SF December 2022

LEADERSHIP STRATEGIES FOR ACCOUNTANTS AND FINANCIAL PROFESSIONALS

AI and Digital Discrimination The Value of Connectors Will You Be Ready if the SEC Comes Knocking?

DECEMBER 2022

MANAGEMENT ACCOUNTANTS AND CORPORATE COMPLIANCE

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Contents /12.22

Data analytics capabilities, incentives for reporting wrongdoing, and innovative training can help accounting professionals mitigate the risk of corporate misconduct.

28 FEATURE ARTICLES

28/ 34/ 42/ 50/ MANAGEMENT ACCOUNTANTS AND CORPORATE COMPLIANCE

COVER STORY You can help

revamp organizational compliance by utilizing data analytics, improving internal reporting, and adding storytelling and gamification to training.

BY KELLY RICHMOND POPE, PH.D., CPA, AND LOREAL JILES

AI AND DIGITAL DISCRIMINATION

THE VALUE OF CONNECTORS

Strategies to help mitigate AI bias in automated systems encompass data governance and curation, system development and life-cycle review, human-algorith­mic interactions, and policies and regula­tion.

Recognizing the three characteristics of connectors can help your company reduce turnover costs.

BY ARIF PERDANA, PH.D., CA, AND W. ERIC LEE, PH.D., CPA, CITP, CGMA, CFE

BY ROMANA L. AUTREY, PH.D., CMA, CPA, CFF, CFE; TIM BAUER, PH.D., CPA; KEVIN E. JACKSON, PH.D.; ELENA KLEVSKY, PH.D., CPA; AND MARGARET SHACKELL, PH.D., CMA, CPA

WILL YOU BE READY IF THE SEC COMES KNOCKING? Those who have a corporate governance role need to understand the SEC enforcement programs and the available remediation opportunities.

BY SAMANTHA FALGOUT, CPA; JESSICA L. EVANKO, DBA, CPA; AND DOUGLAS M. BOYLE, DBA, CMA, CPA

December 2022 / STRATEGIC FINANCE / 3

Contents /12.22

42

34

PERSPECTIVES

8 SOLID AS A ROCK

BY GWEN VAN BERNE, CMA SF BULLETIN

10 IMA: JOIN SCMS 10 N EWS: ISSB CONFIRMS GHG EMISSIONS REQUIREMENTS

11 NEWS: IFAC URGES

COOPERATION AMONG G20 LEADERS

11 I MA: WELCOME, NEW CMAs! 12 B OOKS: FORENSIC ANALYTICS FOR ACCOUNTANTS

12 S URVEY: ECONOMIC OUTLOOK TAXES

15 DOCUMENTATION AND SMALL BUSINESSES

BY SHIRLEY DENNIS-ESCOFFIER, PH.D., CPA, AND ANTHONY P. CURATOLA, PH.D.

RESEARCH

17 THE EFFECT OF RELATIVE PERFORMANCE EVALUATIONS

BY CHRISTOPH FEICHTER, PH.D.; FRANK MOERS, PH.D.; AND OSCAR TIMMERMANS, PH.D. SMALL BUSINESS

19 THE IMPORTANCE OF WORKING CAPITAL MANAGEMENT

BY LOGAN ARUMUGAM, CMA, CSCA, CFM, CPA, ACMA DIVERSITY

21 EMPHASIZING DE&I IN EMPLOYEE RETENTION

TECHNOLOGY WORKBOOK

57 TECH FORUM

BY MICHAEL CASTELLUCCIO

59 TOOLS OF THE TRADE

BY MICHAEL CASTELLUCCIO

60 EXCEL

BY BILL JELEN

62 TECH PRACTICES

BY JUN LIU, CMA, CSCA IMA LIFE

64 FROM PRO ATHLETE TO CMA

BY POLINA NYER, CMA

BY RINKU BHATTACHARYA, DPS, CMA, CPA, AND SHREYANSE JAIN, CMA, CA

SF PICK

CFO TO CFO

23 PRIORITIZING PROFESSIONAL DEVELOPMENT

BY DANIEL BUTCHER

59

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4 / STRATEGIC FINANCE / December 2022

VOL. 104 NO. 6 December 2022

EDITOR-IN-CHIEF

CHRISTOPHER DOWSETT, CAE cdowsett@imanet.org

NATIONAL ADVERTISING MANAGER

ELIZABETH KENNEDY

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nfass@imanet.org TECHNOLOGY EDITOR

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mcastelluccio@imanet.org FINANCE EDITOR

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Views expressed herein are authors’ and do not represent IMA policy unless so stated. Publication of paid advertising and new product and service information does not constitute an endorsement by IMA of the advertiser or the product or s­ ervice.

EDITORIAL ADVISORY BOARD Bruce R. Neumann, Ph.D. Academic Editor Ann Dzuranin, Ph.D., CPA Associate Academic Editor William R. Koprowski, Ph.D., CMA, CFM, CFE, CIA Associate Academic Editor For more information on the role of the Editorial Advisory Board and a complete list of reviewers, visit sfmag.link/reviewers.

PUBLISHED SINCE 1919

6 / STRATEGIC FINANCE / December 2022

Strategic Finance® (ISSN 1524-833X/USPS 327-160) Vol. 104, No. 6, December 2022. Copyright © 2022 by IMA. P ­ ublished ­monthly by the ­ Institute of Management A ­ c­coun­tants, 10 Paragon Drive, Suite 1, Montvale, NJ 07645. Phone: (201) 573-9000. Email: sfmag@imanet.org. ­ MEMBER SUBSCRIPTION PRICE: $48 (included in dues, nondeductible); student

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PERSPECTIVES

Solid as a Rock

BY GWEN VAN BERNE, CMA

S

HORTLY AFTER THE October 2022 IMA® Global Board of Directors meeting in Montvale, N.J., I took a vacation with family and friends to visit Stonehenge in the U.K. Walking around the iconic and beautiful site, I reflected on the recent gathering of our strong and diverse group of volunteer leaders and IMA staff in New Jersey.

Stonehenge contains almost 100 massive upright stones placed in a circular layout. The outer ring reminded me of the vast group of members and finance professionals that our Board represents. The four station stones placed around the edges brought back memories of the rigorous work of the chairs of our Board committees (Global Markets, Strategic Planning, Volunteer Leadership, and Performance Oversight and Audit—with alignment by a fifth committee, Governance). These stones mark a perfect rectangle whose central point is in the exact middle of the monument. That center contains an imposing formation with huge lintels, and I couldn’t help but smile and think about IMA’s senior leadership team, which carries so much weight for our community and is responsible for the heavy lifting and strategic direction on a daily basis.

Just like our global volunteer leaders attending the meeting, each rock at Stonehenge was brought to this landscape arrangement from faraway places. Together and in formation, they form an impressive symbol for unity and peace.

The powerful effect reminded me of what an organization’s chair aims to accomplish during

events like the Board meeting in Montvale: You want everyone to come together to converse openly and honestly about the necessary transformations the organization is going through, but you also want everyone to feel united through a strong governance and community structure.

The circle formation of Stonehenge also brought to mind management guru Stephen Covey’s circles of influence and control. In the middle of Covey’s leadership model is a circle that represents acting and control. These are the things we can change and have direct control over—our personal values and what we work on. This circle is surrounded by a larger circle, which is the circle of influence. These are things that we can change indirectly (e.g., partnerships and peer strategies).

Finally, there’s an outer circle that stands for external concerns that we have very little control over but that require a reaction (e.g., the economy and regulation).

For me, a good Global Board meeting needs to address all three circles, and I’m proud to say we certainly touched on all the circular layers of control and influence. Not only did we look at IMA’s immediate, short-term future, diving into the organization’s performance this year, but we also allowed ourselves sufficient reflection time to think about IMA’s longer-term future and more indirect responses to what’s going on in the world.

Reminiscent of Stonehenge, IMA has an excellent foundation, and our leadership relationships are rock solid. Our history and governance structures make us who we are, and if we stay open to new control measures and responses to changing times, IMA will surely stay relevant for future generations of finance professionals. SF

« IMA has an

EXCELLENT FOUNDATION,

and our leadership relationships are ROCK SOLID.»

Gwen van Berne, CMA, is director of finance and risk at Oikocredit and Chair of the IMA Global Board of Directors. She’s also a member of IMA’s Amsterdam Chapter. You can reach Gwen at gwen.vanberne @imanet.org or follow her on LinkedIn at bit.ly/3LVeRGM.

8 / STRATEGIC FINANCE / December 2022

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NEWS/

IMA/

JOIN SCMS

Membership eligibility to the Stuart Cameron McLeod Society (SCMS) is now open to all IMA® volunteer leaders who have actively volunteered for at least one year. SCMS is committed to providing educational programs for students and professionals, an annual student scholarship, networking opportunities, and a forum for volunteer leaders to continue their camaraderie. Visit bit.ly/3WPmTrM to learn more and apply.

75%

THE STATS

of U.S. office workers have witnessed some form of workplace misconduct during their careers.

Source: Vault Platform, bit.ly/3S6ho5n.

See “Management Accountants and Corporate Compliance” on p. 28.

10 / STRATEGIC FINANCE / December 2022

ISSB CONFIRMS GHG EMISSIONS REQUIREMENTS

T

he International Sustainability Standards Board (ISSB) of the International Financial Reporting Standards (IFRS) Foundation voted unanimously at its October 2022 meeting to require company disclosures on Scope 1, Scope 2, and Scope 3 greenhouse gas (GHG) emissions, applying the current version of the GHG Protocol Corporate Standard. This decision came following careful analysis of feedback from its first two proposed sustainability-related disclosure standards—IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures.

As part of these requirements, the ISSB will develop relief provisions to help companies apply the Scope 3 requirements. This relief will be decided at a future meeting and could include giving companies more time to provide Scope 3 disclosures and working with jurisdictions on so-called “safe harbor” provisions, which give companies protection from, or reduce, liability on information disclosed to investors and other capital market participants.

Scope 1 covers direct emissions from a company; scope 2 covers indirect emissions from electricity purchased and used; and scope 3 covers all other indirect emissions from the value chain.

The ISSB also clarified key concepts from the General Requirements Standard at the meeting. It confirmed that its requirements will focus on meeting the information needs of investors and decided to modify language in the proposals that was not clearly understood.

The ISSB has also confirmed it will use the same definition of material as is used in IFRS Accounting Standards and will discuss at a future meeting the need for further guidance on how to determine what is material information. —Nancy Fass

®

NEWS/

IFAC URGES COOPERATION AMONG G20 LEADERS

T

he International Federation of Accountants (IFAC) issued 2022 G20 Call to Action (bit.ly/3fKJi8M) in November 2022, urging global cooperation among G20 leaders on issues such as sustainability, the need for strong public financial management, and the fight against corruption. The call for cooperation comes amid the anticipated and widespread economic and political uncertainty in the wake of the COVID-19 pandemic.

“Tremendous interconnectivity is required if we are to make any significant progress toward achieving the [United Nations’] Sustainable Development Goals [SDGs]. This is not just within the accountancy profession, but also between the profession and other UN SDG stakeholders.

We commend the efforts of the G20 and also call on G20 leaders to do even more,” said IFAC CEO Kevin Dancey.

The priorities outlined in the 2022 call align with IFAC’s IMPACT approach, introduced in 2021, which identifies the most important issues currently facing the accountancy profession, private and public organizations, and global financial markets and economies. The IMPACT approach is a guide for where the accountancy profession should be headed and serves as a tool for increased collaboration and cohesion within the profession.

To strengthen global economies, societies, and the environment, and to continue to address challenges resulting from the COVID-19 pandemic, IFAC calls on G20 leaders to: ■ Make sustainability a reality, not just a goal, including supporting IFRS Sustainability Disclosure Standards and recognizing the role of professional accountants in developing decision-useful sustainability information.

■ Support public finance management and fight corruption, including implementing multilateral commitments against corruption and related issues, as well as supporting professionalization in the public sector and adoption of International Public Sector Accounting Standards.

■ Work together for collective prosperity, including minimizing regulatory fragmentation to drive economic growth.

WELCOME, NEW CMAs!

1,067

IMA members became CMAs between October 1 and October 31, 2022.

The names of all the new CMAs can be found on the Strategic Finance website at sfmagazine.com/issue /december-2022.

For more information on CMA certification, visit www.imanet.org /cma-certification.

The 2022 G20 Call to Action builds upon four priorities set forth in IFAC’s 2020 G20 Call to Action (bit.ly/3UCmJSm) and its 2021 update (bit.ly/3Tf1nJY). —Lori Parks December 2022 / STRATEGIC FINANCE / 11

Bulletin BOOKS/

FORENSIC ANALYTICS FOR ACCOUNTANTS

Improve your fraud detection and analytics skills by studying forensic accounting investigations.

F

orensic Analytics: Methods and Techniques for Forensic Accounting Investigations (second edition) by Mark J. Nigrini is worth a look by management accountants and other finance and audit professionals for several reasons. For one, Nigrini’s style is straightforward, and his tips are practical and relevant for practitioners. His stepwise instructions make it easy for investigators and finance professionals alike to follow. The forensic accounting and analytics techniques that he discusses are accessible to most accountants. Since I once missed out on an attractive job because I lacked investigative experience, I wish I had read this comprehensive reference work years ago.

The hook for wider audiences comes from the first word of the title: forensics. We’re drawn in by detective stories and narratives centering on fraud or other crimes. Safekeepers of a company’s assets and auditors will perk up at the second word: analytics. Do we all need advanced tools and special training to detect and investigate fraud? Nigrini asserts that most analytical investigative techniques are relevant to accounting professionals.

The book presents more than 30 interesting fraud cases that illustrate analytics tests. Some are high-level tests to detect major issues such as embezzlement, whereas others identify smaller subsets of high-risk transactions. If the organizations had embedded controls or if these tests had been run by internal, tax, or revenue-recovery auditors, then the fraud schemes detailed in the book probably would have been discovered sooner. Cases are brought to life with figures, tables, actual data, and photos.

Nigrini analyzes real-world data sets to demonstrate analytics techniques. Chapter 13 describes a $49.3 million case where an employee processed fraudulent property tax refunds. Chapter 14 describes a $20.6 million case where a supplier claimed fraudulent shipping charges. Chapter 15 is an in-depth look at financial statement fraud. The common thread running through the featured cases is that the schemes were quite simple.

The forensic analytics tests are easy to understand and run. Most of the tests are demonstrated in Excel and Access, while some are in data analysis tool IDEA, programming languages R and SAS, data visualization software Tableau, and statistics software package Minitab.

Considering all the valuable information and relevant examples in the book, the techniques outlined in Forensic Analytics are worth adding to your repertoire, either to detect misconduct or enhance your understanding of data analysis for the benefit of your organization and your career. —Chris Mishler, CMA, CIA 12 / STRATEGIC FINANCE / December 2022

SURVEY/

ECONOMIC OUTLOOK

The Q3 2022 Global Economic Conditions Survey from ACCA (Association of Chartered Certified Accountants) and IMA® (Institute of Management Accountants) found confidence on the economic outlook remains well below the median reading over the past decade, while new orders, capital expenditure, and employment all showed continued deterioration.

Looking at what has challenged businesses over the quarter, respondents cited:

74% increased costs

37%

decreased income

35%

foreign exchange volatility The number reporting increased cost pressures was the highest ever recorded in the survey. For more results and analysis, the full report is available at bit.ly/3doZc2U.

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957930618

TAXES

DOCUMENTATION AND SMALL BUSINESSES The Wolpert tax court case illustrates the importance of having good documentation to substantiate the deductibility of business expense when operating a small business. BY SHIRLEY

A

DENNIS-ESCOFFIER, PH.D., CPA, AND ANTHONY P. CURATOLA, PH.D. LTHOUGH INTERNAL REVENUE CODE (IRC) §162

permits a deduction for ordinary and necessary expenses paid to carry on a business, the taxpayer bears the burden of proof in substantiating the amount and purpose of the expenses and must maintain adequate records for any deductions claimed. The Wolpert tax court case provides an effective illustration of the need for small businesses to have sufficient documentation to ensure a deduction when paying relatives and when claiming deductions for other expenses such as vehicles and travel. It also illustrates the potential threat of penalties in addition to an assessment for back taxes.

Julian Wolpert (TC Memo 2022-70) was a civics consultant and former professor. Following an audit, the Internal Revenue Service (IRS) disallowed more than $65,000 of business deductions for his Schedule C consulting business over a two-year period, resulting in an income tax deficiency in excess of $25,000.

In this case, Wolpert didn’t maintain a separate business checking account but instead made payments from his personal checking account and didn’t provide the additional documentary evidence required to substantiate these expenses.

This case provides a classic illustration of how deductions can be disallowed for lack of substantiation.

COMPENSATION TO RELATIVES Compensation paid to a child or other relative can qualify as a business deduction if it’s reasonable for the services legitimately provided and there’s sufficient documentation. Wolpert issued checks to his three children and a grandchild for work as “assistants” for his business. He claimed deductions for payments in excess of $50,000 over two years, which he considered compensation for services rendered to his consulting business.

There was no evidence such as timecards or pay stubs or any other records to document the services.

Copies of a few negotiated checks were provided, but the checks didn’t include any notation stating the purpose of the payment.

December 2022 / STRATEGIC FINANCE / 15

TAXES

THE WOLPERT CASE PROVIDES A CLASSIC ILLUSTRATION OF HOW DEDUC­TIONS CAN BE DISALLOWED FOR LACK OF SUBSTANTIATION.

Most of the payments were made to Wolpert’s daughter. She testified at trial regarding her general involvement in the business, which included preparing flyers, taking photographs, and conducting research.

Yet none of the flyers, photographs, or research were offered into evidence. The court didn’t find her to be a credible witness and stated her testimony didn’t establish the specific services she performed.

VEHICLE AND TRAVEL If a taxpayer is unable to substantiate the amount of a deduction, the court may choose to allow some portion of it under the Cohan rule (see Cohan v. Commissioner of Internal Revenue) if there’s sufficient evidence.

The Cohan rule says that a business may rely on reasonable estimates when unable to produce records of actual expenditures, provided there’s some factual basis for it. Yet the Cohan rule can’t be applied to deductions subject to the strict substantiation requirements of IRC §274(d) such as vehicle and travel expenses.

Vehicle expenses.

Under the substantiation requirements that apply 16 / STRATEGIC FINANCE / December 2022

to passenger vehicles, a taxpayer must document the (1) amount of each expense, (2) mileage for each business use of the vehicle and total mileage for all use of the vehicle during the year, (3) date of each business use, and (4) purpose of each business use. To substantiate these expenses, a taxpayer must generally maintain a contemporaneous log, trip sheet, or similar records, as well as corroborating documentary evidence that establishes each element.

If choosing to use the standard mileage rate method, the taxpayer must still substantiate the (1) mileage for each business use and total mileage for all use of the vehicle during the year, (2) date of each business use, and (3) purpose of each business use.

Using the standard mileage rate, Wolpert claimed vehicle expenses totaling more than $10,000 for two years, but he didn’t maintain adequate records. The mileage logs appeared to be printouts from a computer-generated spreadsheet rather than the original log the taxpayer allegedly kept in the vehicle and made no mention of the business purpose of

each trip or the total mileage of the vehicle for the year. The only corroborative evidence was his general testimony regarding mileage logs and calendars, which the court found was insufficient to meet the requirements to justify a vehicle expense deduction.

Travel expenses.

Under the substantiation requirements for travel expenses, taxpayers must provide the (1) amount of each expenditure for traveling away from home, (2) date of departure and return for each trip, and number of days spent on business, (3) destination, and (4) business reason for travel. Similar to the requirement for vehicle expenses, the taxpayer must substantiate each element through adequate records or sufficient corroborating evidence.

Wolpert provided credit card statements, but the statements didn’t substantiate the date of travel, number of days spent on business, destination of each trip, and the business purpose of each trip. He alleged in general terms that he took business trips to several different states for meetings with government and other officials to discuss projects during the years at issue. In denying his deduction, the court determined that his testimony lacked the specificity and detail needed under the substantiation requirements.

Wolpert also claimed expenses for internet and cell phone services but offered no bills or invoices from the cable company providing the bundled internet and cellular phone services. The only evidence offered were credit card statements reflecting

charges from the cable company, but that didn’t provide the identity of the payee or the services covered. In disallowing the deductions, the court noted that these payments could have included charges for cable television, which would be a nondeductible personal expense.

POTENTIAL PENALTY The one bright spot for Wolpert was that he wasn’t assessed an accuracy penalty. The IRS attempted to assess the IRC §6662 accuracy penalty, which could be 20% of the underpayment amount for negligence or intentional disregard of the rules or regulations. The court held that Wolpert wasn’t liable for the accuracy penalty because the IRS didn’t comply with the procedural requirement that it seek written supervisory approval for the assessment of the penalty.

This case should put taxpayers on notice that if the IRS follows all its procedural requirements in future cases, they risk being subject to this penalty in addition to back taxes and interest. SF

Shirley Dennis-Escoffier, Ph.D., CPA, is an associate professor of accounting at the University of Miami. She can be reached at sdennis@bus .miami.edu.

Anthony P. Curatola, Ph.D., is editor of the Taxes column for Strategic Finance, the Joseph F. Ford Professor of Accounting at Drexel University, and a member of IMA’s Greater Philadelphia Chapter. You can reach Tony at curatola@drexel.edu. © 2022 A.P. Curatola

RESEARCH

THE EFFECT OF RELATIVE PERFORMANCE EVALUATIONS Evaluating managers relative to the performance of their peers can lead to aggressive behavior. BY CHRISTOPH FEICHTER,

C

PH.D.; FRANK MOERS, PH.D.; AND OSCAR TIMMERMANS, PH.D.

OMPARING MANAGERS’ PERFORMANCE AGAINST

the performance of their peers at other companies has become a popular way to evaluate them. Since 2006, there has been a sharp increase from about 20% to 65% of companies using such relative performance comparisons for their top management, and the pay these managers can earn from outperforming their peers is substantial (see bit.ly/3TXRZeZ and bit.ly/3TNCztt). For example, the average CEO can earn up to 75% of his or her previous year’s total compensation by outperforming peers when specified in the compensation contract, which translates to roughly $7 million on average.

This prevalence motivated us to examine the consequences for managers’ decisions. Because relative performance evaluation contracts state that managers are only paid if they perform better than their peers do, we focused on the aggressiveness of their decisions toward peer managers (“Relative Performance Evaluation and Competitive Aggressiveness,” Journal of Accounting Research, 2022).

With relative performance evaluations, managers aren’t held accountable for factors that are general to the industry or product market and thus beyond their control. For example, because the performance of all airlines decreased substantially during the COVID-19 crisis, in absolute terms, evaluating performance against peers allowed for a correction of this general decrease and thus for providing insights into how well airlines performed given the situation.

As a result, relative performance evaluation provides a better understanding of a manager’s true performance. Poor performance, in absolute terms, doesn’t necessarily imply that a manager performed poorly during an industry-wide crisis. Conversely, when a company grows by 7%, this might still be indicative of poor performance when peers grew by 15%.

Yet comparing a company relative to its peers also puts managers in direct competition with their peers, which has consequences for how aggressive managers act.

Managers might directly December 2022 / STRATEGIC FINANCE / 17

RESEARCH

challenge their peers and increase their own relative position by attacking them.

For example, they could take increasingly competitive actions such as price reductions, developing new products, engaging in lawsuits toward competitors, engaging in merger and acquisition activities, and so forth. This means companies become more competitively aggressive when managers are evaluated relative to managers of peer companies.

OUR STUDY Using data from the largest U.S. companies between 2006 and 2017, we examined the relationship between relative performance evaluation and competitive aggressiveness.

One feature of these relative performance contracts is that when one company uses another company as part of its peer group, the other company doesn’t need to use relative performance evaluation itself or, if it does, doesn’t have to include the focal company as a peer in the manager’s contract. But if the other company selects the focal company as a peer, then there’s a peer group overlap.

Our prediction is that the greater a company’s peer group overlap, the greater the incentive to adjust its competitive aggressiveness.

To measure managers’ competitive actions, we examined newspaper headlines identified in about 19,000 traditional media sources (e.g., Dow Jones Newswire and The Wall Street Journal) and social media sites. These headlines showed whether companies took competitive actions such as price reductions, strategic alliances, 18 / STRATEGIC FINANCE / December 2022

new product offerings, etc.

On average, companies take about 33 competitive actions per year, and there’s substantial variation in the type of actions they take.

FINDINGS AND IMPLICATIONS Results from our analyses show that peer group overlap in these relative performance evaluation contracts is associated with greater levels of competitive aggressiveness. Compared to companies using relative performance evaluation with no peer group overlap, those with the highest levels of peer group overlap take about 36% more competitive actions per year, and the variation of these actions across the different action types is 19% greater, which implies that companies significantly expand their competitive repertoire across more action types.

We also found that managers tend to spend more on advertising and that their operating margins are lower. Jointly, these patterns suggest that peer group overlap leads to more competitive aggressiveness in product markets. Our results also indicate that this increase in competitive aggressiveness is even greater when the company and its peers have more similarities (e.g., in terms of size, performance measures, and/or industry).

Collectively, our study provides several new insights that might be important for boards of directors, investors, regulators, and other practitioners. For example, when companies choose to evaluate managers on their relative performance to

filter common uncontrollable factors, they need to consider that it also affects the way managers will compete with peers.

While being competitively aggressive can improve a company’s relative position, it might also have harmful side effects. For example, peer companies can decide to counteract these actions by also becoming more aggressive, which can lead to an upward spiral in competitive investments and a downward spiral in margins. Furthermore, managers might also take other actions that increase their relative performance but not necessarily their absolute value.

By being aware of such potential side effects, compensation committees as well as investors can better judge the costs and benefits of relative performance evaluation, establish whether these contracts expose companies to material risks, and prevent value-destroying actions by increasing the intensity with which they monitor managers and the company.

Knowing that relative performance evaluation is associated with increased aggressiveness is also important for managers themselves. Once they see that a peer company uses relative performance evaluation and includes them as a peer, it could warn them that the peer will likely increase its competitiveness. This allows managers of the focal company to set some counteractions beforehand.

From this perspective, our results also have implications for regulators.

For example, while the U.S. Securities & Exchange Commission has increased

its compensation disclosure requirement toward capital market participants, this increased transparency can also shape the way companies compete in the product market.

Regulators should thus be aware of such market externalities when setting standards.

Finally, showing that aggressiveness increases with peer group overlap also has implications for other types of relative performance contracts in practice. For example, many companies use relative performance evaluation for lower-level employees (e.g., sales competition, forced ratings). In these settings, all employees typically compete against each other, and thus there’s a 100% peer group overlap. As a result, relative performance evaluation contracts within companies might also lead to aggressive actions among employees, which is often reflected by a lack of cooperative behavior. This informs companies about potential costs and benefits of these incentive plans. SF

Christoph Feichter, Ph.D., is assistant professor at Vienna University of Economics and Business. He can be reached at christoph.feichter@wu.ac .at.

Frank Moers, Ph.D., is professor of management accounting and control at Maastricht University. He can be reached at f.moers @maastrichtuniversity.nl.

Oscar Timmermans, Ph.D., is assistant professor of accounting at the London School of Economics. He can be reached at o.timmermans @lse.ac.uk.

SMALL BUSINESS

An SME’s financial managers should manage cash just as in recessionary conditions, as tightly as possible, while operations and sales focus on the operational efficiencies and service levels, respectively. This balancing act will optimize working capital levels and enable the flexibility to support topline growth in opportunistic business conditions.

THE DISCIPLINE OF METRICS

THE IMPORTANCE OF WORKING CAPITAL MANAGEMENT Organizations can find their path to optimize working capital, the most important short-term financial resource for an SME.

S

BY LOGAN ARUMUGAM, CMA, CSCA, CFM, CPA, ACMA

MALL AND MEDIUM-SIZED ENTERPRISES (SMES) MUST MAKE the

maximum effort to optimize their cash to face the competition and collaborate with larger businesses. An SME may survive for some time without profit, but a lack of it can compromise its prospects. There are many practical ways an SME can optimize its working capital without infusing external finance.

As Peter Drucker famously said, “what gets measured gets managed,” and this holds too for fine-tuning and improvements to reach our desired goals.

Forecast, update, and review the 13-week cash forecast biweekly.

The discipline of making a biweekly, 13-week rolling cash forecast helps with planning and control of cash timing in and out. For the ensuing two weeks, this forecast needs to be reported weekly to explain any variance in how actuals match to forecasted amounts. This routine will help fine-tune the 13-week forecast to improve its accuracy and cash planning and shed light on short-term corrections.

Report the cash conversion cycle (CCC) as the main financial metric.

To unlock the idle cashout, the objective should be to turn the money over faster (more turns) by shortening the CCC period.

CCC measures how fast a company can convert its initial cash into cash from invoiced revenues. Money returned to the company will be used many times December 2022 / STRATEGIC FINANCE / 19

SMALL BUSINESS

to churn in more profits through the repeat revenue cycles. To grow only the top line with poor collections will eventually hurt cash flow and profitability.

Therefore, include CCC trends as part of the financial reporting package.

Coordinate a metrics tracker system. Finance should take the lead role in coordinating the system’s setup, tracking, and reporting. Targets for the metrics should be set based on planned continuous improvements from systems driven by cross-functional participation. They should be tied to performance evaluations through individual, functional, and company-wide compensation programs.

OPTIMIZING THE PRICING PROCESS SMEs require a good, competitive pricing strategy today to participate profitably in complex and volatile commercial environments.

Create and maintain robust costing and pricing processes. Good cost accounting and related pricing systems are essential to successful revenue generation.

Standard costing produces incorrect decisions in many aspects of profitability analysis, which in turn produces weak pricing. Accountants should keep separate cost/ profitability models for different vital processes utilized by their products.

They should then focus on pricing those products using the current process rates to determine the price. Accurate bills of materials, routing, scheduling systems, and 20 / STRATEGIC FINANCE / December 2022

other production data improve product costing and pricing.

Accountants should also be aware of the strategic purpose of pricing for different situations.

These include target pricing, total cost-plus margin, incremental/marginal pricing, or volume rebates.

Volume rebates are a great tool to use after the yearend instead of lowering prices. This helps the cash flow and serves as a buffer for cash collection or a cushion for bad-debt challenges.

With a closer watch on the competition, increase prices creatively in today’s inflationary environment.

Naturally, this comes with a trade-off price increase that may result in the departure of an existing customer. It’s always costlier to acquire a new customer than maintain one at a slightly lower margin.

Finance needs to evaluate this trade-off under scenario modeling.

Nurture customer/ supplier relationships.

These factors significantly influence cash management via working capital turnover efficiencies— working hand in hand with customers and suppliers, especially in today’s uncertainties. The faster you identify the changing needs and respond to your competition, the more you secure a substantial competitive advantage with better resiliency.

Customer/supplier relationships and operational excellence are critical prerequisites for optimal working capital.

To support good relationships, visiting key customers and suppliers, setting up good terms and

agreements, and communicating and enforcing credit policies will help.

For accounts receivable and accounts payable, to speed up the cash cycle, automate or minimize invoicing and processing cycle times, increase efficiencies in lockbox collections, and effectively manage invoice discounting or factoring policies. To optimize inventory, implement systematic reviews for stock-keeping unit (SKU) rationalization and optimization for colors, sizes, and package types with market support.

Use outsourced additive manufacturing and take advantage of 3D printing at low costs for composite parts to avoid carrying a larger volume of subassembly parts.

Outsource specialized SKUs in lower quantities to reduce design and assembly time. Pre-buy if the adequate operating ability is in place with the same extended terms.

Outsource small volume simple SKUs with larger varieties and drop-ship them to customers.

Monitor the environment and watch for red flags. It’s vital to be aware of the economic and political impacts of inflation, fiscal and monetary policies, and global effects, especially in China and Europe, including supply-chain impacts and new subsidies. Prompt response to significant current events and future expectations has implications within the competitive landscape: new entrants, substitutes, technology changes, etc.

Recognizing early signals will help mitigate the working capital build during reporting time due

to the lag time. They’re primarily visible via bottlenecks; work-in-progress buildups; rework; excessive scrap and moves; wait times; redundancies from man, machine, and materials; increased safety incidents; and customer complaints.

Red flags are the early warning signals as the leading indicators, unlike most lagging traditional metrics. Therefore, prompt attention to them is key to any successful operation. On the other hand, ACSM’s working capital study Managing Operational Performance in Volatile Times (bit .ly/3Se2mJM) reveals three best practices among top-performing companies: ■ Customer relations: putting the customer first ■ Inventory and working capital: moving from “reduce” to “optimize” ■ Costs: controlling costs while upgrading capabilities All three recommendations are crucial to balancing an SME’s longterm success and the care needed to optimize rather than reduce the working capital. Working capital management targets should align with the SME’s strategic goals. Most importantly, to be resilient in today’s volatile environment, the culture should focus on systems to attain goals and continuously improve. SF

Logan Arumugam, CMA, CSCA, CFM, CPA, ACMA, CGMA, CPIM, is the lead consultant at Manjuloga, LLC. He’s a member of IMA’s Small Business Committee and Dayton Chapter. You can reach him at larumugamcma@gmail .com.

DIVERSITY

EMPHASIZING DE&I IN EMPLOYEE RETENTION While it’s important for companies to recruit a diverse workforce, they must also ensure that they retain that talent to realize the full benefits. BY RINKU BHATTACHARYA, DPS,

D

CMA, CPA, AND SHREYANSE JAIN, CMA, CA

IVERSITY, EQUITY, AND INCLUSION (DE&I) PROGRAMS ARE becoming

more popular within companies as organizations become more aware of the benefits of workplace differences. By striving to establish a more representative employee base through targeted hiring practices, these programs help companies to foster greater diversity of thought.

A well-balanced and diverse employee pool results in alignment with diverse populations, creative internal thought processes, and responsible operations.

Research has shown that diverse companies are better at problem solving and often have better customer satisfaction metrics. Particularly, with increasing globalization, a diverse workplace is important to ensure that all of a company’s stakeholders are represented in the company’s employee and decision-making base.

For companies to realize the full benefits of diverse hiring practices, however, they must also ensure that they retain the diverse talent that they’re striving to bring in, which in turn improves the organization’s bottom line (on.bcg.com /3frbpKa).

Successfully retaining a diverse set of employees is an essential component for an organization’s ability to operate over the long term. To ensure it’s being done effectively requires incorporating data around human capital and employee retention into the company’s critical success metrics.

DE&I SOLUTIONS Diversifying Global Accounting Talent: Actionable Solutions for Progress, a study published in April 2022 by IMA® (Institute of Management Accountants), California Society of Certified Public Accountants, and the International Federation of Accountants, found that most participants, especially women, felt that there was a need to enhance the level of inclusiveness in the accounting and finance profession. As a result, the study emphasized the need to retain diverse talent.

There are several areas companies can focus on to help retain these December 2022 / STRATEGIC FINANCE / 21

DIVERSITY

employees. Here are a few to start with: Create a sense of belonging. Employees develop a sense of belonging in a workplace through sustained inclusion and a commitment to equality.

When companies sustain an equitable workplace, they in turn often create a sense of belonging.

It’s important to ensure that the workplace is committed to a true culture of fostering and promoting diverse value and thought.

A commitment to belonging promotes openness, respect, and inclusion when interacting with people of different backgrounds. It’s important to focus on equity and inclusion along with focusing on diversity.

Evaluate DE&I chal­ lenges. For a culture of continuous diversity and innovation, it’s important to continuously evaluate programs that are designed to enhance diversity within an organization.

This includes assessing and understanding problems and correcting them as they occur.

According to the Society for Human Resource Management, around 80% of companies are simply “going through the motions” of DE&I programs without “holding themselves accountable” (bit .ly/3T4Mbj9). For example, in many instances, organizations have diversity statements, but they don’t have support from the top for a full-fledged, well-developed program that’s part of the organization’s fabric.

Make DE&I a priority.

DE&I is often left to the realm of human resources rather than emphasized as an organization-wide pri22 / STRATEGIC FINANCE / December 2022

ority. It’s particularly less prevalent in discussions surrounding technical employees, such as those in finance and IT staff, as they’re often perceived to be back-office rather than forward-facing functions.

Yet these are often areas that struggle to build an employee population from all different backgrounds.

The function of the job shouldn’t outweigh the culture of the company.

To overcome some of these barriers, it’s important to ensure that when an organization is hiring with an emphasis on diversity, it considers it part of an integrated strategy rather than something that’s a nice-to-have benefit in the workplace. Companies like Facebook are touting that they hire for culture add rather than culture fit.

Culture fit suggests that employees are hired only when they embody the values and fit into the organization. Culture add, on the other hand, suggests that diverse candidates will bring different perspectives that company leaders know will add value.

This is essentially saying that companies are placing emphasis on a fluid and dynamic culture rather than a static one. (For more on culture add and culture fit, see Paul Myers, “Moving Beyond Culture Fit,” Strategic Finance, March 2022, bit.ly/3SVewIC.) BENEFITS OF DE&I Human talent is one of the greatest assets and competitive advantages for an organization. Employees are the driving mechanism within an organization.

A focus on the retention rates of employees with

A COMMITMENT TO BELONG­ ING PROMOTES OPENNESS, RESPECT, AND INCLUSION WHEN INTERACTING WITH PEOPLE OF DIFFERENT BACKGROUNDS.

an emphasis on DE&I is important for a company to maintain a truly innovative workforce. It’s also a reflection of the company’s commitment to effective governance and social responsibility. In short, this is a strong indication of a company’s ability to ensure success and sustained strategic innovation in the workforce.

Good DE&I practices for managers include empowering employees, encouraging authenticity, building trust among the workforce, and bringing diverse forces together to work toward a common goal. A Gallup poll of 7,272 U.S. adults found that 50% of employees left their job “to get away from a manager and improve their overall life at some point in their career” (Tom Nolan, “The No. 1 Employee Benefit That No One’s Talking About,” Gallup Workplace, bit.ly/3TfAplK).

Therefore, it’s important for an organization to hire managers from diverse backgrounds and experiences who in turn care for, develop, and maximize the strength of every employee.

In addition, having a good reputation for DE&I practices benefits a company. Recruitment and the

costs of employee turnover can be very expensive for a business from a practical and reputational perspective. Talented individuals often consider the reputation of a company when considering where to work and avoid places that don’t have a good reputation.

As important as hiring talent is, it’s equally important for companies to retain talent. This starts with creating diversity and belonging as part of the corporate culture. Training managers, making a growth path for employees, creating an inclusive workplace culture, and creating mentorship opportunities can help in attracting and retaining diverse talent. SF

Rinku Bhattacharya, DPS, CMA, CPA, is the CFO of Lutheran Social Services and a member of IMA’s Westchester Gateway Chapter, DE&I Committee, and Global Board of Directors. You can reach her at rinku_bhattacharya @outlook.com.

Shreyanse Jain, CMA, CA, is associate manager at VerSe Innovation. He’s also a member of IMA’s Bengaluru Chapter and DE&I Committee. You can reach him at shreyanse.khabiya @gmail.com.

CFO TO CFO

PRIORITIZING PROFESSIONAL DEVELOPMENT The CFOs of Ulta Beauty and Meritage Homes Corporation share professional development advice to boost accountants’ careers. BY DANIEL BUTCHER

W

ITH THE FINANCE FUNCTION

by AI, automation, and data analytics, among various other trends, it’s more important than ever for accounting and finance professionals to remain nimble and proactively focus on professional development.

In a conversation with Strategic Finance, Hilla Sferruzza, CFO and executive vice president at Meritage Homes Corporation, and Scott Settersten, CFO of Ulta Beauty, shared insights into best practices for gaining important knowledge and new skills.

BEING TRANSFORMED

SF: What are the most important elements of professional development?

Sferruzza: For accounting and finance professionals, you have to have a passion for the business.

Sometimes in our world, it becomes all about numbers and you forget what those numbers represent.

In my world, that’s homes and tasks completed by our operational team. Having that connection to the business and a hunger to learn is important for professional development. So it goes hand in hand with openness to change, but always be raising your hand and trying to understand what else the company is working on—how does it connect to what I do, our global mission for the company, and our strategy? That passion for the business coupled with the hunger to learn is a differentiator between the run-of-the-mill employee and those that push the envelope in their professional development.

Settersten: When I think about the elements of career growth and professional development, it’s a shared responsibility between the employee and the employer. For young people starting down their career path, it’s important to remember that it’s a continuous process that needs to be nurtured over the course of a very long career, and you should always be looking for new opportunities and ways to develop different skill sets. It’s going to be a blend of technical skill development as well as fundamental management and leadership skills. Subject matter expertise is the baseline. You have to know how to do your job well before December 2022 / STRATEGIC FINANCE / 23

CFO TO CFO

you begin thinking of other ways to develop yourself.

It’s a mix of formal and informal mentorship and coaching opportunities. You can get it through a formal relationship within your company or a mentorship program, but there are other ways to do that in a more informal fashion. It could be a mixture of pursuing internal opportunities within the company, but there are also external things like working with nonprofit boards where people can gain experience and develop different skills. There are accounting and finance-specific software or analytical tools, and you need to keep current on that. Those are the table stakes part of being a productive employee within the finance organization.

SF: What benchmarks are relevant for charting one’s progress in career growth?

Settersten: It’s incumbent upon the employee to develop an individual development plan. It’s each individual’s responsibility to think about his or her

marks and metrics as numerical computation. It’s relationship building.

The way that you can mark your success in an organization is your connectivity to your peers, supervisors, and other [colleagues] outside of your direct team. Those connections that you make are how you develop.

Understanding and being able to go to a peer with a question, presenting an opportunity to a supervisor, and assisting on a project for an unrelated function within your organization are the keys to success.

Underlying it all is general knowledge of the business. If you want to succeed you have to understand the business itself, not just your narrowfocus functional area. Creating opportunities to form as many connections as you can throughout the business is critical to benchmarking success.

SF: How can senior executives help longer-tenured team members and new hires to continue to improve their skills and knowledge?

Sferruzza: One area where you can challenge existing team members

presentations. As you move up the ranks, that’s going to be a part of your job, so it’s really important to hone those skills. Find opportunities to have your team members step in for you in a team meeting—or even an external event—and make the presentation.

Fundamental to all these different ideas is to get out of your box.

It’s easy in accounting and finance to fall into [defined roles]. “I have month-end duties. This is what I do on Monday; this is what I do on Tuesday,” and you get stuck in a rut. It’s important to break out of that box every once in a while, remember why you love what you do, and connect with your functional expertise and the business as a whole. Challenging yourself and your team to get out of the comfort zone is really important.

Settersten: For me, the overriding notion is to share my insights, experiences, and thoughts about the business, the organization’s strategies, and what we’re doing to execute to drive results in the business. I have various functions reporting up through me: real estate,

“Remember why you love what you do, and connect with your functional expertise and the business as a whole. Challenging yourself and your team to get out of the comfort zone is really important.”

—Hilla Sferruzza

career road map, ambitions, and objectives and then build a plan that has check-in points that provide an opportunity to take inventory and measure progress. Develop a plan; get input from your supervisor, manager, colleagues, and mentors; set clear, measurable objectives; and have a way to manage against those over a period of time. And make sure you obtain feedback from people along the way to ensure you’re making progress against your plan.

Sferruzza: As much as we like to measure things in the accounting and finance world, don’t look at bench24 / STRATEGIC FINANCE / December 2022

who have been with you for a while is through UAT [user acceptance testing].

There’s always something new and different happening in the IT [information technology] world, and if it’s systems-related, the accounting and finance team members are usually the system functional experts. Having them test the system, particularly when it doesn’t relate to accounting and finance issues, helps them understand the business better.

Another area where you can push team members to challenge themselves is through public speaking or

investor relations, loss prevention, core finance, accounting, and compliance.

I regularly gather groups of new hires together for a CFO lunch meeting. It doesn’t matter what particular functional area they work in. I share with them the history of the company, my personal story line around my family, how I found my way to Ulta Beauty, and what keeps me engaged and excited about the business. Then I describe how I see their core role and responsibilities within the company, including good stewardship and ethical standards like “When you see a problem, tell someone

“Develop a plan; get input from your supervisor, manager, colleagues, and mentors; set clear, measurable objectives; and have a way to manage against those over a period of time.”

—Scott Settersten

about it” to set expectations for what we want to see from them.

Then we cover career development programs and opportunities, but stress that it’s a shared responsibility, and they need to be the primary driver.

With new officers or people that we’re grooming to be future leaders of the company, I spend time sharing thoughts about the strategy of the business and what we’re doing tactically to drive results across the business. I talk with them about how to influence decisions. We’ll always debrief after important meetings to assess why we positioned an issue a certain way, what the reaction or pushback was from key decision makers, if any, what did we learn from that, and what was the feedback from the audience on a particular topic. We give our people many opportunities to present to the executive team. Interpersonal skill development is the key for finance professionals, and so to continually polish that and get them ready for the next stage of their career is probably the most important learning experience they can have. Afterward, I always make sure I give them feedback on how it went, how it was interpreted by the audience, and how we can make it better next time.

SF: To what extent is offering professional development, coaching, and mentorship opportunities the responsibility of the C-suite, team leader, or manager?

Settersten: People need to understand that it’s a shared responsibility, and I believe younger employees understand that point these days;

they’re very self-sufficient in many ways with social media and other platforms. They’re starting their careers with internships much earlier than many of us ever did, so they know the world is complex and they’re getting up to speed a lot quicker than we ever had the opportunity to do before. So, they get it. Companies are also increasingly investing more in their people than ever before. If you want to draw and retain the best talent, you have to have programs in place to develop your people internally. [Professional development requires] people working together, but it’s up to the employee to take advantage of the available opportunities.

You can’t be passive. You need to actively engage in your career progression. So whether that’s during coaching or review sessions or being proactive and looking for opportunities and inquiring, engaging, and then following through on it, make sure you’re taking follow-up action to take advantage of all available opportunities. Getting back to the mix of internal and external opportunities, don’t have tunnel vision, [thinking that] there’s only one way to do this. There are many different ways to develop your skill sets; some you can do on your own time, some on the company’s time, and some company sponsored. You have to keep an open mind to all opportunities, be proactive, and take advantage where you can.

Sferruzza: You can probably make people do some sort of training and track it and make sure that they’re doing what’s needed, but that’s typically reserved for cybersecurity, sexual harassment and ethics

training. You do it because you have to do it. Hopefully, we’re not making you do professional development; you have to want to do it. That’s what’s going to set you apart from the pack. Especially in accounting and finance, where there are many folks with a similar title hoping to get to the next level, it’s a pyramid.

Not everyone’s going to be able to move up to the next level and even fewer people to the level above that.

So, you really need to want it. The employee needs to be hungry [to take on more responsibilities]. The manager’s opportunity is to encourage it, make them aware of the resources available, and monitor progress, but the employee fundamentally needs to own it. Having said that, the company needs to make sure those resources are available and easy [to access].

Today’s employees are extremely tech-savvy, so we need to make sure that we’re providing development opportunities in a manner that aligns with what they’re looking for in a scenario that’s safe, so virtual solutions are very helpful. We spend a tremendous amount on employee development, particularly as we’re growing our younger staff, and there’s plenty of research that millennials value the experience, not just the outcome, so we want to make sure that we’re viewed as a company that provides you with experiences that lead to growth opportunities.

For my team, we have advanced Excel learning classes, which is a functional skill set in our business. It’s something that we need; you need to know how to be able to [master] Excel and financial modeling—that’s a given.

December 2022 / STRATEGIC FINANCE / 25

CFO TO CFO

It gives you a leg up in your everyday business, and our library of available professional development is open to every employee in the entire company.

Follow your passion, and it might be learning for learning’s sake, or it might give you some more insight or teach you something about yourself, where you say, “I didn’t realize I had a passion for this,” or “Now that I get this [concept], maybe this is a path that I should push a little further in my professional development with my supervisor or [career] coach.”

Having that whole suite of professional development tools available is important. We have a lot of curated solutions for the skills that you [need to] have in our industry, but we also buy professional development classes, some virtual, that are available to anyone in our company.

It doesn’t have to be something that’s particular to [the finance function] if you’re learning about public speaking skills or how to share bad news. If you’re a new supervisor and have to have a tough conversation with an employee, there are people who know how to train to those skills much better than we do. We also subscribe to third-party providers to allow our employees to gain access to a wide library of professional development classes free of cost. In fact, we incentivize them; they get points for taking these classes that they can use to buy stuff on our company store. We think it’s a good investment in themselves.

SF: Can you offer advice for career coaching and mentoring?

Settersten: Everyone builds their own method. Be yourself—your authentic self—when you’re thinking about how you’re going to coach and mentor people. Always accentuate the positive; when you’re giving feedback to people, make sure that you’re recognizing good work consistently in front of their peers and superiors, so that people feel like, “You’re thinking about me, you care about me, and you want to see me do well.” That has to be balanced with [constructive criticism]. If you see something that’s going to be a significant roadblock for someone, you need to communicate 26 / STRATEGIC FINANCE / December 2022

that to them so they get the benefit of your insight. That shows a level of caring for individuals as well.

Finance people are by nature more risk-averse than your average employee across the business, so sometimes they take a little bit more of a nudge to push them to take a chance or a risk, whether it be a promotion or some other new initiative to get them stretched outside of their box. Often they need a little bit more motivation to take that next step.

For younger employees, don’t wait for a formal mentoring program. If you see somebody in your day-to-day activities that you respect or like their style, don’t be too shy to approach them. Most people are more than willing to share their time to help younger employees develop.

Sferruzza: It may seem a little counterintuitive, but I’ve had the most success when I mentor folks not in my functional area. There’s too much emotional baggage when you’re mentoring someone on your own team because you’re already their direct or indirect boss, and it’s hard to be open about, “I’m experiencing frustration with this employee; how do I handle that?” Because you probably know what employee they’re talking about.

It gives everyone a little bit of freedom if you mentor someone outside of your functional area, and maybe you’ll both learn something.

We want to share our knowledge, that’s why we’re mentors, but it’s really important to listen. The first couple opportunities when I mentored people, I had so much information to share, I talked a lot and forgot to listen to what advice they needed. I gave them good advice on everything, every topic under the sun, but didn’t tailor it to them, so they probably left my office a little overwhelmed and not really sure what to do with the 50 pieces of advice I gave them.

Remember to listen first. I have to make a conscious effort to remember this. Some of the things that we think aren’t that fun and interesting are really fun and interesting to people coming up the corporate ladder looking for opportunities. We have to put our mental headspace back to where we were when we were [at the expe-

rience level of] the person that we’re mentoring and create opportunities or make recommendations on topics that may seem mundane [to experienced professionals]. They may be fun and exciting to someone coming up the ranks, so remember what it was like to be at that level and what opportunities seemed interesting then. I always try to remember that [early-career] perspective.

SF: What do you see in your crystal ball as it relates to the future of skills acquisition and professional development?

Sferruzza: I see the intersection of operations and finance becoming very blurry. If you ask me what kind of a CFO I am, I’d say I'm an operational CFO. I'm heavily involved in strategy and operations. I’m not our COO; we have one of those, and he’s excellent. But we intersect significantly more today than we did 15 years ago when I joined the company. So I see a migration to operational finance with some of the finance and accounting staff becoming subject matter experts to help a particular area with their accounting and finance needs, where you also have a little bit more insight into an operational area. You’re still a finance functional expert but with a more versatile skill set.

Settersten: It comes back to critical thinking skills. The world continues to change at an accelerated pace, whether it’s your business or career trajectory. Critical thinking skills include being able to collaborate, being open to other opinions, and interacting with other people to come to a consensus. Be openminded when thinking about business challenges, and solicit feedback from across the enterprise to come up with the best solution to whatever problem you’re tackling. General business acumen [is crucial], so think more like a general manager and don’t focus only on finance. SF

Daniel Butcher is the finance editor at IMA and staff liaison to IMA’s Committee on Ethics. You can reach him at daniel.butcher @imanet.org.

FALL• WINTER• SPRING•SUMMER

MANAGEMENT ACCOUNTING

Quarterly

EVERY QUARTER, IMA® brings you the in-depth information you want and need.

Management Accounting Quarterly is a refereed online journal that contains in-depth articles by and for academics and practitioners of accounting and financial management.

Some of the subjects covered are cost/management accounting techniques, ABC/ABM, GRC, statistical process controls, target costing, accounting education, theory of constraints, internal controls, technology and software, methods of calculating stock options, new theories in finance and accounting, and much more.

Visit www.imanet.org/insights-and-trends/management-accounting-quarterly

MANAGEMENT ACCOUNTANTS

AND

CORPORATE COMPLIANCE Data analytics capabilities, incentives for reporting wrongdoing, and innovative training can help accounting professionals mitigate the risk of corporate misconduct.

BY KELLY RICHMOND POPE, PH.D., CPA, AND LOREAL JILES

28 / STRATEGIC FINANCE / December 2022

D

espite efforts taken to mitigate workplace misconduct, it still happens.

Compliance programs are essential to managing a company’s exposure to the risks of workplace misconduct.

Traditionally, they’ve fallen under the purview of legal departments, but technological advances and heightened complexity in the business landscape have prompted calls for a more integrated approach to addressing organizational compliance. That’s where management accountants, working alongside executive leadership, can play a valuable role in ensuring corporate compliance.

When an organization is investigated for a potential ethics violation, a prosecutor will always ask whether the company has a well-designed compliance program in place. The prosecutor will examine how the organization has identified, assessed, and defined its risk profile and the degree to which the compliance program devotes appropriate resources to the risks. For those in the United States, the Department of Justice (DOJ) outlined in 2020 three key questions to assist prosecutors in evaluating an organization with a potential ethics violation: 1. Is the corporation’s compliance program well designed?

2. Is the program being applied earnestly and in good faith?

3. Does the corporation’s compliance program work in practice?

To meet the needs of the complex business landscape, changes must be made to current compliance programs.

Research by Hui Chen and Eugene Soltes shows that two key factors inhibit compliance program effectiveness (“Why Compliance Programs Fail—and How to Fix Them,” Harvard Business Review, March-April 2018, bit.ly/3btfTgL). First, compliance programs are often driven by a check-the-box approach, focused on fulfilling requirements on paper without adequately understanding the impact they have on employee behavior. Second, many organizations continue to rely on the same core tools—hotlines, codes of conduct, and traditional training—despite evidence of their limited effectiveness.

Management accountants can help mitigate the risk of corporate misconduct by modeling and monitoring employee behavior. Long regarded for their compliance, control, and risk management skills, management accountants are also esteemed for their ability to model ethical and professional conduct, including compliance with relevant laws and regulations, and their expertise in strategy formulation and implementation. The following three strategies will help management accountants contribute to the revamping of internal compliance programs: 1. Using data analytics to gain insights that enhance the effectiveness of compliance programs.

2. Designing incentive programs to increase internal reporting of fraud and misconduct.

3. Increasing engagement and knowledge retention in compliance training through storytelling and gamification.

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Statement on Management Accounting This article is adapted from the IMA® Statement on Management Accounting (SMA) Ethics in the 21st Century: Management Accounting Practices for Robust Compliance Programs, published in October 2022. It has been edited and abridged to fit in Strategic Finance. The full report can be found at bit.ly/3ePu6GW. And don’t miss the special edition of IMA’s Count Me In podcast from October 20, 2022, where coauthor Kelly Richmond Pope discusses the SMA. The podcast is available at bit.ly/3zvnsgg.

Gain Insights through Data Analysis

The technological advances of the Fourth Industrial Revolution, such as AI, 3D printing, robotics, the Internet of Things, and quantum computing, are key catalysts for management accountants’ accelerated data analytics skills development, according to Chen and Soltes. As Chris Mishler, a past chair of the IMA® (Institute of Management Accountants) Technology Solutions and Practices Committee, said, “Data analytics skills are a critical pathway for management accountants to know the right questions to ask and how to get the answers their organizations need to succeed” (bit.ly/3a8feRJ). Finance functions now marry financial and nonfinancial data when implementing leading-edge analytics, which can drive down costs, improve decision making, and maximize customer value.

Many organizations strive to become data-driven, but most haven’t achieved that objective yet. The 2021 Big Data and AI Executive Survey of 64 C-suite technology and business executives from Fortune 1,000 companies (including American Express, Bristol Myers Squibb, and McDonald’s) found that 76% of survey participants have yet to forge a data culture, and 59% admit that they aren’t competing on data and analysis (bit.ly/3hrGH42).

For organizations that come under DOJ scrutiny, prosecutors are now asking various teams across the organization that are involved in investigations whether they have access to the right data. If management accountants are fully integrated into the compliance program, their holistic view of the organization and its existing information systems can aid in the design and execution of compliance programs.

From utilizing Big Data and embracing data visualization platforms to implementing automation and voice recogni-

tion, data analytics options can be utilized to mitigate risk and ensure organizational compliance.

Incentivize Internal Reporting

One effective way to teach employees about compliance is to lead with a values-based culture—specifically, a values-based compliance culture. According to the Society for Human Resource Management (SHRM), a values-based culture is shaped by a clear set of ground rules establishing a foundation and guiding principles for decision making and actions, along with a sense of community (bit.ly/3NAtjVH).

An essential feature of values-based compliance is a commitment to facilitating “open reporting” or mechanisms for raising concerns. Characteristics of values-based compliance programs include: ■ Clear policies and expectations ■ Engaged employees who own and actively participate in the program ■ Use of metrics and data analytics ■ Knowledge sharing of lessons learned throughout the company ■ Ongoing training programs that are current and interesting Organizational incentive programs can help empower and engage employees to report misconduct. According to the National Whistleblower Center, rewards for internal reporting are effective because “(1) they promote positive behavior by employees who witness wrongdoing, and (2) they create a deterrent effect within the market through large award payments” (bit.ly/3OPHEP2).

Commitment to confidentiality is crucial for some, if not all, employees to decide to speak up. If confidentiality isn’t an option, incentives can be an effective way to inspire employee reporting. Employee incentives can include monetary and nonmonetary rewards. Monetary rewards include “spot awards,” which are bonuses that are distributed close to the time of the action that prompted the bonus, rather than through an annual or traditional performance cycle.

Nonmonetary incentives could include positive performance feedback, rewards based on personal interest, flexible hours, penalties for retaliation, and, if appropriate, internal recognition through organizational communications.

Whistleblowers—people who report an alleged dishonest act—are the most effective information source in fraud detection, according to the National Whistleblower Center. They provide valuable firsthand information that may not otherwise have been discovered. These high-quality leads are crucial to protecting stakeholders and recovering ill-gotten gains.

A 2021 survey of 2,000 office staff across the U.S. and the United Kingdom conducted by Vault Platform found that 75% of U.S. office workers have witnessed some form of workplace misconduct during their careers. Of those who experienced workplace misconduct in the 12 months before the survey was published, 14% ended up leaving their jobs.

Workers who took time off in 2021 due to their experience with workplace misconduct missed, on average, six days of work, or a total of 43 million sick days. This resulted in a $8.54 billion loss for the U.S. economy.

Whistleblowers are the most effective information source in fraud detection.

In addition, more than two-thirds of employees who observed misconduct didn’t report it. The reasons are obvious: In 82% of fraud cases where the whistleblower’s identity was revealed, the person reportedly was fired, quit, or had their responsibilities significantly altered (The Trust Gap: Expectation vs Reality in Workplace Misconduct, bit.ly/3S6ho5n).

Organizations with whistleblower programs that seek to incentivize individuals often provide high-quality tips that lead to successful enforcement actions. Since the inception of the U.S. Securities & Exchange Commission (SEC) whistleblower program in 2010, the SEC has recovered more than $2.5 billion in financial remedies from whistleblower tips (bit.ly/3zlhvBM). The program has significantly improved the SEC’s ability to detect fraud schemes domestically and abroad, thereby significantly improving investor protection. It’s worth noting that the SEC has received tips from whistleblowers in 123 countries outside the U.S. and made substantial payouts to foreign whistleblowers (bit .ly/3PJtBLJ).

Enhance Compliance Training

Organizations struggle with compliance training for a variety of reasons, including: Too much, too soon. Many organizations attempt to combine compliance training with onboarding new employees. Consequently, they spend a minimal amount of time on compliance concepts. Although incorporating compliance into onboarding sends an important message that compliance is important within the organization, it typically isn’t the right time. In order to retain the inforDecember 2022 / STRATEGIC FINANCE / 31

TABLE 1: SEVEN PRINCIPLES OF DIGITAL STORYTELLING 1. Point of View

The main point of the story and the perspective of the author in relation to the story

2. A Dramatic Question

A key question that keeps the viewer’s attention and will be answered by the end of the story

3. Emotional Content

Serious issues that come alive in a personal and powerful way and connect the audience emotionally to the story

4. The Gift of Your Voice

A way to personalize the story to help the audience understand the context and to get a stronger sense of the person behind the story

5. The Power of the Soundtrack

Music or other sounds that support and embellish the story

6. Economy

Using just enough content to tell the story without overloading the viewer

7. Pacing

The rhythm of the story and how slowly or quickly it progresses

Source: University of Houston, “About Digital Storytelling: The 7 Elements of Digital Storytelling,” bit.ly/3R3l5YY.

mation, employees need to spend time learning the rules and regulations. Trying to cram it into the onboarding process when employees are also learning about other ins and outs of the organization reduces retention and understanding.

SOLUTION: Start with the compliance topics that matter most to your organization. Leveraging a holistic understanding of overall business processes and many compliance regulations, management accountants can play active roles in compliance topic selection and prioritizing compliance course content and timing to aid in retention of important information.

The courses are too long. Long courses tend to be boring and lack the necessary engagement to influence future behavior.

SOLUTION: Research by University of California Irvine computer sciences professor Gloria Mark found that the average human attention span is 40 seconds before it switches to another task (bit.ly/3ufefpE). Yet many organizations rely on text-heavy slides to convey important compliance topics. Utilize “microlearning” strategies so courses can be broken into bite-size lessons that answer one question at a time. Microlearning is an organizational training method that delivers short bursts of on-demand content for learners to study at their convenience. Learners are more likely to retain information presented in this way. Microlearning courses can employ various media forms such as images, infographics, text, videos, and games to ensure engagement throughout the course.

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The courses don’t allow for application. Employees need to put compliance training into practice before an issue arises, but they often don’t have the opportunity to do so. Allowing learners to see themselves immersed in the scenario will contribute to greater knowledge retention.

SOLUTION: Gamification allows employees to practice compliance issues and utilize scenario-based learning.

Scenario-based learning is an instructional strategy that uses interactive scenarios as the basis for learning. These scenarios imitate real-life situations and train the learner in complex decision making via simulated work challenges. Ethics and fraud scenarios make for excellent scenario-based learning courses.

Storytelling and gamification are two methods that management accountants can use to recharge internal compliance programs that are suffering from the previously mentioned issues. Given that our brains are hardwired to respond to stories, story-based training can be an effective, cost-efficient way to upgrade internal employee training programs. Specifically, digital stories have the added advantage of being potentially multimodal (words, images, sound, and movement) and easily shared within an organization.

When developing engaging content, it’s important to consider the seven principles of digital storytelling developed

by Joe Lambert in his book Digital Storytelling Cookbook (see Table 1). Utilizing storytelling and gamification as training techniques can invigorate a traditional compliance program.

Management accountants can leverage existing expertise to contribute to the betterment of compliance training initiatives through these approaches. Although many people

Ethics and Whistleblowing Resources from IMA Articles Tala Khalifeh, “Theranos: Cautionary Tale of Ethical Failings,” Strategic Finance, June 2022, bit.ly/3Wg9V5P Daniel Butcher, “Compliance Training Is Key to Preventing Fraud,” Strategic Finance, November 2021, bit.ly/3NoV1pK Patrice Schiano and Arcady Zaydenverg, “Whistleblowing Laws Evolve,” Strategic Finance, November 2021, bit.ly/3UeFcEi Daniel Butcher, “Lessons from an MLB Pitcher and Whistleblower,” Strategic Finance, November 2020, bit.ly/3zvGCCN Jeffrey Grobart, “Preparing for Whistleblower Complaints,” Strategic Finance, September 2020, bit.ly/3h1u1k0 Daniel Butcher, “Increase Your Whistleblowing IQ,” Strategic Finance, January 2020, bit.ly/3sNjoUW Jamie Seitz, Terry Truitt, Michael Bruce, and Michael Wiese, “The Dodd-Frank Whistleblower Provisions: An Empirical Examination of Effectiveness Using the Theory of Planned Behavior,” Management Accounting Quarterly, Winter 2020, bit.ly/3tRIAL7 Douglas M. Boyle and Daniel J. Gaydon, “SEC Whistleblower Program Expands,” Strategic Finance, November 2019, bit.ly/3b0geCs Tara Shawver and Lynn H. Clements, “Whistleblowing: Factors that Contribute to Management Accountants Reporting Questionable Dilemmas,” Management Accounting Quarterly, Winter 2008, bit.ly/3WmGpeH

Count Me In podcast Episode 190, “The Ethics and Risks of Whistleblowing,” July 11, 2022, bit.ly/3sM6YfL CPE courses Action Required - Navigating Ethical Dilemmas, bit.ly/3fjy4I4

might not consider management accountants to be natural storytellers, storytelling is an integral component of the management accountant’s role. Part of their job is to tell the story behind financial and, often, operational data, and they’re increasingly relied upon to do so through data visualization tools. Their experience in telling the story behind the numbers, combined with knowledge of the business and familiarity with compliance regulations and controls, positions management accountants to help create stories that communicate key policies or cultural aspects.

Much of what can go wrong with compliance training has to do with the use of antiquated, inflexible training methods, like daylong seminars with a lecturer who delivers content from static slide deck presentations. Alternatively, games, branching scenarios, and simulations allow for storytelling where dangers and disasters can be framed as “adventures.”

Games in which learners are required to assess risk profiles, recommend risk mitigation strategies, identify potentially fraudulent activity, and report corporate misconduct can increase the likelihood that employees understand actions they’re expected to take and feel more comfortable taking those actions. Additionally, badging (awarding digital badges at course completion that can be featured on social media platforms) can allow employees to share and celebrate their accomplishments, as well as reinforce commitment to a positive compliance community.

When attempting to incorporate gamified training content, consider the following: ■ Choose real-world case facts to gamify.

■ Provide learners with the option to solve the game by providing clues throughout the learning experience to increase engagement.

■ Ensure the game introduces a realistic conflict so that an emotional connection is made between the dilemma and the learning objectives.

The DOJ’s 2020 memo recommended that compliance officers have access to all data. The new demands of compliance professionals present an opportunity for accountants and financial professionals to offer value-added guidance to aid in ensuring organizational compliance. Upskilled management accountants equipped with data analytics capabilities can better analyze real-time data to help direct compliance teams to areas of concern. An incentivized employee population can encourage more people to come forward if they have witnessed questionable practices, and more innovative training can energize employees and help promote a positive work environment. SF

Kelly Richmond Pope, Ph.D., CPA, is the Dr. Barry Jay Epstein Endowed Professor of Accounting at DePaul University and the IMA Research Fellow for Ethics and Corporate Governance. She can be reached at kpope2@depaul.edu.

Ethics: The Power of Trust, bit.ly/3WjUOIQ Mission Impossible: When Benchmarks Undermine Ethics, bit.ly/3UeeRX0

Loreal Jiles is vice president of research and thought leadership at IMA, a member of IMA’s Technology Solutions and Practices Committee, and a member of IMA’s San Gabriel Valley Chapter. She can be reached at loreal.jiles@imanet.org.

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AI AND DIGITAL DISCRIMINATION By contributing to responsible AI practices and risk mitigation, management accountants and other financial professionals can minimize AI discrimination.

BY ARIF PERDANA, PH.D., CA, AND W. ERIC LEE, PH.D., CPA, CITP, CGMA, CFE

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W

hile automated decision making, with its algorithms often described as AI, serves as a catalyst for efficiency, it can also have potentially harmful consequences. Typically viewed as innocuous and fair, these decision-making algorithms may cause and even amplify biases, creating or perpetuating structural inequalities in society.

The phenomenon of digital discrimination due to AI bias has become so prevalent that a study published by the U.S. Department of Commerce found that people of color are more likely than whites to be misidentified by AI-based facial recognition technology. In fact, the list of cases involving AI bias has continued to grow over the last several years, extending to increasingly complex processes, with grave consequences.

For example, with regard to police work, there have been numerous wrongful arrests resulting from false hits by facial recognition software. In healthcare, an AI algorithm that was supposed to identify high-risk, chronically ill patients and assign them additional primary care visits wound up favoring white patients over Black patients. Using cost as a proxy in the algorithm, however, often ended up causing a racial bias due to an inherent difference in healthcare needs between Blacks and whites, even when both groups spent comparable amounts.

These anecdotes illustrate the unintended biases that could result from automated decision-making systems commonly used in such varied fields as marketing, insurance, healthcare, law, and finance. With a multidisciplinary approach and a coordinated effort, however, there are solutions to mitigate such biases—an effort to which management accountants and other financial professionals can contribute.

One Company’s Cautionary Tale

In 2016, Microsoft developed an AI application that featured a chatbot named Tay that could handle written conversations in real time. Tay was developed following the earlier success of Xiaoice, which had been produced in China in 2014 and was hailed as an “emotional” computing device for its ability to write poems, compose songs, and even become a virtual chat partner, garnering millions of followers on Weibo and WeChat.

Initially, Tay received an overwhelmingly positive response from Twitter users, interacting with them more than 100,000 times within a 24-hour period. Yet Tay quickly went from friendly and tolerant to racist and sexist.

A day later, following the public outcry over Tay’s behavior, Microsoft removed it from Twitter.

This came as a surprise to many experts, as Tay and Xiaoice were often regarded as twins. Both were from Microsoft and used the same technology. So how could they behave so differently?

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AI developers are like parents who need to provide a suitable environment for their children to thrive.

To examine this discrepancy, it’s necessary to understand the crucial role that data plays within the sphere of AI. Operating from the platforms of Weibo and WeChat, Xiaoice was exposed predominantly to users within one country. In contrast, when Tay initially launched on Twitter, it interacted with a widely diverse group of users from around the globe, with the ensuing interactions often degenerating into uncivil conversations. As an unintended consequence of AI, Tay learned from the data that it received in such an environment and proceeded to mimic and make similar extreme statements.

Bias Creep in AI Platforms

In a way, AI developers are like parents who need to provide a suitable environment for their children to thrive. While children often have biases passed down from their parents, they can also learn from a wide range of societal biases prevalent in their environments. Neither is AI immune from bias. The data used by AI developers can similarly contain a myriad of implicit (also known as “algorithmic”) biases, either because of existing societal biases influencing algorithmic developments or due to biases embedded within the training data.

Amazon’s automated tool for recruiting new hires, for example, has been shown to exhibit both algorithmic and data biases. The automated screening system was taught to recognize word patterns instead of relevant skills in job applications. Moreover, since the system was exposed to data primarily from a largely male applicant pool over the past 10 years, the screening device inadvertently favors résumés from men over those from women.

Another example of an apparent biased automated decision-making system is the Correctional Offender Management Profiling for Alternative Sanctions (COMPAS), a tool that many courts in the U.S. use to assess the likelihood of a defendant becoming a recidivist. This application collects information related to defendants’ prior offenses, education, and employment history. Although the application doesn’t collect data on race, investigative journalism organization ProPublica found that Blacks are “are almost twice as likely as whites to be labeled a higher risk but not actually re-offend,” while whites are more likely to be labeled a lower risk to re-offend but then go on to commit other crimes. (See Julia Angwin, Jeff Larson, Surya Mattu, and Lauren Kirchner, “Machine Bias,” bit.ly/2Hl2rgn).

Similarly, critics say that PredPol, an application that helps police officers deploy more security personnel to crime-prone areas, often ends up predicting those areas populated predominantly by Blacks as having a higher crime rate potential than those inhabited by whites. Police departments that have used PredPol have reported mixed results, and some departments have stopped using the software altogether.

Ethical Challenges

A difficult conundrum exists concerning biases in automated decision making. In reality, biases resulting in discrimination can be both helpful and dangerous. For example, when AI is used as intended in accounting and auditing, it can flex its discriminatory abilities to

help detect or predict activities that may be potentially fraudulent. Financial institutions can also use automated decision-making techniques to better manage their risks when debating whether to extend credit to both potential and existing customers. In effect, by using AI in credit scoring, financial institutions can determine an individual’s potential risk of default. Similarly, in the financial technology space, crowdlending companies assign scores to potential projects, thereby allowing lenders to select projects that fit their desired risk profiles and appetites.

While these applications have clear advantages, a major problem with using automated decision-making tools is that the associated vetting techniques are rife with biases. A study from the University of California, Berkeley found that both online and in-person lenders charge African American and Latino borrowers much higher interest rates, earning 11% to 17% higher profits on their loans, respectively, when compared to those of other borrowers. Another study from Stanford University suggests that the observed differences in mortgage loan approval rates are primarily due to minorities and low-income groups having less readily available information on their credit histories.

In certain situations, biases can further pose an ethical challenge, sometimes with dire consequences, when AI discriminates based on data that’s related to ethnicity, race, religion, and/or gender due to certain high correlations among the data. Nevertheless, simply removing these variables may not resolve the observed biases.

This is because other seemingly unrelated variables may also indirectly serve as proxies. For example, even though COMPAS didn’t collect data related to race, the defendants’ educational backgrounds and addresses may introduce biases when aggregated and used as training data.

Similar cases of bias have involved Apple Card and a host of insurance companies, including Allstate, GEICO, and Liberty Mutual. Lawsuits were filed against these

TABLE 1: ETHICAL IMPLICATIONS OF AUTOMATED DECISION MAKING Negative Effects of Digital Discrimination ■ Loss of opportunity ■ Loss of liberty ■ Economic loss

Risk Mitigation Strategies ■ ■ ■ ■

Data governance and curation System development life-cycle review Policies and regulations Human-algorithmic interactions

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companies for the alleged discrimination in their automated decision-making processes, whereby their algorithms systematically discriminated against certain gender and minority groups—even though these companies comply with the prevailing regulations and hence don’t collect data related to gender, marital status, and race. In Oregon, for example, women were overpaying for basic auto insurance by an average of $100 (or roughly 11.4% more) compared to men. It turns out that even though no gender or race-related data was directly collected, other indirect demographic proxies like ZIP codes may often lead to generalizations of locations typically inhabited by Blacks or Latinos.

Promoting Responsible AI Practices

For individuals, businesses, and communities, automated AI decision making, if not managed properly, could ultimately

lead to restriction of certain liberties, missed opportunities, and economic losses. In addition, as companies increasingly use AI for fraud analyses, insurance claims, and payment eligibility, potential bias-related pitfalls may arise.

Overall, organizations should remain vigilant toward responsibly implementing automated decision making. This includes instituting preventive actions aimed at minimizing potential risks of biases as well as corrective and compensatory measures when things go awry. In this regard, organizations would do well to consider adopting risk-mitigation strategies that will lead to responsible AI practices (see Table 1). These strategies fall under the categories of data governance and curation, system development life-cycle review, policies and regulations, and human-algorithmic interactions. Let’s take a closer look at each one.

Data Governance and Curation

Data governance is critical for organizations because it helps them solve the “first mile” and the “last mile” of data prob-

TIPS FOR CLEAN DATA Data cleansing involves correcting incorrect, incomplete, redundant, and erroneous data as well as removing any potential bias in a data set. It involves weighing various variables in the data set and often removing the unimportant ones or those that are irrelevant to the analysis.

Clean data means that the data is usable, has no bias, and is of high quality (accurate, valid, complete, and relevant). Data cleansing isn’t easy, however. Here are some tips:

1. Perform data hygiene. This includes running spell-check; removing duplicate variables or lines, as well as extra spaces; fixing numbers and signs; and formatting clearly.

2. Examine the data sufficiently before discarding one or more variables.

3. Be careful about excluding seemingly unimportant variables because the analysis could end up with a biased model. For example, if a certain age group (60 years or older, for example) makes up 10% of the data set, while the rest of the data includes those younger than 60 years old, the model will end up favoring this younger set of adults.

4. Ensure data types are consistent in terms of date, string, float, and integer data.

5. Depending on the purpose of the analysis, effectively deal with missing data by filling it in or by deleting certain variables from the data set.

6. Use appropriate techniques to deal with unbalanced data (for example, by resampling the training data set).

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lems. The “first mile” problem relates to data collection; it’s of utmost importance that the data, besides being sufficient and relevant, is of high quality and complies with regulations governing personal data protections. The “last mile” issue occurs when unexpected problems arise after the automated decision-making tool has processed the data. When that happens, data governance plays a role in determining which relevant data the company should use for automated decision making, who has the authority to access the data, how the data should be shared, and how it should be retained within an organization as well as across organizations.

There should be strict protocols regarding how data governance for automated decision-making tools should proceed and whether sufficient data has been collected in the first place. (For help on ensuring “clean” data, see “Tips for Clean Data.”) For example, American Banker estimates that about 14% and 17% of Hispanic and African American households in the United States, respectively, lack access to affordable banking. This problem is compounded by the fact that many members of these minority households don’t have government-issued photo IDs, thereby often leading to misinterpreted or missing data. Organizations thus need to be cautious when dealing with the algorithms used to process erroneous data. At a minimum, the results of automated decision making should be evaluated carefully in order to screen out any cases of possible bias.

Even though both the underlying models and data interact to produce results, AI developers should first look at the data rather than attempting to tweak the code when the models behave in unexpected ways. AI developers must carefully consider whether the use of proxies or other related variables may lead to biased results. From an ethical standpoint, biases could become problematic and unfair when any decisions discriminate on the basis of ethnicity, race, religion, and/or gender.

Alternatively, AI developers may consider using behavioral proxies. For example, in China, companies like Lenddo and Yongqianbao have started using a smartphone’s battery life, among various proxies, to determine customers’ credit scores, with the thinking being that individuals who regularly charge their smartphone may engage in other positive behaviors. Other variables, such as browsing history, time spent on social media, and the number of days taken to pay bills, could similarly be used as behavioral proxies.

Naturally, using customer data for predictive analytics can have negative consequences in the absence of good data governance. An effective data governance policy can help to protect against financial and reputational risks caused by data breaches, with management accountants playing a key role in helping companies better collect, store, and manage their data. Incorporating data ethics into a company’s corporate culture can help maintain data sensitivity and transparency, thereby leading to improved regulatory compliance and risk mitigation in relation to data use.

System Development Life-Cycle Review

Problems can also exist in the system’s development life cycle of automated decision making, such as in any of the

LIME AND SHAP In both the Local Interpretable Model-Agnostic Explanations and the SHapley Additive exPlanations tool kit—known as LIME and SHAP, respectively—a trained, automated decision model is used as input to a post hoc statistical analysis. The methods are then used to develop decision logic that explains how the model used in the automated decision arrives at its decisions.

Using LIME, analysts can explain a single prediction (for example, that the probability of a loan default is less likely when an individual’s education and/or annual income is higher).

Alternatively, SHAP explains the overall behavior of the model: for instance, the effect of an independent (feature) variable on the dependent (target) variable, such as in a situation where high annual income lowers the probability of default.

successive phases of concept, design, development, testing, operation, and decommissioning. To resolve these problems, several tools are available, including AI Fairness 360, Local Interpretable Model-Agnostic Explanations (LIME), and the SHapley Additive exPlanations (SHAP) tool kit.

LIME and SHAP can help organizations to better understand how automated decision-making systems generate their results (see “LIME and SHAP” for more). Recent research has also demonstrated how these tools can help auditors improve the transparency, interpretability, and accountability of AI use in audit tasks.

In addition to proper algorithmic design in order to mitigate bias, AI developers should also explain the impact of any resulting biases. For example, if automated decision making is tasked to score a diverse population pool, this can sometimes magnify existing biases due to a lack of training data from the minority pool (in the U.S. for example, this would comprise mainly Hispanics and African Americans). In such instances, providing appropriate explanations will help improve the accountability, transparency, and interpretability of the automated decision-making systems that will be developed. These explanations may include the rationale for creating the automated decision-making tool, whether the developers December 2022 / STRATEGIC FINANCE / 39

have considered their own unconscious biases, and how stakeholders could be better involved in the algorithmic design and development processes.

Even though transparency and accountability are key defenses when automation-related decisions become challenged in court, many companies developing automated decision-making tools have often resisted calls for greater public transparency, as doing so may inadvertently allow their competitors to steal their technology. As the next recommendation suggests, however, a concerted effort to enact uniform regulations toward public transparency will make for a more level playing field in the long run.

Policies and Regulations

It turns out that the use of automated decision making in setting auto insurance premiums can sometimes result

in lower-risk individuals paying higher premiums. Due to numerous cases of gender discrimination related to AI-based premium setting in the past, U.S. states such as Washington and Oregon have banned the use of credit scores in setting insurance premiums.

This type of dilemma highlights the need for governments to play a critical role in regulating AI-based automated decision making. Data confidentiality and privacy regulations are key elements toward setting the ethical guidelines for AI. For example, in Singapore, the Model Artificial Intelligence Governance Framework provides guidance in the areas of internal governance structures and measures, level of human involvement in AI-based decisions, and operational management, as well as addresses issues concerning stakeholder interactions and communications. Similarly, the European Union (EU) has released several privacy directives, like the General Data Protection Regulation (GDPR) and Ethics Guidelines for Trustworthy AI. According to the EU guidelines, AI should comply with

AI GOVERNANCE AROUND THE WORLD In 2020, the Singapore government released the second edition of its Model Artificial Intelligence Governance Framework, which provides private sector companies with detailed guidance on addressing key ethical and governance issues in deploying AI solutions. By promoting public understanding and trust in the technology, the framework explains how AI systems work, ensures responsible use of data, and creates open and transparent communication. The guiding principles in this framework are that AI systems should put people first, be explainable and understandable, and make fair decisions.

The European Commission published the Ethics Guidelines for Trustworthy AI in April 2019. They state that trustworthy AI must comply with all applicable laws and regulations, be ethical, and be technically and socially robust. The guidelines also set out a number of requirements that AI systems should meet in order to be considered trustworthy. For example, AI should promote fundamental human rights and enable informed decision making. AI systems must not only be resilient and secure, but also require human participation, such as the human-in-the-loop and human-in-command approaches.

They also note that safety, reliability, repeatability, accuracy, and a contingency plan are essential in AI. In this way, unintended damage can also be minimized and prevented. In addition, all data must be of high quality and handled with integrity, lawful access, and privacy.

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Data confidentiality and privacy regulations are key elements toward setting the ethical guidelines for AI.

applicable regulations and laws, be ethically and morally sound, and be technically robust. In addition, automated decision-making tools should be audited regularly to ensure that any biases caused by either the algorithms or the data can be mitigated.

When it comes to data protection, an accountant may act as either a controller or a processor. A controller determines the “purposes and means” of processing personal data. When processing data, accountants can help organizations decide why specific data must or must not be processed, what data types should be included in the analysis, and the duration of data processing and retention. Thus, accountants can assist in ensuring that data is compliant, that data collection and processing are ethical, and that automated decision-making systems ultimately produce more transparent results.

For example, accountants play an essential role in developing information systems such as enterprise resource planning systems in order to help ensure that they fit into their company’s business processes and

generate relevant outputs for decision making. With the advent of AI and data science, this role should be expanded to include algorithmic evaluations. Accountants can also help explain the results of LIME and SHAP more clearly to enable a better understanding of the inner workings of AI tools and to document them for internal and external stakeholders.

Human-Algorithmic Interactions

AI can’t and shouldn’t unilaterally make decisions for humans. With no will and no intention, AI is merely a tool to help generate information. On the other hand, humans make decisions and are responsible for the consequences.

With justification, human decisions can be questioned and rebuked in the name of respecting the rule of law.

Even though AI is capable of being fully automated, human judgment remains critical. Automated decisionmaking tools, for example, can correlate a person’s gender with risk. This, however, shouldn’t be generalized and thus needs to be justified on a case-by-case basis. This is consistent with the AI ethical guidelines in Singapore and the EU. (For more on these guidelines, see “AI Governance around the World.”) Both have emphasized the need for humans to supervise and control AI-based decision making, using a combination of human-in-the-loop and human-incommand approaches.

Simply put, with proper checks and balances, the system put in place as a result of implementing human-algorithmic and data interactions will help mitigate biased and potentially harmful outcomes that can erroneously occur with either full automation or human-only decision making.

Overall, mitigating the potential risks posed by automated decision making remains an ongoing challenge.

Accountants can meet that challenge head on by leveraging their stewardship and value-creation expertise. With their skills in data management, accountants can extend their contribution to minimize risks when using automated decision-making systems to transform data into information, thereby helping to create a more responsible AI environment within their organizations. And, finally, one of the best things an ethical, diligent management accountant can do is raise questions with AI developers regarding sources of potential bias and how to prevent them from ever becoming a problem. SF

Arif Perdana, Ph.D., CA, is an associate professor in the data science cluster at Monash University, Indonesia. Arif can be reached at arif .perdana@monash.edu.

W. Eric Lee, Ph.D., CPA, CITP, CGMA, CFE, is an associate professor of accounting and the accounting alumni faculty fellow at the University of Northern Iowa’s College of Business Administration. He’s a member of IMA’s Waterloo-Cedar Falls Chapter. You can reach him at eric.lee @uni.edu.

December 2022 / STRATEGIC FINANCE / 41

THE VALUE OF CONNECTORS

Voluntary employee turnover is more costly than ever. Connectors in your teams can reduce turnover and lower these costs.

BY ROMANA L. AUTREY, PH.D., CMA, CPA, CFF, CFE; TIM BAUER, PH.D., CPA; KEVIN E. JACKSON, PH.D.; ELENA KLEVSKY, PH.D., CPA; AND MARGARET SHACKELL, PH.D., CMA, CPA December 2022 / STRATEGIC FINANCE / 43

M

alcolm Gladwell’s book, The Tipping Point: How Little Things Can Make a Big Difference, describes the three types of people needed to lead to positive social epidemics: connectors, mavens, and salesmen. According to Gladwell, connectors know lots of people, know diverse people, and get things done. Now academic literature suggests that this connector concept is multifaceted, and one’s predisposition to be a connector can be measured with reasonable accuracy and convenience. As a member of the finance team in your organization, you can leverage this research to help find connectors. The net results could include reduced costs for the organization as well as improved effectiveness of your team.

Through their research, Romana Autrey, Tim Bauer, Kevin Jackson, and Elena Klevsky developed a model for

connectors, including several traits and skills. (See “Deploying ‘connectors’: A control to manage employee turnover intentions?” in the November 2019 issue of Accounting, Organizations and Society for details of their research.) They administered a survey online to 140 students at a large state university. Students who received scores in the top 10% of those respondents were classified as connectors. The other 90% were classified as nonconnectors. They formed groups of three to five students—some that purposefully included one connector and some that purposefully included no connectors—unbeknownst to the students. The students then met with their groups in breakout rooms on campus and completed a task in which they had to work together.

When the task was complete, they individually completed a feedback survey about the group and their connection to it.

Autrey, et al., measured group experience (see Figure 1) and individual turnover intentions.

From this research, they were able to describe three key connector components (see Figure 2). First, being person-

FIGURE 1: GROUP EXPERIENCE FEEDBACK​ Shared Identity Select the pictures below that best describe how your personal attributes, qualities, and values align or overlap with the attributes, qualities, and values of your group. [Scored as 1 = nonoverlapping circles to 7 = almost completely overlapping circles]

Fun How much fun did you have working with your group in completing the assigned tasks?

[Scored as 1 = not at all fun to 11 = very fun]

Function How well did your group perform in completing the assigned tasks?

[Scored as 1 = performed very poorly to 11 = performed very well]

Freedom of Expression How free did you feel to offer your opinions or suggestions when participating in the group discussion?

[Scored as 1 = not at all free to express myself to 11 = very much free to express myself]

Cooperation How well did the group cooperate in completing the assigned tasks?

[Scored as 1 = cooperated very poorly to 11 = cooperated very well]

Participation Rate A = Please indicate the number of group members who helped complete the tasks (including yourself).

B = Please indicate the number of participants in your group (including yourself).

Participation rate = A/B

44 / STRATEGIC FINANCE / December 2022

FIGURE 2: WHO IS A CONNECTOR?

Able to Influence Relationships Type of person: able to influence others, build relationships with and among others, and send clear signals of support to others

Connector Component 3

Political skill

Self-monitoring Connectivity

Connector Component 1

The Connector

Connector Component 2

Agreeable Emotionally stable

Interpersonal orientation

Open to experience

Being Personable Type of person: approachable, has personal appeal, and likely to have more opportunities to build relationships

Extroverted Conscientious

Positive and negative affect

able: agreeableness, openness, and the other characteristics relate to friendliness and/or approachability. People like to talk to personable people. They’re easy to be around and welcoming, and they don’t create conflict or unwanted disruption in group settings. Being personable, however, isn’t enough to connect people. If the potential connector isn’t interested in connecting, then a friendly personality isn’t enough to make it happen.

This is where the second component comes in: desire to relate to others. An interest in connecting is essential to making the bond materialize. Finally, that person also needs to be able to use their skills to influence people around them. Hence, the third component is the ability to influence

Relational identity

Desire to Relate to Others Type of person: intrinsic desire and motivation to build relationships with and among others, and genuinely curious about others

others’ relationships. This reciprocity is necessary. People that the connector reaches out to must want to reach back.

If a group member has these three components, that member will be able to connect people within your organization.

With the twin trends of group work and diversity affecting organizations, these connectors are valuable for their ability to help colleagues have great group experiences and want to stay in the company. Connectors can also help organizations that are looking to enrich their decision making by including diverse voices. Because diversity, equity, and inclusion (DE&I) is an increasing priority for organizations, finding a way to retain diverse talent can help with this priority.

December 2022 / STRATEGIC FINANCE / 45

Connector or No Connector?

Building on prior literature, Autrey, et al., developed a survey based on existing scales and research to measure whether people are connectors or not. The first section of the survey relates to how much the person generally possesses a positive or negative affect; for example, they indicate whether “on average” they feel enthusiastic or scared.

This helps to assess if they look at the world more through a “glass half full” (positive affect) or “glass half empty” (negative affect) lens.

The second section relates to whether the person has an orientation that is more individualistic, relational, or collective. For example, asking questions about self-aspect such as their preferred way to respond to “when faced with an important personal decision,” while providing options such as “ask myself,” “talk with my partner or best friend,” or “talk to my family or relatives,” can measure whether the person is most comfortable on their own, relating to one person, or relating to a group of people, respectively.

Connectors can also help organizations that are looking to enrich their decision making by including diverse voices.

46 / STRATEGIC FINANCE / December 2022

The third section has to do with personable traits, asking whether the person sees themselves as sympathetic, dependable, emotionally stable, etc. The final section relates to “connectivity” and political skill/interest. For example, respondents indicate whether they agree with “I’m often the link between friends in different groups.”

An individual’s collective responses to these questions help determine whether that person makes an effort to connect and be connected. Identifying whether someone is a connector then involves weighting each response using predetermined multipliers to come up with a combined score across all questions.

So how do you know if you’re a connector or have connectors working for you? You or your employees can take the survey at bit.ly/3zk2fG0. It reports a connector score and offers an assessment on the likelihood that you’re a connector. A higher score means that employees will be more likely to be able to facilitate inclusion of group members. Specifically, based on the research, scores greater than 80.5 represent a connector with a probability greater than 90%. Individuals with scores lower than 80.5 might still be connectors, but that probability is considerably lower.

(Readers are also encouraged to contact Autrey, et al., for help developing a more sophisticated score that identifies connectors relative to organizational peers. They also developed a simplified scoring method to help managers quickly and easily identify connectors.)

In their study, Autrey, et al., found that turnover intentions could be reduced, especially in diverse team members, by inserting connectors into the team. To explore this further requires a look at the prevalence of group work in accounting and finance, the connector survey used to identify connectors, the concept of group work attachment, and how you might apply the research findings to create a positive impact for your organization. Let’s begin with a look at what the role demands of management accountants.

Do Accountants Do Teamwork?

One stereotypical image of the accountant is the solo finance professional with the green eye shade. This individual works alone, toils for long hours, and doesn’t consult with colleagues. We all know that stereotype is false. The trend in both private and public accounting is an emphasis on communication skills and collaboration. See “The Importance of Group Work in Management Accounting” for more detail.

A review of some of the main roles in accounting and finance illustrates just how much group work is prevalent in the finance function these days. To begin, those serving on an organization’s board of directors need to collaborate with other directors to select the top management team and hold them accountable for acting in the best interests of the shareholders. Because directors may hold diverse viewpoints, they need to reach a consensus on what exactly is in the best interests of the shareholders. This requires collaboration.

The trend in accounting is an emphasis on communication and collaboration.

Secondly, CFOs are members of the top management team, so they need to work together with the heads of the other functional areas to set the company on the path to fulfilling its mission and vision. They also lead their department (i.e., a team specializing in the accounting and finance function).

Third, controllers may serve as members of crossfunctional teams created to solve organizational problems.

In this role, collaborating with representatives of the other functional areas will be important for obtaining information, evaluating problems, cocreating feasible solutions, and implementing those solutions. They also lead a team of accountants who report directly to them.

Fourth, internal auditors, who report directly to the board of directors, are responsible for evaluating their organization’s internal controls and suggesting improvements, which is typically too complex a task for one person to do alone, so they need to collaborate with other

THE IMPORTANCE OF GROUP WORK IN MANAGEMENT ACCOUNTING Directors serving on an organization’s board of directors need to collaborate with other directors to select the top management team and hold them accountable for acting in the best interests of the shareholders.

CFOs need to collaborate with the heads of the other functional areas to set the company on the path to fulfilling its mission and vision. They also lead their department/team.

Controllers may serve as members of cross-functional teams created to solve organizational problems. They also lead a team of management accountants who report directly to them.

Internal auditors are responsible for evaluating the organization’s internal controls and suggesting improvements in collaboration with other internal auditors to ensure correct and timely results.

External auditors obtain evidence so that their audit firm can opine on the reasonableness of a client’s financial statements and the effectiveness of a client’s internal controls over financial reporting.

December 2022 / STRATEGIC FINANCE / 47

FIGURE 3: DIVERSITY AND THE GREAT RESIGNATION BY THE NUMBERS

40%

Colleagues and culture are a top priority when picking a new job. (Source: LinkedIn, 2022 Global Talent Trends: The Reinvention of Company Culture, bit.ly/3sV7Hvf)

44%

Candidates turned down an interview or job offer due to organization’s lack of diversity, according to recruiters. (Source: Zogby Analytics, 2021 Recruiter Nation Report, bit.ly/3h9MVoY)

48%

Talent acquisition and retention challenges present the biggest risk to achieving growth goals.

(Source: PwC Pulse Survey, January 2022, bit.ly/3Nz1dvz)

50%

Respondents have left or wanted to leave a tech job because company culture made them uncomfortable. (Source: mthree/Wiley, Diversity in Tech: 2021 US Report, bit.ly/3FHYpdJ)​

51%

Respondents quit their jobs because they didn’t feel a sense of belonging at work. (Source: survey of 5,774 employees in five countries, “‘Great Attrition’ or ‘Great Attraction’? The choice is yours,” McKinsey Quarterly, September 2021, bit.ly/3FHI2Py)

68%

Respondents felt uncomfortable in a tech/IT role because of their gender, ethnicity, socioeconomic background, or neurodevelopmental condition. That included:

69%

of Hispanic and Latino respondents​

75%

of female respondents (77% for women of color)​

81%

of Black and African American respondents

(Source: mthree/Wiley, Diversity in Tech: 2021 US Report, bit.ly/3FHYpdJ)​

internal auditors to get it done correctly and on a timely basis.

Fifth, external auditors perform audits as members of an audit team. They’re responsible for obtaining evidence that lets their audit firm opine on the fairness of their client’s financial statements and the effectiveness of their client’s 48 / STRATEGIC FINANCE / December 2022

internal controls over financial reporting. This is also too complex a task for one person to do alone, so they need to collaborate with their audit team members to perform each audit. This scratches the surface of just how much teamwork happens in accounting and finance, and how vital connectors in teams might be to your organization.

Group Work Attachment

These days, after a prolonged period of a tight labor market and on the heels of the Great Resignation, organizations need to do everything possible to reduce voluntary turnover (see Figure 3). And research has found that employees who are more connected to their work groups are less likely to leave (see Susan E. Jackson, Joan F. Brett, Valerie I. Sessa, Dawn M. Cooper, Johan A. Julin, and Karl Peyronnin, “Some differences make a difference,” Journal of Applied Psychology, October 1991; and G. G. Dess and J. D. Shaw, “Voluntary turnover, social capital, and organizational performance,” Academy of Management Review, July 2001).

It’s difficult to find new employees. And when you factor in the cost of hiring and training new employees, the reduced or lost productivity while a position is unfilled or until recent hires get acclimated, the increased workload for remaining employees who take on the former employees’ responsibilities, and the risk of voluntary turnover becoming contagious as cherished employees leave, it truly is in the company’s best interest to keep the good employees that they have (see Matthew O’Connell and Mei-Chuan Kung, “The cost of employee turnover,” Industrial Management, January 2007). Therefore, employees need to feel connected to the groups that they’re working in. For some employees, especially those who feel that they have lots in common with their fellow workers, it’s fairly easy to feel connected.

But think about situations that you may have been in that you didn’t feel connected. What was it about those situations that drove that feeling? Was it that you were dissimilar to the rest of the group? Have you ever been the only woman in a group? The only person of color? The only person born abroad?

There could be a variety of attributes, some less obvious (e.g., age, religious identity, political affiliation, and marital status), that make employees and group members feel like outsiders. Employees who feel like outsiders don’t share their authentic selves and generally don’t want to remain in the groups. This leads them to look for other jobs and then leave the company. What can your company do to help employees feel like they belong?

Results and Implications for Practice

The research by Autrey, et al., found that connectors influence group experiences. There are three key findings. First, the groups with a connector reported lower turnover intentions and a better experience. Second, the individuals reporting better group experiences also had lower turnover intentions, and it was the better group experiences of groups with connectors that lowered turnover intentions. Finally, these results were strongest

for people who were minorities on their particular team, e.g., the only woman in a team of men or the only U.S. native in a team of non-U.S. natives, etc.

Keeping a record of employees who are high on the connector scale can be very useful for multiple reasons. The ability to recognize connectors and their impact on employee group work can help managers understand how to retain workers. With organizations stressed and finding it difficult to retain employees, taking advantage of the research findings is even more critical.

The connector survey can also help you identify those people currently in your organization who can help others feel connected and reduce employees’ desire to find another job. Connectors can help your employees develop relationships that allow groups to have better experiences and, through those better experiences, also reduce employees’ desire to leave.

What’s also important about this research is the impact on DE&I. Organizations are enriched when all voices are heard and when employees can bring their authentic selves to work. It isn’t easy for this to happen when members of underrepresented groups feel like they aren’t part of the organization. Connectors can help foster a sense of belonging, even more so for these diverse employees. So retaining employees who can make a bigger impact is even more crucial. Get started today. Have your employees take the survey—take it yourself—and find out who among you is a connector, and then work with that person to help foster a sense of belonging. SF

Romana L. Autrey, Ph.D., CMA, CPA, CFF, CFE, is the associate dean of academic affairs and an associate professor of accounting at Willamette University’s Atkinson Graduate School of Management.

She can be reached at rautrey@willamette.edu.

Tim Bauer, Ph.D., CPA, is the associate director of assurance at the University of Waterloo Centre for Information Integrity and Information Systems Assurance. He is also an associate professor of accounting and a research fellow in the UW School of Accounting and Finance. He can be reached at tdbauer@uwaterloo.ca.

Kevin E. Jackson, Ph.D., is the vice provost for undergraduate education at the University of Illinois. He is also a professor of accountancy.

He can be reached at kjack@illinois.edu.

Elena Klevsky, Ph.D., CPA, is an assistant professor of accounting at the University of Tampa’s Sykes College of Business and a member of IMA’s Tampa Bay Chapter. She can be reached at eklevsky@ut.edu.

Margaret Shackell, Ph.D., CMA, CPA, is an associate professor of accounting and director of the MS in accountancy program at Ithaca College. She’s a member of IMA’s Finger Lakes Chapter. Contact Margaret at (607) 229-2530 or shackell@ithaca.edu.

December 2022 / STRATEGIC FINANCE / 49

WILL YOU BE

SEC COMES

50 / STRATEGIC FINANCE / December 2022

READY IF THE

S KNOCKING?

If a company and its chief officers respond proactively to instances of misconduct, the SEC may reduce or even eliminate its corrective actions and penalties.

BY SAMANTHA FALGOUT, CPA; JESSICA L. EVANKO, DBA, CPA; AND DOUGLAS M. BOYLE, DBA, CMA, CPA

T

he U.S. Securities & Exchange Commission (SEC) Division of Enforcement is, as its name implies, a division solely dedicated to the Commission’s enforcement responsibilities. SEC Chair Gary Gensler emphasized the importance of enforcement at the 2021 Securities Enforcement Forum by stating that it is “one of the fundamental pillars in achieving the SEC’s mission.”

The Division of Enforcement’s results for fiscal year 2021 reflect and support that mission. A total of 697 enforcement actions were filed, including 434 new actions, which represents a 7% increase from the prior year. While 2022 statistics aren’t yet published, the SEC recently investigated and charged 16 Wall Street firms (including Goldman Sachs, Morgan Stanley, and Credit Suisse Securities) with violations, which resulted in combined penalties of more than $1.1 billion. This demonstrates the SEC’s continued commitment to its enforcement responsibilities.

What does the SEC’s zeal for oversight mean to you, a practicing accounting or finance professional, and to your organization? Simply put, it’s important for anyone serving in corporate governance roles at U.S. public companies to understand the scope of the various SEC enforcement programs and the remediation opportunities that are available to reduce potential exposure to the company and those involved in SEC investigations.

Initiative (see Figure 1). In 2009, the SEC initiated a program phasing in the mandatory use of XBRL to enhance access to and analysis of financial data by SEC staff and third parties, including investors, analysts, and journalists. The following year, in 2010, the SEC’s whistleblower program was created through the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The purpose of the program was to incentivize individuals to report federal security law violations through monetary rewards; Dodd-Frank was expanded in 2014 to include anti-retaliation protection. This enforcement effort has successfully continued through fiscal year 2021, with the distribution of the highest awards in the program’s history (a total of $564 million to 108 whistleblowers), pushing the total payouts over the life of the program to more than $1 billion.

The next SEC initiative, called Operation Broken Gate, began in 2013. It was designed to “provide tighter oversight of individuals [the SEC] considers to be the ‘gatekeepers’ for protecting investors by helping ensure fair financial presentation and disclosure by public companies” (“Operation Broken Gate,” Strategic Finance, January 2015, bit.ly/3SWeteW).

Operation Broken Gate was followed by the SEC initiative known as the Accounting Quality Model (AQM). The AQM takes public company financial reports filed with the SEC and measures how the organization’s discretionary (abnormal) accruals vary from a peer benchmark. The model then identifies potential accounting irregularities in an attempt to understand and investigate the risk factors of aggressive earnings management practices. The AQM project was feasible because the SEC was able to access the XBRL database of public company financial filings that it had established years earlier.

In 2018, the SEC revealed the Share Class Selection Disclosure Initiative in response to the numerous actions filed by the SEC in which, in the words of the Commission, “an invest-

A Brief History of Enforcement Programs

The SEC’s history of enforcement is demonstrated by initiatives such as eXtensible Business Reporting Language (XBRL) data tagging, the whistleblower program, Operation Broken Gate, Accounting Quality Model, Share Class Selection Disclosure Initiative, and the EPS (earnings per share)

FIGURE 1: TIMELINE OF SEC ENFORCEMENT INITIATIVES Operation Broken Gate

XBRL data tagging

2009

2010

Whistleblower program 52 / STRATEGIC FINANCE / December 2022

Share Class Selection Disclosure Initiative

2013

Accounting Quality Model

2018

2020

EPS Initiative

FIGURE 2: THE SEC’S FOUR COOPERATION MEASURES Self-Policing Establishing effective compliance procedures and an appropriate tone at the top Self-Reporting Conducting a thorough review of the nature, extent, origins, and consequences of the misconduct Promptly, completely, and effectively disclosing the misconduct to the public, to regulatory agencies, and to self-regulatory organizations Remediation Dismissing or appropriately disciplining wrongdoers Modifying and improving internal controls and procedures to prevent recurrence of the misconduct Appropriately compensating those adversely affected Cooperation Working with law enforcement Providing the SEC with all information relevant to the underlying violations and the company's remedial efforts Source: SEC, Division of Enforcement, Office of Chief Counsel, Enforcement Manual, November 28, 2017, bit.ly/3Upj9v4.

ment adviser failed to make required disclosures relating to its selection of mutual fund share classes that paid the adviser (as a dually registered broker-dealer) or its related entities or individuals a fee pursuant to Rule 12b-1 of the Investment Company Act of 1940 (“12b-1” fee) when a lower-cost share class for the same fund was available to clients.”

Most recently, in 2020, the SEC announced its EPS Initiative. The specific details of this initiative haven’t been shared publicly, but the purpose of the program is to expand the SEC’s scope in ensuring proper financial reporting and pursuing violators. (For more, see Laura Bea Lamb, Jessie Kinsley Wright, Stasia H. Morlino, and Douglas M. Boyle, “The SEC’s EPS Initiative,” Strategic Finance, May 2022, bit.ly/3zzViRe.)

Cooperation and Remediation

The SEC encourages companies to cooperate in its investigations, noting the benefits of cooperation “can range from reduced charges and sanctions in enforcement actions to taking no enforcement action at all.” (For more details, including the types of agreements the Commission may enter into with companies or individuals, go to bit.ly/3DXk2FA.)

The SEC has four measures of cooperation: self-policing, self-reporting, remediation, and cooperation (see Figure 2). By following these four measures, a company has the potential to lessen, or potentially eliminate, its sanctions in enforcement investigations.

The timing of these four steps, which the SEC evaluates during its investigation, is of critical importance. Self-policing occurs prior to the discovery of the misconduct, as the Commission assumes that the company should have effective oversight and controls in place to prevent and detect misconduct from happening in the first place. Remediation and cooperation efforts take place when the misconduct is discovered and self-reported and continues for months—or potentially years— until the misconduct is completely resolved. Remediation is a pivotal step in the cooperation process, as these actions are taken to ensure that the misconduct never happens again.

You may be wondering what exactly “remediation” means in the eyes of the feds. The SEC’s Division of Enforcement defines remediation as “dismissing or appropriately disciplining wrongdoers, modifying and improving internal controls and procedures to prevent recurrence of the misconduct, and appropriately compensating those adversely affected.” The SEC doesn’t, however, specify what constitutes December 2022 / STRATEGIC FINANCE / 53

remediation nor the cases where remediation is applicable.

Rather, it appears to apply remedial measures on a case-bycase basis. Occasionally, the proposed remediation comes directly from the person or company accused of malfeasance via a good faith proposal to correct the wrongdoing. In these situations, it’s up to the organization to begin remedial efforts to either reduce or eliminate additional penalties.

A review of recent cases involving remediation actions identified patterns helping to define remediation. These actions to resolve the misconduct include bringing the wrongdoing to the attention of the audit committee or those in charge of governance, termination, and legal action against those individuals both responsible for, and who failed to prevent, the wrongdoing. Those organizations or persons who are accused must show that they’re adjusting their internal controls to mitigate the specific risks cited, including the possibility of replacing or adding employees with expertise in the areas related to the wrongdoing. (For more on this topic, see Landon W. Mignardi, Scott Masci-

anica, and Jessica B. Magee, “Remediation: The SEC Smiles on Proactivity,” January 31, 2022, bit.ly/3T1qKPf.) As you can see in Table 1, the most recent case involving remediation efforts is SEC v. HeadSpin, Inc. Headspin’s then-CEO, Manish Lachwani, was found to be fraudulently reporting the company’s annual recurring revenues (ARR) beginning in 2018 through 2020. (HeadSpin sells hardware and software to test applications; its ARR is generated through subscriptions to these services.) Additionally, the case notes that Lachwani also inflated revenues by recording customers’ pending commitments and held control of financial information against the request of the board by refusing to hire a CFO. Based on these maneuvers, which inflated the value of HeadSpin by $5.1 million in one year, investors sank millions of dollars into the company.

HeadSpin identified the wrongdoing internally and then fired Lachwani. Following these actions, the board returned investors’ money to them and lowered the company’s valuation, with balances being paid in a loan with 1% interest.

TABLE 1: RECENT REMEDIATION ACTIONS Year

Company

SEC Charges/Violations

2017

YourPeople, Inc. (dba Zenefits FTW Insurance Services)

Misrepresented or did not disclose material information to investors

Cease-and-desist order and a civil penalty of $450,000

2017

Provectus Biopharmaceuticals, Inc.

Distributed improper and unauthorized payments to its former CEO and CFO due to insufficient internal accounting controls

Cease-and-desist order

2018

LendingClub Asset Management, LLC

Improperly used money from private funds to benefit the company

Charges weren’t recommended against the company

2018

Alliance One International, Inc.

Improperly recorded inventory, cost of sales, and revenue

Cease-and-desist order

2021

GWFS Equities, Inc.

Failed to file certain suspicious activity reports with the U.S. Treasury Department’s Financial Crimes Enforcement Network

Cease-and-desist order, censure, and a civil penalty of $1.5 million

2021

Tandy Leather Factory, Inc.

Inventory tracking system issues Cease-and-desist order and a civil and control failures and deficiencies penalty of $200,000

2021

ProPetro Holding Corp.

Failed to disclose certain perquisites and stock pledges concerning its cofounder and former CEO in its definitive proxy statements and annual reports

Cease-and-desist order

2022

HeadSpin, Inc.

Falsely inflated its key financial metrics and doctored internal sales records

Settled fraud charges without a penalty

54 / STRATEGIC FINANCE / December 2022

Outcome

ENFORCEMENT AROUND THE WORLD

The SEC is far from the only regulatory body with enforcement responsibilities. Here’s a quick look at what governing bodies in other countries are doing, including remediation opportunities.

Country

Governing Body

Enforcement Efforts

Remediation Opportunities

Notes

Australia

Australian Securities and Investments Commission (ASIC)

Emphasis on system and process failures causing financial harm to customers

ASIC doesn’t specifically call for remedial or cooperative efforts in the same way the SEC does.

ASIC balances “statutory objectives aimed at facilitating markets and promoting trust and confidence in the financial system.”

China

China Securities Regulatory Commission (CSRC)

An upward trend on enforcement for insider trading has been observed.

N.A.

The CSRC is encouraging greater use of “debarring” to prevent insiders from further participating in the market.

France

Authorité des marchés financiers

Insider dealing

Mitigation efforts are considered.

While the European Securities and Markets Authority is the technical authority for European Union members, including France, enforcement efforts are dependent on the member nations’ participation. Member nations oversee enforcement; therefore, consistency could be an issue.

Germany

Federal Financial Supervisory Authority (BaFin)

BaFin supervision and task force (includes entering and inspection and search and seizure)

BaFin will agree to mitigation in certain circumstances.

BaFin recently implemented an interdisciplinary task force that can take swift action to respond to allegations.

Japan

Financial Services Agency (FSA)

Money laundering

Mitigation efforts are considered when determining administrative sanctions.

Hamada & Matsumoto, a legal firm, provides details about mitigation and cooperation efforts by the FSA and the Japan Fair Trade Commission, which can issue surcharges or penalties due to cartels and bid-rigging.

United Kingdom

Financial Conduct Authority

Money laundering controls

Remedial actions can include up to a 30% reduction in penalties if resolved quickly.

Efforts against failed money laundering controls have been ongoing since 2018 and have netted £665 million.

HeadSpin’s board of directors hired a new executive team, including a controller, and adjusted its internal control systems appropriately.

When Is Remediation Necessary?

In cases that involve remediation, the SEC considers several factors when determining whether to lessen a com-

pany’s sanctions based on the management team’s own remedial actions. A main consideration is whether the misconduct was malicious or unintentional, along with the nature of the act(s). In the case of GWFS Equities, Inc., the company was accused of willfully neglecting to file accurate suspicious activity reports in compliance with the Bank Secrecy Act. Remediation was part of the corrective action in this case, and the company was also fined $1.5 million, which could be related to the intentional December 2022 / STRATEGIC FINANCE / 55

misconduct as well as the risk it posed to clients. In comparison, HeadSpin was proactive once misconduct was detected and wasn’t assessed a penalty.

A second significant consideration is the overall response to the misconduct. Specifically, how quick was the response, and how transparent was the company regarding the misconduct? Did the organization conduct its own thorough and objective investigation? For example, the SEC’s Division of Enforcement decided not to recommend charges against LendingClub Asset Management, LLC, as a result of the company self-reporting its misconduct following a review initiated by its board of directors and reimbursing approximately $1 million to investors who were adversely impacted. In a case involving Tandy Leather Factory, Inc., information regarding the misconduct was brought to the audit committee, which conducted an internal investigation. This inquiry led to a new accounting system to accurately value the company’s inventory, as well as the hiring of additional accounting personnel and adjustments to its control system.

In a case from 2018, a subsidiary of Alliance One International, Alliance One Tobacco (Kenya), was found to have violated several SEC regulations, including premature recording of revenue and inventory, improper internal controls, and failure to file reports. Yet due to the remedial efforts by the parent organization after identifying the misconduct, the SEC accepted its offer and issued a ceaseand-desist order only. The company’s efforts included close communication with the SEC, hiring of counsel and forensic accounting firms by the board of directors, restatements of financial statements, accounting hires in its African region, and implementation of new internal controls.

A third consideration relates to where in the organization the misconduct occurs. In deciding the weight of penalties or the extent of remediation, the SEC considers how high up in the chain of command knowledge and participation in the misconduct occurred. In the case of Zenefits, a private software company based in San Francisco, Calif., its founder and former CEO, Parker Conrad, was named as a respondent in the case in addition to the company. While CEO, Conrad was aware that unlicensed Zenefits employees were selling insurance, and he allowed the practice to continue. Feeling the heat from state insurance regulators, Conrad later resigned from the company. As part of the remedial efforts, Zenefits replaced its top leadership, including the head of sales, created the position of chief compliance officer, and established a compliance team.

A fourth consideration involves assurances that the misconduct is unlikely to recur. For example, will internal controls be implemented to prevent and detect future misconduct? Insufficient internal controls that failed to catch millions of dollars in bogus cash advances and expense reports was the motivation in the case against Provectus Biopharmaceuticals, Inc., which resulted in remediation efforts and a cease-and-desist action. In addition to what happened in this case, other factors the SEC may consider are the timing of the misconduct in relation to a company’s initial public offering, the timing of reorganizations or acquisitions, and the harm the misconduct caused to stakeholders.

56 / STRATEGIC FINANCE / December 2022

Only One Part of the Framework

Remediation is just one of the four measures the SEC uses to evaluate a company’s cooperation during an enforcement investigation. As important as the remedial actions are to ensure the misconduct doesn’t happen again in the future, the other three factors—self-policing, self-reporting, and cooperation—are also considered in each case.

The SEC provides guidance on factors it considers when determining whether or not to grant leniency to companies in enforcement investigations. Although there’s a framework, there’s a lot of human discretion involved in examining the facts of each particular case, such as the nature of the misconduct, the company’s overall response, where in the organization the misconduct occurred, and what measures have been implemented to prevent it from reoccurring. The framework doesn’t address the level of cooperation required to reduce sanctions and penalties during an investigation, only the factors taken into consideration when making the determination. The outcomes can be different for companies with a similar set of facts based on varying degrees of misconduct. Therefore, it can’t be assumed that the SEC’s degree of leniency in an investigation is based merely on other cases and decisions.

Opportunities to avoid or mitigate penalties require attention to the first three measures of the SEC’s framework. Organizations need to ensure they have the proper tone at the top and that employees charged with governance value compliance and the need for proper procedures. Admitting fault isn’t easy for anyone, much less an organization in which the public is invested. But accepting responsibility is the beginning of the remediation process, to be followed by swift and appropriate action.

Although accounting and finance professionals hope they never find themselves involved in an SEC enforcement investigation, it’s important that they be aware of the remediation opportunities granted to companies that cooperate. SF

Samantha Falgout, CPA, is an instructor of accounting in the Department of Accounting and Finance at Nicholls State University. She can be reached at (985) 448-4193 or samantha.falgout@nicholls.edu.

Jessica L. Evanko, DBA, CPA, is an assistant professor of accounting in the William G. McGowan School of Business at King’s College. She’s a member of IMA’s Northeast Pennsylvania Chapter.

You can contact Jessica at (570) 208-5780 or jessica.hildebrand @kings.edu.

Douglas M. Boyle, DBA, CMA, CPA, is an associate professor and department chair in accounting in the Kania School of Management at the University of Scranton. Doug also serves as director of the Ph.D. in accounting program. He’s a member of IMA’s Northeast Pennsylvania Chapter. You can contact Doug at (570) 941-5436 or douglas.boyle @scranton.edu.

TECH FORUM | 57

TOOLS OF THE TRADE | 59

EXCEL | 60

TECH PRACTICES | 62

TECH FORUM

THE READERS WE HAVE BEEN

BY MICHAEL CASTELLUCCIO

There are risks that accompany the benefits of the internet and the crowd of computerized devices in our homes. One of the more subtle and profound of these problems has emerged as we continue to move away from a literacy- and word-based culture into a faster-paced digital and screen-based one. The way we read is changing.

C

ognitive neuroscientist Maryanne Wolfe begins her book Reader, Come Home with an examination of the evolution of the reading brain. There are three essential facts, she explains, “Let’s begin with a deceptively simple fact…: human beings were never born to read. The acquisition of literacy is one of the most important epigenetic achievements of Homo Sapiens.”

(Epigenetics studies how behaviors and environment can cause changes that affect the way our genes work.)

The invention is only 6,000 years old, and when considered alongside other evolutionary changes, our ability to read developed in an incredibly short time. That’s due to the neuroplasticity of the brain and its ability to rewire circuits and reassign purpose to neurons that weren’t specifically designed for roles like reading. That short gestation period for reading circuits also includes the caution that epigenetic changes are reversible. Wolfe reminds us that the basic rule for neurons

is use them or lose them, and that includes those neurons and circuits assigned to reading.

In their book, Evolving Ourselves, futurists Juan Enriquez and Steve Gullans point out, “We are in a different phase of evolution; the future of life is now in our hands. It is no longer just natural evolution, but human-driven evolution.” And what we create in tech can recreate us.

Finally, a third fact is that our reading circuits are now dividing into two types: one for the established print-reading circuits and another for new digital circuits. This is creating a new, biliterate brain.

Until recently, according to Wolfe, little attention was paid to what happened “in the brains of children (or adults) as they learned to read while immersed in a digitally dominated medium six to seven hours a day.”

Neuroscientists and educators are now closely examining the effects of reading in digital formats and the daily immersion in a variety of digital December 2022 / STRATEGIC FINANCE / 57

TECH FORUM

experiences—from social media to virtual games. In the atmosphere of perpetual distraction online, research is piling up that describes shallow reading that produces information but decreases comprehension and offers few or none of the benefits of the slower cognitive processes such as critical thinking, personal reflection, imagination, and empathy that are all part of deep reading, for which the original print-reading circuits were developed.

A CIRCUIT SOLEIL Instead of chapters, Wolfe’s book is divided into nine letters addressed to the reader. The first is an overview of the problem of losing the deep-reading circuit. The last two address possible solutions (“Building a Biliterate Brain” and “Reader, Come Home”).

Early in the book, Wolfe uses a circus metaphor to describe the structure of the reading brain. When we read, it isn’t a small part of the brain that does the work, rather something like a five-ring circus (vision, language, cognition, motor, and affect) that includes, under the same tent, thousands upon thousands of neuronal working groups lighting up whenever you read a single word. The reading circuit incorporates input from two hemispheres, four lobes—frontal, temporal, parietal, and 58 / STRATEGIC FINANCE / December 2022

occipital—and all five layers of the brain from the uppermost telencephalon to the lower levels of the metencephalon and myelencephalon. In fact, all of that was firing and connecting as you read through these lines.

The overriding concern in the book centers around the deep-reading brain and the question, “Will the quality of our attention change as we read on media that advantage immediacy, dart-quick task switching, and continuous monitoring of distraction, as opposed to the more deliberate focusing of our attention?” If our digital reading brain circuit continues to demand most of our reading time, Wolfe asks, “Will the quality of attention in reading—the basis of the quality of our thought—change inexorably as our culture transitions away from a print-based culture toward a digital one?” It seems we’re all aware that this is happening, but do we know where it’s leading? Wolfe reminds us, “The long developmental process of learning to read deeply and well changed the very structure of that circuit’s connections, which rewired the brain, which transformed the nature of human thought.” The most advantageous path that we should take now, she advises, is to teach a new biliteracy to prepare our children and to “preserve [deep reading] in the present reading brain lest we lose something irreplaceable.” SF

“We stand at the threshold of galactic changes over the next few generations.”

—Maryanne Wolfe, UCLA professor-inresidence of education

SF PICK

TOOLS OF THE TRADE

1

MICROSOFT SURFACE PRO 9

1

Despite only minor changes in its latest release, the Surface Pro 9 is still one of the best 2-in-1 laptops available. The headphone jack is gone, but you now have a selection of four colors including platinum, sapphire, graphite, and forest on the Intel models with platinum only for the SQ3 and base model Intel version. Both models are under 2 lbs. and less than a half-inch thick. The Type Cover keyboard is an option that will add to the base prices of $999 for the Intel model and $1,300 for the Microsoft SQ3 processor. Both support Bluetooth 5.1 and Wi-Fi 6E, but the SQ3 also offers 5G connectivity. The Intel processor is either Core i5 or i7, and both models offer 8GB or 16GB of RAM. Internal SSD storage is available in 128GB, 256GB, or 512GB, and the Intel models top out at 1TB. The 3:2, 13" touch display has 2,880 ✕ 1,920 (267ppi) and a refresh rate up to 120Hz. The front-facing Windows Hello camera provides 1,080p FHD video with AI features, and the 10MP rear-facing camera has autofocus, 1,080p HD and 4k video. A Voice Focus feature can filter out background noise for audio and video apps. www.microsoft.com

2

APPLE IPAD, 10TH GENERATION

The newest entry-level iPad 10th generation has a bigger 10.9" screen and faster A14 Bionic processor,

but the headphone jack has been removed.

On the other hand, the long-awaited USB-C charging port is a welcome change offering access to many accessories, including USB-C hubs. The design has been modernized, now with smaller bezels and no home button. You use touch gestures to navigate, and there’s a fingerprint reader for Touch ID in the power button. The front-facing camera has been relocated to the long side of the bezel to accommodate a horizontal position when used for Zoom or other video calls.

One other unexpected change is that you can only use the first-generation pencil, and you’ll need an adapter to plug your pencil into the USB-C port. www.apple.com

3

GOOGLE PIXEL 7

Google’s new Pixel 7 smartphone still maintains its price advantage over the competing flagships from Apple (iPhone 14) and Samsung (Galaxy S22), and Google now offers its

2

newly designed Tensor G2 processor, which has machine learning and AI to improve functions like the new photo-editing tool called Photo Unblur and to improve battery life. The $599 starting price becomes even more of a draw when you take a closer look at the Pixel cameras. The rear cameras include a main 50MP (f/1.85) and 12MP (f/2.2) ultrawide, and the front camera has a 10.8MP (f/2.2) lens. The rear lenses are set in a bar that runs across the entire back of the phone. The 6.3" OLED

4

buds, and a tilting, adjustable surface for attaching your phone in a vertical or horizontal alignment. Made for MagSafe, the Cube is compatible with iPhone 12/13/14 series and Apple Watch and AirPods. LED lights indicate charging. www.apple.com SF

3

screen (2,400 ✕ 1,080) has an adaptive 90Hz refresh rate for smooth scrolling. store.google.com

4

ANKER 3-IN-1 CUBE WITH MAGSAFE

If you’re a fan of minimalist design and prefer the positive connection with MagSafe for your Apple phone, Watch, and AirPods, the Anker 3-in-1 Cube with MagSafe will accommodate all three and provide up to 15W of fast, wireless recharging.

Folded, it’s a palm-sized cube that measures about 3.5" on each side, and when opened it has a side shelf for your watch, the top surface for your ear-

Keep up with the ­latest tools and trends in ­technology with SF TECHNOTES, now a semimonthly blog at SFmagazine .com.

December 2022 / STRATEGIC FINANCE / 59

EXCEL

CHOOSE A RANDOM WORKDAY Excel offers three functions for generating random numbers.

But what if you want to generate a random workday from the year—specifically, a date that occurs on a Monday through Friday excluding company holidays? If your typical workweek is Monday through Friday, then the WORKDAY function gets the job done. If you have a different work schedule—such as Monday, Wednesday, Friday—then use WORKDAY.INTL.

BY BILL JELEN

See more figures in the website version at:

SFmagazine.com

60 / STRATEGIC FINANCE / December 2022

The WORKDAY function takes a starting date and then a number of workdays into the future. It optionally accepts a range of holiday dates to exclude. In Figure 1, the company holidays are listed in C2:C14. A single formula in A2 generates a list of 247 workdays in 2023: =WORKDAY(C2, SEQUENCE(247),C2:C14).

Monday, January 2, 2023, is used in this formula as the starting date by reusing the first holiday of the year from C2. In other cases, you could store the day before the first workday in another cell or use DATE(2023,1,2) or even “01/02/2023” as the first argument. The second argument that contains the sequence of numbers from 1 to 247 represents the range of workdays in the year. The third argument points to a range of company holidays to skip.

In Figure 1, the first four workdays of the year are Tuesday, January 3, through Friday, January 6. The WORKDAY function automatically skips Saturday and Sunday, so the fifth workday, shown

in A6, is Monday, January 9. The list skips Monday, January 16, 2023, jumping from Friday, January 13, 2023, to Tuesday, January 17, 2023.

Say that you need to randomly schedule 10 surprise audits throughout the year. A single formula in E2 generates the 10 random workdays: =SORT(WORKDAY(C2,RAND ARRAY(10,1,1,247,TRUE),C2:C14)).

Let’s work from the inside of this formula to the outside. The RANDARRAY formula is generating 10 rows by 1 column of numbers between 1 and 247. The final TRUE argument limits the results to integers, so you don’t get any fractional days. This formula might generate a set of numbers such as 36, 50, 158, 129, 183, 33, 57, 60, 98, 45.

The WORKDAY function is similar to the function shown in cell A2. But instead of all 247 workdays, you’re asking for 10 random workdays using the results of RANDARRAY. They’ll be in a random order, so wrapping the whole function within SORT makes sure they’re in order from earliest to latest.

PREVENTING REPEAT DATES None of the dates were repeated in the example. But as you increase the number of selected dates, there’s a greater chance that the same date will be selected twice. An alternate formula approach can prevent repeats.

Figure 2 shows a formula that randomly selects 20 workdays without any repeats. Cell E2 contains the formula =SORT(INDEX(SORTBY(A2#, RANDARRAY(247)),SEQUENCE(20))).

It starts with the 247 workdays that are generated by the formula in A2.

The SORTBY function combined with a RANDARRAY of 247 random numbers puts the 247 dates into a random sequence. Then the INDEX function with SEQUENCE(20) asks for the first 20 dates from the random sequence.

Finally, those 20 dates are sorted.

USING ALTERNATE WORKWEEKS The WORKDAY function assumes that the workweek is always Monday through Friday. The newer WORK-

DAY.INTL function adds a “Weekend” argument so you can specify which days should be excluded from the workweek. When you’re entering the formula, the tooltip will show 14 builtin choices, such as 1 for a weekend of Saturday and Sunday, 7 for Friday and Saturday, and 11 for Sunday only.

But the most flexible way to specify the weekend is with a seven-digit binary number. The first digit represents Monday, and the last digit represents Sunday. Use a 1 to specify that the company is closed this day and a 0 to indicate that the company is open.

For example, 0000111 would specify the workweek for a company that’s open Monday through Thursday and closed on Friday through Sunday. For a company open Monday, Wednesday, and Friday, the weekend is essentially Tuesday, Thursday, Saturday, and Sunday: 0101011.

To generate all possible workdays that fall on a Monday, Wednesday, or Friday, use this formula in A2: =WORKDAY.INTL(C2, SEQUENCE(146),"0101011",C2:C14).

Then to randomly select 12 days with no repeated dates, use this formula: =SORT(INDEX(SORTBY(A2#, RANDARRAY(146)),SEQUENCE(12))).

FORMAT RESULTS AS DATES For many date functions, Excel will automatically format your results as dates.

The exceptions are any functions that originated from the Analysis ToolPak add-in. For an unknown reason, WORKDAY, NETWORKDAYS, WORKDAY.INTL, and NETWORKDAYS.INTL aren’t programmed to show the results as dates.

When you see answers that look like 44953, you’re seeing the date serial number in an unformatted state. Make sure to apply a date format to display the results as dates. SF

Bill Jelen is the host of MrExcel.com and the author of 67 books about Excel. He helped ­create IMA’s Excel courses on data analytics (bit.ly/2Ru2nvY) and the IMA Excel 365: Tips in Ten series of micro­learning courses (bit.ly/2qDKYXV). Send questions for future articles to IMA@MrExcel.com.

Figure 1

Figure 2

A formula such as =RANDBETWEEN("01/01/2023","12/31/2023") is likely to generate a significant number of dates that fall on weekends or holidays.

December 2022 / STRATEGIC FINANCE / 61

TECH PRACTICES

CAN FINANCE TEAMS DEVELOP SOFTWARE?

BY JUN LIU, CMA, CSCA

Finance professionals are empowered to fast-track and boost productivity and control through low-code development platforms.

T

he COVID-19 pandemic has contributed to dramatic changes in the software development industry. While developers continue to generate plenty of new software, things are changing. Rather than relying on software professionals, end users are building their own software using low-code or no-code application platforms.

A low-code application platform, or low-code development platform, provides users with the capabilities of rapid application development and deployment using low-code and no-code technologies. These include declarative, model-driven application design and development together with simplified deployment of applications, like software-as-a-service.

MORE PLATFORMS EMERGE Low-code application platform providers are increasing. Equipped with these platforms,

management accountants can evolve to become champions in the financial digital transformation journey. Vendors whose platform may be known across the industry include: 1. OutSystems 2. Appian 3. Microsoft (Power platform) 4. Salesforce 5. Mendix COMMON FUNCTIONS Most low-code application platforms provide similar functions that enable users to build their own applications with little to no professional IT help. (See Figure 1 for more detail.)

■ Form builder. End users can rapidly build a new form by themselves. For example, a finance professional can create an expense application form with just his or her financial knowledge and simple drag-and-drop mouse steps.

Figure 1 : Low-Code Application Platform System Architecture Common Functions Role/privilege Form Builder

Messaging

Multi-devices

Workflow Engine

Portals Data Intelligence

Data Layer Data definition

62 / STRATEGIC FINANCE / December 2022

Data manipulation

Data query

Data control

■ Workflow engine. Continuing with the form builder example, after building an expense application form, the user can then continue to design the approval flow using the same drag-and-drop operations. No code is required.

■ Data intelligence. The end user can also build custom analytics across multiple data sources without typing one line of source code.

BENEFITS FOR THE FINANCE TEAM Fabrizio Biscotti, vice president of research at Gartner, notes, “The economic consequences of the COVID-19 pandemic have validated the low-code value proposition.” And end user development has become a crucial means of driving digital transformation for finance teams.

McKinsey & Company research estimates that 42% of finance activities can be fully automated (mck.co/3SItIbg), but traditional IT-dependent software development is slowing down productivity and responsiveness to changing business needs. My own research shows that adopting end-user development in finance activities can benefit finance teams in multiple ways.

■ Shorter duration. Without back-and-forth discussion and clarification of requirements between finance users and IT professionals, non-IT employees can build their enterprise-level applications easily with drag-and-drop interfaces and automated workflows, so go-live speed will be faster than ever. Unlike the several months or multiple years required for traditional software development, low-code platforms enable finance professionals to draw their own applications within weeks or even a couple of days.

■ Reduced cost. About a 70% cost reduction can be expected with low-code platform adoption, compared to that of traditonal programs used for software development. It can also free up IT professionals’ time so that they can focus on higher-value strategic tasks such as IT landscape road maps.

■ Higher employee satisfaction. Low-code platforms allow finance teams to achieve independence as well as upskill across the team and drive finance process innovation. Increased transparency and enhanced innovation increase employee satisfaction for both the finance team and IT team.

■ Greater return on investment (ROI). Besides faster development speed, low-code capability also equips finance teams with the agility to adapt as business needs rapidly change. For example, when company policy requires the addition of a new column expense category in an expense application form, end-user developers only need to drag a new list box component into the expense application form and publish the new version to the entire company application store. This kind of speed and agility allows finance team to do more with less. Enterprises will benefit with a greater ROI. Among the forces changing the workplace, low-code application platforms are one of the emerging technologies that matter. End-user development will help finance teams stay updated and relevant as they drive corporate strategy as business partners on the digital transformation journey. SF

Jun Liu, CMA, CSCA, is a solutions architect at Microsoft Japan and a member of IMA’s Technology Solutions and Practices Committee and Japan Chapter. He can be reached at junliu1@microsoft.com.

December 2022 / STRATEGIC FINANCE / 63

LIFE

From Pro Athlete to CMA

BY POLINA NYER, CMA

F

INANCE AND MANAGEMENT ACCOUNTING WAS an unexpected path for me. At the time I discovered the world of business, I was a professional athlete.

My passion is basketball.

I come from a family of basketball coaches, referees, and players, and I guess it’s fair to say it was in my blood. And I happened to be pretty good at it. I turned pro at the age of 16. When I was 17, my contract was purchased by a team in Italy, and I moved there to pursue my dream to play on a professional team.

As someone who became a professional athlete so early in life, most of what I know about the world were lessons I learned from sports. And it’s interesting how the values of sports align closely with those of accounting and finance.

Here are some examples.

Teamwork. The most effective teamwork happens when individual team members harmonize their efforts and work toward a common goal.

Caring about members of the team and the community is a shared value, along with integrity and trust.

Practice makes…better. Perfection doesn’t exist in any profession. This is where continuous learning plays an important role in personal development and motivation. As a professional athlete, I honed my skills to the best of my ability, devoting innumerable hours to improving my technique and physical conditioning. I’ve always been an eager learner, and it’s gratifying to apply this same attitude toward my work in accounting

and finance. I’m also happy to be surrounded by professionals who share this value and encourage each other to do better every day.

Sometimes you lose—and that’s okay. Success and winning aren’t guaranteed, and losses are learning experiences to build upon. On the basketball court and in my financial career, I’ve always tried to take failures and turn them into new opportunities.

I discovered finance and management accounting while pursuing my bachelor’s degree at the University of Bergamo in Italy. I loved these subjects, and, although I continued playing basketball, I eventually decided to leave my job as a pro athlete to explore several business internships. Years later, after I had earned my master’s degree and was working as a financial analyst at HP, I heard about the CMA® (Certified Management Accountant). I wanted to get out of my comfort zone and challenge myself with a professional certification. I did extensive research on the global certifications available, and I chose the CMA because of its broad scope and focus on key skills in the profession. I earned my CMA in 2020.

And my journey continues. Recently, I was one of five participants selected for the IMA® Young Professional Leadership Experience.

As part of the program, we had the incredible opportunity to attend the IMA Global Board of Directors meeting and visit IMA’s global headquarters in New Jersey in October 2022. This was a truly inspiring experience. Seeing IMA leaders in action and hearing the relevant topics discussed was motivating and insightful. It was a great networking opportunity to meet so many IMA leaders at once, and I’m excited to see what my IMA future holds. SF

« I wanted to GET OUT OF MY COMFORT ZONE and CHALLENGE MYSELF.»

Polina Nyer, CMA, is senior finance lead, digital transformation and advanced analytics, at HP in Barcelona, Spain, and a member of IMA’s Spain Chapter. You can reach Polina at polina.nyer @gmail.com.

64 / STRATEGIC FINANCE / December 2022

Think and lead strategically with the

CSCA

The CSCA® (Certified in Strategy & Competitive Analysis) certification helps you build strategic analysis, planning, and decision-making skills that are critical for current and rising leaders in accounting and finance.

PROGRAM HIGHLIGHTS

• The strategy certification designed specifically for CMAs • 3-hour exam: 60 MCQs and 1 case study • Flexible study options • 30 CPE credits when you pass the exam* • March and September exam windows * Earn up to an additional 21 NASBA CPE credits by successfully completing the IMA Learning Series.

Enroll today at www.imanet.org/CSCA

KEY KNOWLEDGE DOMAINS OF THE CSCA

Strategic Analysis

Creating Competitive Advantage

Strategy Implementation & Performance Evaluation