during the last jury deliberations, the first trial ended in mistrial in 2005. After the second trial,
Kozlowski was imprisoned to a minimum punishment of eight years and four months behind
bars and a maximum of 25 years sentence of jail. Swartz suffered the same penalties for his
connection in the Tyco International scam. A group of the defrauded stockholders received $2.92
billion from Tyco as compensation. Price Waterhouse Coopers, their corporate auditors, also
agree to pay $225 million in restitution to the affected investors.

Chapter 6: The Board of Directors & Questionable

Adjustments to Tyco’s Programs
6.1 Questionable Adjustments
Tyco International Ltd., in an attempt to boost its results in the recent years, routinely effected
questionable accounting procedures. But an internal inquiry into the company's bookkeeping
practices concluded that the problems weren't large enough to be "material" to the overall profits
of the company.

Facing a tumultuous year in which three of its former executives and a former director were
indicted, Tyco filed a report with the Securities and Exchange Commission. The report was made
on the findings of the accounting examination, which was headed by attorney David Boies.
Twenty-five lawyers and 100 accountants were appointed and it took them about 65,000 hours to
analyze financial information of more than 45 Tyco operating units.

Despite their cautiousness, the report paints a picture of a corporate culture which has gone awry
accompanied by lax controls and poor ethics. This resulted in a pattern of aggressive accounting
that was affected to increase the reported earnings. Among other things, the report provides
considerable evidence that the entity habitually engaged in a practice which it had denied. It

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suppressed the results of its acquisition targets just ahead of swallowing them, for the purpose of
boosting its own post-deal profits.

As for the company investigators, they said that many of the maneuvers fell within the
accounting rules and didn't require any correction. A number of outright accounting errors was
also found by investigators which included improperly dipping into reserves for paying unrelated
expenses and referring current expenses as long-term costs. But it was stated in the report that
these errors were relatively minor in nature and didn't amount to a "systemic fraud."

The report also brought some new details of excess to light. Such as, the company making a
purchase of $6,000 shower curtain and $15,000 umbrella stand. It was purchased for former
Chief Executive L. Dennis Kozlowski. In one instance that hadn't been previously reported, Mr.
Kozlowski had a Tyco division rent hotel accommodations for him in London, costing about
$110,000 for 13 days. The report also said that his personal assistant had an apartment in London
which had been paid for in 2001 and 2002 by the same division.

Some other examples of loose oversight:

A unit vice president approved a bonus for his boss; charitable contributions were made without
authorization, in one case to an entity that did not even qualify as a charity; loans were forgiven
without clear documentation; and bonus plans were changed in the middle of the year to loosen
payout terms.

Despite its relatively benign conclusions, the report is a serious indictment of the company and
its former management team led by Mr. Kozlowski, who resigned in June shortly before being
charged with sales-tax evasion. He and former CFO Mark Swartz were later charged with
stealing more than $600 million from the company through unauthorized compensation and
stock sales. The report will undoubtedly serve as fodder for the numerous class-action lawsuits
alleging that investors were misled. Their spouses have both pleaded not guilty.

6.2 Role of Board of Directors

At the epicenter of the unethical behavior in the company was Dennis Kozlowski. He engaged in
unethical behavior while serving as CEO, which resulted in Tyco's legal disputes and associated
financial issues. The majority of the funds taken from the business were given to Kozlowski, the
principal player in this situation. He utilized his influence as CEO to influence lower-level

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workers and other top Tyco officers to get engaged and ignore his dubious and unlawful
practices. This instance demonstrates how Kozlowski's and other employees' involvement in the
Tyco affair was a significant contributing factor. Leadership was a crucial element that enabled
the occurrence of the corporate scandal, even though elements like organizational culture had an
impact on the events in this case.

6.3 Role of the Subordinates

People other than Kozlowski were involved in the difficulties in Tyco's lawsuit. Another senior
executive in the company, CFO Swartz, was persuaded to lend his backing to Kozlowski.
Additionally, implicated were directors from Tyco. For instance, a board member remained mute
regarding Kozlowski and his wife's purchase of a home. The board member was compensated,
either directly or indirectly, with money. Kozlowski also persuaded several lower-ranking
workers to remain silent in return for financial rewards.

6.4 Role of External Auditors

PricewaterhouseCoopers, the auditing firm in charge of checking Tyco's financial reports, failed
to identify Kozlowski's illegal financial transactions. PwC was accused of failing to verify
financial reports with due diligence. As a result, Kozlowski's unethical business practices
continued, resulting in the involvement of various Tyco employees. Because of the auditing
firm's lack of constraining influence, these practices became difficult to stop

Findings & Conclusion

Accounting frauds such as the one elaborated are caused by a multitude of fraudulent activities
by the management & subordinates of a firm. Due to the negligence of audit assurance providers,
this may very well go undetected for years as it did in the discussed case. Therefore, in order to
ensure clarity in the management of a firm, the internal auditors as well as external audit service
providers should be on guard.

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 Reference

Herold, T. (2016, December 30). What was the Tyco International Scandal? –. Herold Financial

Dictionary. https://www.financial-dictionary.info/terms/tyco-international-scandal/

Romero, J. (2020, September 18). Tyco Corporate Scandal of 2002 (Ethics Case Analysis).

Panmore Institute. https://panmore.com/tyco-corporate-scandal-2002-case-analysis

All Answers Ltd. (2022, July 27). Unethical or Legal Issues in Tyco International.

https://www.lawteacher.net/free-law-essays/company-law/unethical-issues-or-legal-

issues-in-tyco-international-company-law-essay.php

Maremont, & P. Cohen, L. (2002, December). Tyco’s Internal Report Finds Extensive

Accounting Tricks. https://www.wsj.com.

CNN.com - Three Tyco execs indicted for fraud - September 12, 2002. (n.d.).

https://edition.cnn.com/2002/BUSINESS/asia/09/12/us.tyco

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