970 likes | 1.32k Views
Rotman School of Management, March 19, 2002. 2. Agenda. BackgroundEnronAccounting Disclosure ManipulationEnron ProblemsStructures, activities and disclosuresControl and cultureLessonsGovernanceAccounting standards and professionDirector's BehaviourQuestions. Rotman School of Management, March 19, 2002.
E N D
1. Enron Briefing Clarkson Centre for Business Ethics
& Board Effectiveness—CC(BE)2
& Executive Programs
Rotman School of Management
March 19, 2002
2. Rotman School of Management, March 19, 2002 2 Agenda Background
Enron
Accounting Disclosure Manipulation
Enron Problems
Structures, activities and disclosures
Control and culture
Lessons
Governance
Accounting standards and profession
Director’s Behaviour
Questions
3. Rotman School of Management, March 19, 2002 3 Rotman Briefing Team Ramy Elitzur – Accounting, Audit
Former Director, MBA Program, elitzur@rotman.utoronto.ca
Irene Wiecek – Accounting, Audit
Associate Director, MMPA, wiecek@rotman.utoronto.ca
Eric Kirzner – Finance, Governance
Director, Market Regulation Services, + kirzner@rotman.utoronto.ca
Len Brooks – Governance, Ethics, Accounting, Audit
Exec. Dir. , The Clarkson Centre for Business Ethics & Board Effectiveness
Director , Master of Management & Professional Accounting (MMPA)
Director, Diploma in Investigative & Forensic Accounting (DIFA)
brooks@rotman.utoronto.ca
4. Rotman School of Management, March 19, 2002 4 The Enron Affair Management was:
out of control, and engaged in self-dealing
manipulating transactions & financial reports
Company imploded - Chap. 11 in Dec. 2001
Investors misled, pensions lost
Executives plead the 5th, poor memory, ignorance, incompetence
Outrage
Auditor savaged, profession to be changed
5. Rotman School of Management, March 19, 2002 5 Overview of Key Problems Governance failure at the Board level
Too much trust
Incompetence - awareness and/or understanding of role , control & reporting systems
Lack of motivation, conflicts of interest
Dishonest management, conflicts of interest
Culture of deception, self-interest
Manipulation of accounting and disclosure
Poor standard setting
Auditor deficiencies
Regulatory short-sightedness
6. Rotman School of Management, March 19, 2002 6 Enron Stock Chart
7. Rotman School of Management, March 19, 2002 7 Enron’s Business (10K-2000) Transportation and distribution
Wholesale services
Commodity sales & services, risk management products, plants, etc
Retail energy services - gas, electricity
Broadband services
Nationwide fiber-optic network - build, market, etc.
Corporate and other
operation of water, renewable energy, and clean fuels plants plus other corporate activities
8. Rotman School of Management, March 19, 2002 8 Enron’s Income (IBIT):Income Before Interest, Minority Interest and Income Taxes 2000 1999 1998
Transport & distribution ($ mil.)
Trans. Services 391 380 351
Portland General 341 305 286
Wholesale Services 2,260 1,317 968
Retail Energy Services 165 (68) (119)
Broadband Services (60)
Exploration & prod. - 65 128
Corporate and other (615) (4) (32)
IBIT 2,482 1,995 1,582
9. Rotman School of Management, March 19, 2002 9 Enron’s Wholesale Services …creation of networks involving selective asset ownership, contractual access to third-party assets and market-making activities. 10K p.36.
…uses portfolio and risk management disciplines, including offsetting or hedging transactions, to manage exposures to market price movements (commodities, interest rates, foreign currencies and equities). 10K p.37.
… sells interests in certain investments and other assets to improve liquidity and overall return, 10K p.37
10. Rotman School of Management, March 19, 2002 10 Enron’s Financial Data 2000 1999 1998
Revenues (in Billions) 100.8 40.1 31.3
Operating income (Millions) 1,953 802 1,378
IBIT 2,482 1,995 1,582
Net Income before Cumulative
Accounting Changes 979 1,024 703
Net Income 979 893 703
EPS (in dollars) - basic 1.22 1.17 1.07
- diluted 1.12 1.10 1.01
11. Rotman School of Management, March 19, 2002 11 Enron’s Financial Data 2000 1999
Current assets (Billions) 30.4 7.3
Investments, other 23.4 15.4
Property, plant, equip, net 11.7 10.7
Total Assets 65.5 33.4
Current liabilities 28.4 6.8
Long-term Debt 8.6 7.2
Deferred credits and other 13.8 6.5
Shareholders’ Equity 11.5 9.6
Total Liab. & Shareholders’ Equity 65.5 33.4
12. Rotman School of Management, March 19, 2002 12 Enron’s Changing Risk Profile Early By Risk
1990’s 2000 Level
Pipelines, distribution networks ? ? Low
Retail energy ? ? Low
Power generation ? ? Low
Oil and gas exploration ? ? Med.
Alternative energy ? M/H
Hedging transactions ? High
Commodity trading transactions ? High
Broadband optical fiber networks ? V. High
Related party transact. (SPEs/Partnerships) ? ???
13. Rotman School of Management, March 19, 2002 13 Corporate Governance Role of the Board of Directors - traditional
strategic objectives - set or approve
company policies and procedures:
set or approve
ensure dissemination and compliance
laws, regulations, & expectations of society
ensure monitoring and compliance
act as ethical conscience (Dey Report & CICA)
14. Rotman School of Management, March 19, 2002 14 Enron’s Governance Failure Begins 1997 - Board suspends code of conduct to deal with an SPE (JEDI/Chewco) emergency (alternative controls considered …not implemented)
Can’t find outside investor before year-end
Non-consolidation tests not satisfied:
Outside investor - 3%investment at risk, control.
Fastow (CFO) has Koppers - who reports to Fastow - appointed to run/invest/control SPE
Realization that guard is down/can be controlled
15. Rotman School of Management, March 19, 2002 15 Enron’s Governance Structure
16. Rotman School of Management, March 19, 2002 16 Governance Failure Allows Fastow to control SPE transactions:
Sales of assets at inflated prices (False gains)
False hedging of losses on Enron investments (Falsely keeps losses off Enron Income Stat.)
Exorbitant payments to Fastow & helpers
Hiding of SPE debt ultimately to be borne by Enron
Fastow to create more SPEs (LJMs…)
Manipulation of accounting disclosure
17. Rotman School of Management, March 19, 2002 17 Partial Impact Payments to Fastow & helpers
Invest._ Return Other
Fastow $25,000 $4.5 mil in 2 mo. $30 mil+stock options+
Koppers 125,000 10 mil (incl. $2 mil in fees
friend)
2 others 5,800 1 mil
Manipulated transactions in Q3 & Q4, 1999
Asset sales, plus 1 hedge $229 profit of $570 before tax
and 549 after tax (~50%)
18. Rotman School of Management, March 19, 2002 18 Manipulation of Accounting Disclosure
A Backgrounder
The Accounting Art of War
By Ramy Elitzur
19. Rotman School of Management, March 19, 2002 19 The Accounting Art of War “A Strategy of Positioning evades Reality and confronts through Illusion.”
The Art of War by Sun Tzu
20. Rotman School of Management, March 19, 2002 20 The Accounting Art of War “Appearance and intention are fundamental to the Art of War. Appearance and intention mean the strategic use of ploys, the use of falsehoods to gain what is real.”
The Book of Family Traditions on The Art of War, Yagyu Munenori
21. Rotman School of Management, March 19, 2002 21 The Accounting Art of War The accounting art of war incorporates the entire menu of reporting strategies that management employs to manipulate financial statements.
Involves much more than earnings management.
22. Rotman School of Management, March 19, 2002 22 The Agency Framework Modern corporations have a separation of ownership and management.
As such, there is an inherent conflict of interests between shareholders and managers.
Mechanisms to alleviate the agency problem:
Compensation plan (to create goal congruence between shareholders and managers)
Monitoring or auditing, both internal and external.
23. Rotman School of Management, March 19, 2002 23 The Agency Framework In The Context of Enron The Mechanisms to alleviate the agency problem failed in Enron:
The compensation plan: Not only it did not reduce the agency problem but it actually exacerbated it.
Monitoring or auditing, both internal and external failed to bring the accounting problems to light.
24. Rotman School of Management, March 19, 2002 24 Tools in The Accounting Art of War Earnings Management
Revenue Manipulation
Off-Balance-Sheet Liabilities
Sheer Opportunism
25. Rotman School of Management, March 19, 2002 25 Tools in The Accounting Art of War Earnings Management
Companies may want to:
Increase reported earnings.
Decrease reported earnings.
Smooth earnings.
26. Rotman School of Management, March 19, 2002 26 Earnings Management Merchant (1990) and Merchant and Bruns (1990) find that earnings management is a widespread phenomenon.
Furthermore, the same studies surveyed managers and report that, according to these managers, earnings management is an acceptable practice.
27. Rotman School of Management, March 19, 2002 27 Increasing Reported Earnings Why?
This could increase bonus and other compensation.
28. Rotman School of Management, March 19, 2002 28 Examples Enron
Waste Management where the company overstated income from 1992 to 1996 by more than US$ 1 billion.
Livent, Inc.
29. Rotman School of Management, March 19, 2002 29 Income Decreasing Strategy Why?
In cases of monopoly because of anti-trust considerations.
Regulated utilities.
‘Blood Bath’.
30. Rotman School of Management, March 19, 2002 30 Example Microsoft
The issue of capitalization of software development costs.
Does this strategy have a significant impact?
31. Rotman School of Management, March 19, 2002 31
32. Rotman School of Management, March 19, 2002 32
33. Rotman School of Management, March 19, 2002 33 The Accounting Art of War (Cont.) Manipulation of Valuation
Companies may want to increase reported revenues.
Example: MicroStrategy
34. Rotman School of Management, March 19, 2002 34 MicroStrategy the Securities and Exchange Commission, when moving to crack down on lax accounting standards, in December 2000 has found that MicroStrategy Inc., an inventory-management software maker, was prematurely recognizing revenue.
35. Rotman School of Management, March 19, 2002 35 MicroStrategy Stock Price
36. Rotman School of Management, March 19, 2002 36 Sunbeam A new CEO, "Chainsaw Al" Dunlap, was hired in mid 1996 to turn the company around. A year after he was hired, Al Dunlap Dunlap declared success in turning Sunbeam Corp. around in terms of profits and revenues.
It was later found that the revenue growth came from manipulation of revenues.
37. Rotman School of Management, March 19, 2002 37 Sunbeam (Cont.) The company instituted an "early buy" program for gas grills in the fourth quarter that gave retailers the opportunity to buy grills in November and December of 1997 but not pay until as late as June 1998.
The company also started a "bill and hold" program that allowed Sunbeam customers to use its warehouses to store goods that they had bought, but not necessarily paid for.
38. Rotman School of Management, March 19, 2002 38 Sunbeam (Concluded) Between them, these two programs accounted for a substantial part of Sunbeam's apparent revenue gains in 1997. In essence, these revenues were nothing more than future sales booked now. When this was found out the prices of Sunbeam Corp. shares plunged.
39. Rotman School of Management, March 19, 2002 39 Other Notable Examples of Revenue Manipulation Rite Aid (inflated revenues in 1998 and 1999 by over US$ 1 billion)
HomeStore.com (booked US$ 54 million to US$ 95 million as ad revenue in the first three quarters of 2001 that it never received in cash but as a result of revenue swaps with advertisers for undisclosed goods and services).
40. Rotman School of Management, March 19, 2002 40 Off-Balance-Sheet Financing Companies may want to omit debt from the balance sheet.
41. Rotman School of Management, March 19, 2002 41 Example of Off-Balance-Sheet Debt Enron
Motivation:Lower cost of debt to finance aggressive acquisition strategy.
Special Purpose Entities (SPEs). Debt omitted over $600 million.
Financial Instruments. Debt not shown on the balance sheet $1.5-3 billion.
42. Rotman School of Management, March 19, 2002 42 GE Just recently (March 2002) General Electric Co. reported that it had off-balance-sheet SPEs that held US$56 billion of assets at the end of 2001, up from US$ 41 billion a year earlier.
43. Rotman School of Management, March 19, 2002 43 Kmart Kmart has long-term lease commitments that had, based on my calculations, a present value around US $5.5 billion in 2000. When added both to the assets and liabilities of Kmart in 2000 it changed the debt to equity ratio from 1.4 to 2.3 and the debt/assets ratio from 58% to 70%.
44. Rotman School of Management, March 19, 2002 44 Air Canada A similar exercise in Air Canada resulted in an addition of C$ 7.5 billion of assets and liabilities and a jump in the debt/equity ratio from 17.72 to 38.38.
45. Rotman School of Management, March 19, 2002 45 Adjustment for Off-Balance Sheet Leases - HBC (1999)
46. Rotman School of Management, March 19, 2002 46 Opportunism
Example: Air Canada
47. Air Canada Q2’01: Revenues hurt by economy, competition
48. Air Canada Q1’01: Difficult Economic, Cost Environment
49. Rotman School of Management, March 19, 2002 49 How Fastow/Enron Misused SPEs
To manipulate financial reports and
siphon off funds to Fastow & helpers
until the company imploded.
By Irene Wiecek
50. Rotman School of Management, March 19, 2002 50 Guiding Financial Reporting Principles Economic substance over legal form – portrayal of reality
Which assets and liabilities are part of the company?
When is a transaction a bona fide transaction?
Management intent
Arm’s length presumption - party is unrelated and bargaining on its own account – therefore price and terms fairly arrived at.
Versus related party transactions – fiduciary responsibilities
Transparency – also a fundamental principle of efficient capital markets
51. Rotman School of Management, March 19, 2002 51 Decision making principles
All the relevant information available?
Quality of information i.e. based on reality, numbers reliable?
Understandable?
52. Rotman School of Management, March 19, 2002 52 Economic entity concept - extends beyond legal entity
Economic Entity
Legal Entity Which assets & liabilities are part of the company?
53. Rotman School of Management, March 19, 2002 53 Economic entity concept Report on resources controlled by the company – where the company has the potential to reap the benefits but is also exposed to the risks
Consolidated financial statements recognize that even though there may be separate legal entities, together, they constitute an economic unit
54. Rotman School of Management, March 19, 2002 54 The Concept of Control Continuing power to determine strategic policies without the cooperation of others
Spectrum
No control Significant Joint Control
Influence Control
Related parties
55. Rotman School of Management, March 19, 2002 55 Control Benchmarks General presumption regarding control
Normally – equity ownership >50% - must also prove control exists
SPE – U.S. equity investment (at risk) >3% (now 10%), Canada >10% - must also prove control exists
56. Rotman School of Management, March 19, 2002 56 SPE Primer Consider the following:
Demonstrably distinct – cannot be unilaterally dissolved by transferor, outside ownership
Restrictions on activities
Legal form - may be corporation, partnership or trust
57. Rotman School of Management, March 19, 2002 57 SPE Primer Business reasons for creating SPE
Economic benefits i.e. collateralize assets, share risk, obtain more favourable financing, cash out,
Examples - synthetic leases, pools of similar assets (AR, mortgages, investments)
Wrong reasons
get debt off financial statements, hide losses/risks, generally manipulate financial statements, “P&L protection”
58. Rotman School of Management, March 19, 2002 58 Enron’s SPEs
59. Rotman School of Management, March 19, 2002 59 Chewco/JEDI Intent - JEDI Originally formed in 1993 with CalPERs to syndicate investment opportunities. Enron wanted to find another investor in 1997 so that CalPERs would invest in another vehicle.
Chewco formed 1997 as SPE
Nov 2001 – accounting reviewed and determined to be in error – consolidated retroactively
60. Rotman School of Management, March 19, 2002 60 Chewco/JEDI Kopper/Dodson Dodson
LP/GP Big/Little
SONR River
$11.4
GP LP
$11.4
ENRON Chewco
$132 LP Barclays GP $240 JEDI
61. Rotman School of Management, March 19, 2002 61 Chewco/JEDI
62. Rotman School of Management, March 19, 2002 62 LJM1/Rhythms Intent – Transfer of risks/provide additional markets
Fastow GP – seek outsides investors
Formed 1999 - 20 transactions to 2001
Rhythms/Net connections
Little market for CS (Enron had large holding). Worried about price risk.
Unwinding
63. Rotman School of Management, March 19, 2002 63 LJM1/Rhythms Fastow
LP/GP ERNB/
Campsie
LJM Partners
Fastow $15
GP GP LP
$1
LJM Swap LJM1
Co LP LJM GP Swap Sub
64. Rotman School of Management, March 19, 2002 64 LJM1/Rhythms 3.4 million CS Enron FV $276 ($168 discounted)
ENRON LJM1/Swap
Rhythms CS Sub
$64 Note
$104 Put option on Rhythms CS (Swap to $168 buy Rhythms CS at $56) FV $104
65. Rotman School of Management, March 19, 2002 65 LJM1/Rhythms
66. Rotman School of Management, March 19, 2002 66 LJM/Other Issues
Selling to LJM assets that it could not sell elsewhere – subsequently repurchased
Economic substance? Bona fide transaction? Guarantee against losses
At issue – gain recognition
67. Rotman School of Management, March 19, 2002 67 LJM2/Raptors Intent
Syndicate capital investments
Hedge
Create markets
Fastow GP- Formed Oct 1999
Significant contribution to NI $1 billion 3Q 2000 to 3Q 2001
4 Raptors – 2 of which discussed below
68. Rotman School of Management, March 19, 2002 68 LJM2/Raptors Fastow/Kopper
LP/GP 50 Limited
Partners
LJM2 CMLP
$394
GP LP
LJM2
$30 LP Talon
69. Rotman School of Management, March 19, 2002 69 LJM2/Raptor 1/Talon Capitalization and $41 put $350 - 3.4 million CS Enron FV $537 ($350 discounted)
$50 million note
$41 million premium on put
ENRON/ LJM2/Talon
Harrier
LCC interest
$400 million Note
Put option on Enron CS – Talon to buy Enron CS @$57.50
70. Rotman School of Management, March 19, 2002 70 LJM2/Raptors
71. Rotman School of Management, March 19, 2002 71 LJM2/Raptor 1/TalonTotal return swaps Intent to protect Enron against losses on merchant investments
Enron pay future gains on investments to Talon
Talon pay to Enron future losses on investments
Locked in value on Enron’s books
72. Rotman School of Management, March 19, 2002 72 LJM2/Raptor 1/TalonTotal return swaps
73. Rotman School of Management, March 19, 2002 73 LJM2/Raptor 1/TalonCostless Collars Intent to shore up creditworthiness of Talon
If Enron CS fall below $81, Enron pays Talon difference
If Enron CS increases above $116, Talon pays Enron difference
Costless since premiums equal
74. Rotman School of Management, March 19, 2002 74 LJM2/Raptor 1/TalonCostless Collars
75. Rotman School of Management, March 19, 2002 75 LJM2/Raptor 3 Issues
TNPC – held shares of the very shares that they were meant to hedge.
Not presented to the BOD
76. Rotman School of Management, March 19, 2002 76 Things to think about Business model – non standard transactions/changing business model
Intent - structuring transactions to achieve accounting objective versus economic objective
Narrow interpretation of GAAP - the 3% test – rules based versus principles based
Complexity – non-standard legal structures
Documentation – deal sheets, formal approvals
When the legal form becomes more important than the economic substance
77. Rotman School of Management, March 19, 2002 77 Enron’s Governance StructureWas Short Circuited
78. Rotman School of Management, March 19, 2002 78 Enron’s Ethical Culture Code suspended, alternate controls ignored
Bogus trading floor for visiting analysts
Whistleblowers/doubters came forward (to), but
Co-chair (Lay) resigned, 32 mil. … suicide?
Kaminsky (Fastow) …….. ignored
McMahon (Fastow)...transferred …now CFO
Sharon Watkins (Lay)… Enron’s law firm
found no problem …fox in the chicken coup
No protected whistleblower path to the Board
Do we need an Ethics Committee?
79. Rotman School of Management, March 19, 2002 79 New Board Responsibilities Comprehensive Risk Management
Broad understanding of business model
Financial literacy
Guidance & Control framework
Focus on corp. culture, ethics & reputation
Business ethics…whistleblower protection plan
Ethics Risk Management
Trust, but challenge, don’t turn away
Caremark National Case, trend
80. Rotman School of Management, March 19, 2002 80 Comprehensive Risk Management requires understanding the business Risk Events Causing Drops of Over 25% Share Value,
Percentage of Fortune 1000 companies, 1993-1998
Strategic ……………………………. 58%
Customer demand shortfall (24) Competitive pressure (12)
M & A Integration problems (7) Mis-aligned products (6)
Operational …………….31%
Cost overruns (11) Accounting irregularities (7)
Management ineffectiveness (7) Supply chain pressures (6)
Financial ………..6% [Foreign macro-eco, interest rates ]
Hazard …….0% [Lawsuits, natural disasters]
Source: Mercer Management Consulting/Institute of Internal Auditors, 2001
81. Rotman School of Management, March 19, 2002 81 Comprehensive Risk Management includes Ethics Risk Management Ethics Risk Reputation Success
Reputation is important
Arthur Andersen…………… survival
RBC Dominion………reputational capital
Tylenol ……………competitive advantage
Selling trust and credibility, not pills, …
82. Rotman School of Management, March 19, 2002 82 Comprehensive Risk Management depends upon the Corporate Ethical Culture Comprehensive Risk Management utilizes both:
A. Key risk factor identification & measurement
B. Review of key business processes including the ethical culture that underpins process integrity
Ethical culture provides guidance for employees about when to adhere to the Code, when actions are not covered in Code, in a grey area, or in a crisis - tools to measure ethical culture do exist
Enron’s Board failed to consider any of this!
Few corporations do A, fewer do B!
83. Rotman School of Management, March 19, 2002 83 Audit Committee must Understand key business operations
Understand comprehensive risk management model and reports
Examine key/large transactions
Ensure compliance with good policies
Ensure fair presentation
Who wants this risk?
How much should the members be paid?
84. Rotman School of Management, March 19, 2002 84 Accounting Standards & Disclosure FASB’s 3% standard was too low … now changed to 10%
Need rededication to:
fair presentation, not specific rules orientation or pro forma illusions
clarity
transparency
SEC/IASC will be more evident… Can.?
85. Rotman School of Management, March 19, 2002 85 Audit & Professional Standards SEC rules on non-audit services
More emphasis on professional ethics
Stronger enforcement/punishment for individual professionals:
in accounting/audit firms
in corporate clients
Is it in the public interest to shut down Arthur Andersen?
86. Rotman School of Management, March 19, 2002 86 Eric Kirzner:A Director’s Commentary An eye-opening example from my experience
My criteria – must be met before I accept a Director’s post.
Tradeoffs a Director must understand
Process steps for a Director to consider
87. Rotman School of Management, March 19, 2002 87 Finance, Governance 1. AME HISTORY
Listed Montreal Exchange
Board: affinity people; friends of management
Going Private transaction
Independent committee
NOBODY:
Management; board members understood!
88. Rotman School of Management, March 19, 2002 88 Membership Criteria My criteria for serving:
1. I am an expert in the field
2. The other board members: either experts, or knowledgeable and representing key stakeholders
union reps on pension plans for example
3. No Cronyism
89. Rotman School of Management, March 19, 2002 89 Membership Criteria My criteria for serving:
4. Chair is expert, experienced and understands balance between unfettered debate and accomplishments.
90. Rotman School of Management, March 19, 2002 90 Membership Criteria My criteria for serving:
5. All functions in place
Management; internal audit and external audit
Independence of internal audit and management
Independent directors
50% plus?; public governor proxy
Fee for service!
91. Rotman School of Management, March 19, 2002 91 Membership Criteria My criteria for serving:
6. Committee Structure
Governance
HR
Audit and finance
Risk management
Independent directors dominate committees?
92. Rotman School of Management, March 19, 2002 92 Understand Tradeoff Paradigm #1
DIRECTORS TO:
“ Act in best interest of…”
Company (statutory) OR
Shareholders (regulatory)
Paradigm #2
Maximization of Shareholder wealth
Paradigm #3
Public/ethical responsibility
93. Rotman School of Management, March 19, 2002 93 Process For Board Member A Model
Can you develop checklist of responsibilities
Example: meet CDIC guidelines?
2. Committees
Audit, HR, finance
Appropriate trade-off approval and recommending
94. Rotman School of Management, March 19, 2002 94 Process 3. Board self-assessment
Peer group review
Chair review
4. Independent Directors; Public Directors
Must understand everything
Ultimate sanction of voting with their feet!94
95. Rotman School of Management, March 19, 2002 95 Comments & Questions The Last Word
Ramy
Irene
Questions
96. Rotman School of Management, March 19, 2002 96 New Governance Series For directors and senior officers:
Director’s Responsibilities
Financial literacy
Guidance and control systems
Ethics risk management
Comprehensive risk management
97. Thank You on behalf of the
Clarkson Centre for Business Ethics
& Board Effectiveness—CC(BE)2
Executive Programs
Rotman School of Management