November 2016 - Issue 28
RSM reporting Technical developments in global accounting and reporting.
THE POWER OF BEING UNDERSTOOD AUDIT | TAX | CONSULTING
Welcome Dear reader, As Europe has been the cradle of IFRS and has played a decisive role in its global success, a significant change in the European geo-political setting is relevant to IFRS as much as it is to many other aspects of international business and trade. Therefore, the November issue opens with an interview with the chairman of the Corporate Reporting Policy Group at the Federation of European Accountants, Mark Vaessen, who shares with us his views on the possible effects of Brexit on the development of IFRS. As this is the last issue of 2016, Joelle Moughanni provides a valuable recap of the IFRS developments of the year. The technical advice in this issue focuses on intracompany loans, which may present, in some situations, challenges even for the most experienced. Enjoy your reading! Marco
Prof. Marco Mongiello, PhD, ACA m.mongiello@surrey.ac.uk
“As Europe has been the cradle of IFRS and has played a deCISIVE role in its global success, a significant change in the European geo-political setting is relevant to ifrs as much as it is to any other aspects of international trade. �
Mark Vaessen is the chair of the FEE Corporate Reporting Policy Group and a member of the EFRAG Board. Mark is a Dutch national, who lives and works in London. He is a partner with KPMG LLP in the UK, and Global Head of IFRS for KPMG International. In addition, Mark is a member of the Consultative Working Group to ESMA’s Corporate Reporting Standing Committee and the ICAEW’s Financial Reporting Faculty Advisory Group. He is also a former member of the IFRS Advisory Council.
REFleCTIONS ON THE FUTURE OF ACCOUNTING AND REPORTING - A conversation with MARK VAESSEN by the Editor Developments in international accounting and reporting are driven by changes in business models and technological innovations, as well as being influenced by macro-economic events and political decisions. This is what keeps our profession relevant and effective at fulfilling its purpose of providing decision makers with reliable information, on which they may base their decision-making processes. It is therefore important that we endeavour to obtain an insight into the effects of major political decisions, such as Brexit, which may change the regulatory and economic landscapes of large jurisdictions as we know them. We are interested in understanding if and how Brexit may affect the way accounting and reporting are regulated, endorsed and developed in Europe. For this reason, I approached the person who occupies the most advantaged observation point with regard to accounting and reporting in Europe: Mark Vaessen, EFRAG board member and chairman of the Corporate Reporting Policy Group at the Federation of European Accountants (FEE). FEE, by its own account, represents 50 institutes of professional accountants and auditors from 37 European countries, including all of the 28 EU Member States. With regard to the possible effects of Brexit on international accounting and reporting, Mark Vaessen explains that “it is very early days”.
MV: There is still a lot of uncertainty about what relationship the UK will have with the EU once it leaves, and if it leaves. However, assuming that the UK will leave the EU, the IAS regulation will continue to be applicable to the UK for quite a while, as during the time when the negotiations will take place, the UK will still be a member of the EU. Therefore, nothing will happen for probably three years, allowing for two years to negotiate the exit as the maximum upon triggering Article 501, which could happen in 2017 or later2. The date for official notification by the UK of triggering Article 50 may be impacted by the timing of the general elections in France and Germany. For the longer term scenarios, one possibility is that the UK will still be part of the EU market, hence continuing to adopt the IAS regulation, including the endorsement process. This scenario is what I would call the Norwegian model3. However, from my perspective, the more likely scenario is that the UK will no longer be under the IAS regulation and will have to determine for itself what it wants to do with the IFRS. When considering this scenario, you should look at the investment that the UK has made with respect to IFRS over several decades. The UK was quite instrumental in getting the IASB acknowledged and was also strongly supportive in making sure that we, in Europe, got IFRS at a time when the risk was emerging of many companies moving over to US GAAP. In Europe, we had to come up with a plan to have standards that reflected the European tradition, and still would be harmonised and serve the international capital market. The UK, at that time, was a big supporter of IFRS. The UK had valuable standard-setting experience at the time in developing UK GAAP but it realised that ultimately its principles-based approach to standards would have lost out to US GAAP if it did not put its weight fully behind the International Accounting Standards. With that history in mind, I would say that, even if the UK will no longer be bound by the IAS regulation, it will continue to be a strong supporter of the global standards, as it has always been. In addition, it will want to keep the UK markets attractive for global companies. Therefore, I have no reason to believe that the support will diminish. Rather, for the foreseeable future, accountants
1 Editor’s note: Article 50 of the Lisbon Treaty (www.lisbon-treaty.org) stipulates that any Member State of the European Union may decide to withdraw from the Union by providing formal notification of its intention. It also stipulates that the Treaty will cease to apply to that Member State within two years of the notification. 2 Editor’s note: since the interview took place, the UK prime minister indicated that the UK will trigger Article 50, i.e. will give notification of its intention to withdraw from the European Union, in the first quarter of 2017. 3 Editor’s note: Mark Vaessen refers to the bundle of bilateral agreements that define the economic and political relationship between Norway and the European Union, whereby Norway, albeit not a Member State of the European Union, enjoys a status that is in many respects similar to that of a Member State.
need more and more high-order skills in data-mining and analyses and in making judgements and estimates. MM: Might EFRAG, FEE and the EU’s clout in the global accounting scene be weakened as a consequence of representing a smaller economy? MV: Personally, I think that the change [brought by Brexit] will be neutral. You raise a legitimate question, though, because the UK provides large parts of the capital market and liquidity in Europe, so taking that out of the endorsement could make Europe have a weaker negotiating position. On the other hand, the market in the rest of Europe will still be large, and efforts are being made to stimulate the capital markets in the EU outside of London. On balance, I do not think that the impact and the power that Europe has on the IASB will diminish. I also do not think that the UK’s impact on the IASB will be diminished by stepping out of bodies like EFRAG. There is an argument that because the UK will be able to speak directly to the IASB, its voice will be less filtered; having the direct contact with the IASB may actually increase the UK’s voice. My opinion, though, is that the effect will overall be neutral. MM: This applies to IFRS, but what about IFRS for SMEs? Their adoption seems to be getting some momentum around the world, but not in Europe. Will Brexit give their adoption a boost? MV: If you look at the status now, IFRS for SMEs are not widely used in Europe. They have influenced national standards of a few EU countries, the UK included, but no country has taken the IFRS for SMEs as they are. The European Commission is currently looking at whether we need separate standards for companies that are listed on smaller markets. There is a question as to whether IFRS for SMEs are the right standards for this purpose, because they are not written for publicly owned companies; they are written for privately owned companies. The [European] Commission is liaising with the IASB to see whether there are alternatives to IFRS for SME for smaller listed companies, for example [to apply IFRS with reduced] disclosure requirements for those companies. In the meantime, the IASB is also working more generally on the Disclosure Initiative and it is looking at what it calls ‘Principles of Disclosure’. This may be promising, because I believe that if you define the right
principles, you will end up with less complex accounting and reporting, and in that way, smaller listed companies could still use full IFRS, but then with reduced disclosures. So, IFRS for SMEs is still a discussion to be had in Europe and I cannot see that Brexit changes the dynamics of that discussion. The reason why countries have not adopted IFRS for SMEs is because they have their own GAAPs, which often are very closely linked with national taxation, capital maintenance and distribution requirements. If you take countries like France or Germany, these are issues that are so close to the national interest that these countries are reluctant to hand them over to an international standard setter independently of Brexit or not. The UK has a successful AIM4, where a lot of smaller companies are seeking equity funding, listing on the basis of IFRS. Most of the other countries in Europe do not have an equivalent of the AIM, but the capital markets in the EU are trying to promote the establishment of similar stock exchanges. Therefore, I think that the discussion on IFRS for SMEs will focus, for the first instance, on that part of the SMEs market. In summary, I would be really surprised if Brexit caused a lot of changes in the developments of accounting and reporting. I predict that there will be some continued discussions in Europe on whether we should bring on European standards, but I would say that if you look at the consultation on the IAS regulation that the [European] Commission carried out in 2014, there was a groundswell support for global standards – people say that it has achieved great benefits – and generally, there was no support for European standards. After Brexit, the voice supporting European standards may be a bit louder, but generally the mood is that this is not in the interest of the many European companies acting on the global stage, and therefore is unlikely to prevail. MM: On the other hand, change in accounting and reporting is on the horizon, as acknowledged in the Future of Corporate Reporting Cogito Paper, which FEE published in 2015. Can we expect IFRS to evolve in the direction of allowing for more effective metrics to evaluate companies’ performance, particularly in situations where profit and cash flows seem to fail to capture the companies’ value and value creation? How will these developments pan out in a post-Brexit context?
Editor’s note: AIM, or Alternative Investment Market, is the London Stock Exchange’s international market for smaller growing companies.
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MV: This is an excellent point. We [at FEE] have some work to do as a follow-up on the paper on the future of corporate reporting. We have to make clear that when we talk about non-financial information, we are not talking only about ESG5. ESG are important, and there are elements of ESG that are more important for some companies than others, e.g. environmental indicators are more important for an oil company than for a professional service company, because environmental performance is not value driving in a service company, but clearly it is in an oil company. However, performance is broader than ESG. We have to take into account operating performance metrics, which are leading indicators for future value creation. They may be customer satisfaction scores, employee loyalty, creation of intellectual capital, the number of trademarks registered, or whatever the measure is that ultimately reflects the company’s longer term success. At the moment, for reporting these aspects of a company’s performance, we rely very much on the front end of the annual report, where we have a lot of liberty but not a lot of discipline. Most KPIs are not comparable and, although analysts will try all sorts of ways to bring in comparability, there is no real structure. You need to have a framework that instils a certain level of quality and discipline in reporting these KPIs; this is the direction we ought to go. For example, the economic performance of Tesla6 is determined by the success of whatever engine, battery or technology is Tesla’s long-term value driver. However, a lot of the information about these value drivers is in the front end of the company’s corporate report and comes from systems that are not at the same level in terms of quality as the systems that produce financial information. The internal control over those systems are nowhere near to what companies have in place for financial reporting. We [at FEE] are looking at making them more ‘investment grade’, by bringing more discipline around them. Part of this is in the discussion of the ‘Core&More’ in the FEE report. Integrated Reporting (<IR>) is consistent with this view7; its principles recommend to report what is really crucial to your value creation, what the company’s management board monitors very closely in order to know if the business is doing well or not. You then have to take those metrics and report on those consistently, and not change the metrics when they would show you in a negative light, providing
more consistency and comparability over time. I think, in the same way, you have to report on what is really crucial for your company and hold yourself accountable against those KPIs. On this topic, the discussion we are having with the IASB includes the question of whether we should take on a project on intangibles. The reason for questioning this is that we will never be able to remove the difference between market capitalisation and book value of assets on the balance sheet, because they are influenced by so many other factors. So, we just need to be better at reporting those other factors that make up the difference. If I look around the world, I see that in many ways the UK has taken a leading role in trying to make improvements to reporting after the financial crisis, by recognising and addressing a number of weaknesses. The UK is not there either, but I think that it has taken important steps making some corporate governance changes, e.g. the work on the strategic report, requiring boards to declare that this report is ‘fair, balanced and understandable’, and also the focus on ‘clear and concise’ reporting. These initiatives together have already moved the pendulum quite a bit. We should now be looking at an international level and consider what we can learn from the UK experience and whether we can replicate it. I think that the UK will continue to be an important player in the discussion around reporting, in being at the forefront of those developments. The UK is an environment where people are open to change and to development in corporate governance and reporting. For example, the Financial Reporting Lab8; can we replicate it internationally? What are the means needed to be able to do the same at an international level? These are follow-up discussions that we are going to have on the FEE paper. Moving the corporate reporting agenda forward at international level needs cooperation, and ownership of this ‘agenda for change’, including by the IASB and security regulators. [Brexit or not], the UK will have an important role in this process. MM: I am grateful, on behalf of our readers, that Mark Vaessen agreed to share his views with us as there is nothing more valuable than a reassuring expert voice in periods of rapid change and uncertainty.
Editor’s note: ESG stands for Environmental, Social and Governance key performance indicators. The CFA Institute provides an effective overview of this concept here. Editor’s note: Tesla is a highly innovative car manufacturer which has introduced significant technological advancements in electric cars. See this newsletter issue 27 – May 2016 and issue 23 – May 2015 8 See issue 12 – June 2012 5 6 7
IFRS key considerations for closing out 2016 by Joelle Moughanni, RSM The time has come for our annual rendezvous to take stock of the latest developments in IFRS financial reporting requirements. This article provides a high-level overview of new and amended standards and interpretations that need to be considered for financial reporting periods ending on 31 December 2016, with the objective of highlighting key aspects of these changes.9
Pronouncements mandatory for the first time in closing out 2016 year-end accounts10 IFRS 14 – Regulatory Deferral Accounts This interim optional standard – pending the outcome of the IASB’s comprehensive project on rate-regulated activities – is applicable only by first-time adopters of IFRSs who apply IFRS 1 and conduct rate-regulated activities. Entities in the standard’s scope are permitted to continue to account, with some limited changes, for regulatory deferral accounts in accordance with their previous GAAP, both on initial adoption of IFRS and in subsequent financial statements. Amendments to IAS 1 – Disclosure initiative The amendments clarify guidance on materiality and aggregation, the presentation of subtotals, the structure of financial statements and the disclosure of accounting policies. Amendments to IAS 16 – Clarification of acceptable methods of depreciation The amendments – applicable prospectively – add guidance and clarify that the use of revenue-based methods to calculate the depreciation of an asset is not appropriate because revenue generated by an activity that includes the use of an asset generally reflects factors other than the consumption of the economic benefits embodied in the asset. Amendments to IAS 16 and IAS 41 – Agriculture: bearer plants The amendments define bearer plants as living plants which are used solely to grow produce over several periods and usually scrapped at the end of their productive lives (e.g. grape vines, rubber trees, oil palms), and include them within IAS 16’s scope while the produce growing on bearer plants remains within the scope of IAS 41. Amendment to IAS 19 – Discount rate: regional market issue Annual Improvements to IFRSs 2012–2014 Cycle The amendment clarifies that in determining the discount rate for post-employment benefit obligations, it is the currency that the liabilities are denominated in that is important, and not the country where they arise. Thus, the assessment of whether there is a deep market in high quality corporate bonds is based on corporate bonds in that currency (not corporate bonds in a particular country), and in the absence of a deep market in high quality corporate bonds in that currency, government bonds in the relevant currency should be used. Amendments to IAS 27 – Equity method in separate financial statements The amendments reinstate the equity method option allowing entities to use the equity method to account for investments in subsidiaries, joint ventures and associates in their separate financial statements.
This article reflects pronouncements issued up to 15 October 2016. When entities prepare financial statements for the year ending 31 December 2016, they should also consider and disclose the potential impact of the application of any new or amended standard or interpretation issued by the IASB before the financial statements are authorised for issue. Unless mentioned otherwise, all the new or amended pronouncements require retrospective application, sometimes with transitional provisions.
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Amendment to IAS 34 – Disclosure of information ‘elsewhere in the interim financial reporti Annual Improvements to IFRSs 2012–2014 Cycle The amendment clarifies what is meant by the reference in the standard to ‘information disclosed elsewhere in the interim financial report’, and requires a cross-reference from the interim financial statements to the location of that information. Amendments to IAS 38 – Clarification of acceptable methods of amortisation The amendments – applicable prospectively – add guidance and clarify that revenue is generally presumed to be an inappropriate basis for measuring the consumption of the economic benefits embodied in an intangible asset; however, this presumption can be rebutted in certain limited circumstances. Amendments to IFRS 5 – Changes in methods of disposal Annual Improvements to IFRSs 2012–2014 Cycle The amendments – applicable prospectively – add specific guidance when an entity reclassifies an asset (or a disposal group) from held for sale to held for distribution to owners, or vice versa, and for cases where held-for-distribution accounting is discontinued. Amendments to IFRS 7 – Servicing contracts Annual Improvements to IFRSs 2012–2014 Cycle The amendments add guidance to clarify whether a servicing contract is continuing involvement in a transferred asset. Amendments to IFRS 10, IFRS 12 and IAS 28 – Investment entities: applying the consolidation exception The amendments clarify the application of the consolidation exception for investment entities and their subsidiaries. Amendments to IFRS 11 – Accounting for acquisitions of interests in joint operations The amendments – applicable prospectively – require an acquirer of an interest in a joint operation in which the activity constitutes a business (as defined in IFRS 3) to apply all of the business combinations accounting principles and disclosures in IFRS 3 and other IFRSs, except for those principles that conflict with the guidance in IFRS 11. The amendments apply both to the initial acquisition of an interest in a joint operation, and the acquisition of an additional interest in a joint operation (in the latter case, previously held interests are not remeasured).
Pronouncements available for early application in closing out 2016 year-end accounts11 IFRS 9 – Financial Instruments This standard will replace IAS 39 (and all the previous versions of IFRS 9) effective for annual periods beginning on or after 1 January 2018. It contains requirements for the classification and measurement of financial assets and financial liabilities, impairment, hedge accounting and derecognition. IFRS 9 requires all recognised financial assets to be subsequently measured at amortised cost or fair value (through profit or loss or through other comprehensive income), depending on their classification by reference to the business model within which they are held and their contractual cash flow characteristics. Specifically, debt investments that are held within a business model whose objective is to collect the contractual cash flows and that have contractual cash flows that are solely payments of principal and interest on the principal outstanding are generally measured at amortised cost at the end of each accounting period. All other debt investments and equity investments are measured at their fair value at the end of each accounting period. For financial liabilities, the most significant effect of IFRS 9 relates to cases where the fair value option is applied: the amount of change in fair value of a financial liability designated as at fair value through profit or loss that is attributable to changes in the credit risk of that liability (the ‘own credit risk’) is recognised in other comprehensive income (with no subsequent reclassification to profit or loss), unless this creates an accounting mismatch. For the impairment of financial assets, IFRS 9 introduces an ‘expected credit loss’ model based on the concept of providing for expected losses at inception of a contract; it is no longer necessary for a credit event to have occurred before a credit loss is recognised. For hedge accounting, IFRS 9 introduces a substantial overhaul allowing financial statements to better reflect how risk management activities are undertaken when hedging financial and non-financial risk exposures. Key changes from the IAS 39 model include increased eligibility of hedged items and of hedging instruments, more flexibility in demonstrating a hedging relationship such as removal of quantitative thresholds for hedge effectiveness, and expanded disclosures. The derecognition provisions are carried over almost unchanged from IAS 39. IFRS 15 – Revenue from Contracts with Customers The new standard (amended in April 2016 for clarifications and additional transitional relief) – effective for annual periods beginning on or after 1 January 2018 – replaces IAS 11, IAS 18 and their interpretations. It establishes a single and comprehensive framework for revenue recognition to apply consistently across transactions, industries and capital markets, with a core principle (based on a five-step model to be applied to all contracts with customers), enhanced disclosures, and new or improved guidance (e.g. the point at which revenue is recognised, accounting for variable consideration, costs of fulfilling and obtaining a contract, etc.). IFRS 16 – Leases The new standard – effective for annual periods beginning on or after 1 January 2019 – replaces IAS 17 and its interpretations. The biggest change introduced is that almost all leases will be brought onto lessees’ balance sheets under a single model (except leases of less than 12 months and leases of low-value assets), eliminating the distinction between operating and finance leases. Lessor accounting, however, remains largely unchanged and the distinction between operating and finance leases is retained.
Unless mentioned otherwise, all the new or amended pronouncements require retrospective application, sometimes with transitional provisions.
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Amendments to IAS 7 – Disclosure initiative The amendments – applicable to annual periods beginning on or after 1 January 2017 – require entities to provide information that enable users of financial statements to evaluate changes in liabilities arising from their financing activities. Amendments to IAS 12 – Recognition of deferred tax assets for unrealised losses The amendments – applicable to annual periods beginning on or after 1 January 2017 – clarify the accounting for deferred tax assets related to unrealised losses on debt instruments measured at fair value, to address diversity in practice. Amendments to IFRS 2 – Classification and measurement of share-based payment transactions The amendments – applicable to annual periods beginning on or after 1 January 2018 – clarify the effects of vesting and non-vesting conditions on the measurement of cash-settled share-based payments (SBP), the accounting for SBP transactions with a net settlement feature for withholding tax obligations, and the effect of a modification to the terms and conditions of a SBP that changes the classification of the transaction from cash-settled to equity-settled. Amendments to IFRS 4 – Applying IFRS 9 Financial Instruments with IFRS 4 Insurance Contracts The amendments give all entities that issue insurance contracts the option to recognise in other comprehensive income, rather than profit or loss, the volatility that could arise when IFRS 9 is applied before implementing the replacement Insurance Contracts Standard for IFRS 4 that is under drafting by the Board. Also, entities whose activities are predominantly connected with insurance are given an optional temporary exemption from applying IFRS 9 (until 2021), thus continuing to apply IAS 39 instead. Amendments to IFRS 10 and IAS 28 - Sale or contribution of assets between an investor and its associate or joint venture The amendments address a current conflict between the two standards and clarify that any gain or loss should be recognised fully when the transaction involves a business, and partially if it involves assets that do not constitute a business. The effective date of the amendments, initially set for annual periods beginning on or after 1 January 2016, is now deferred indefinitely but earlier application is still permitted.
We focused on: … accounting for intragroup loans
What is the issue? Company XYZ granted an interest-free loan to its subsidiary ABC with no repayment terms, but XYZ does not intend to call for repayment of the loan for five years. As XYZ expects such loans to become common in the group, it intends to establish as a group accounting policy that such intragroup loans should be measured at face value and classified as current in both the lender’s and the borrower’s IFRS financial statements.
What is the proposed solution? We believe that interest-free intragroup loans with no repayment terms attached to them should not be systematically measured at face value and classified as current. Instead, each loan should be considered on its own with its specific facts, circumstances, terms and conditions. If XYZ can demand repayment at any time (i.e. a loan repayable on demand), then ABC should recognise the interest-free loan liability at its face value as a current liability. Since in the present case repayment is to occur, the question raised is actually twofold: (i) recognition and measurement of such loans in accordance with IAS 39, and (ii) presentation as current vs non-current in accordance with IAS 1 in the financial statements of each of the borrower and the lender. Classification as current / non-current does not drive measurement and vice versa. It is notable that there is potential asymmetry of treatment of loans receivable and loans payable that is inherent to the application of the requirements in IAS 39 and IAS 1. In the absence of documented repayment terms, it is appropriate for the lender to consider the intention to demand repayment and to estimate the expectation of settlement, whereas it would be inappropriate for the borrower to estimate the repayment terms. From the lender’s point of view, if collection of the amounts is expected in one year or less they are classified as current assets; if not, they are presented as noncurrent assets. If loans are payable on demand for the borrower and recoverable at call for the lender, they are current at face value.
In addition, it is possible for the estimated timing of cash flows to be different for the borrower and lender, which will have a consequential effect on the loan’s fair value on initial recognition. As XYZ does not intend to call for repayment of the loan for five years, its expectation is that the loan will not be settled within 12 months after the reporting date; thus, it is classified as a non-current asset in XYZ’s financial statements (this intention may change, and therefore classification should be considered at every reporting date). As ABC does not have the unconditional right to defer settlement for at least 12 months after the reporting date, the loan payable is considered payable on demand and is classified as a current liability in ABC’s financial statements. On initial recognition, both XYZ and ABC measure the loan at fair value. For ABC, this is the face value of the loan (fair value of an interest-free loan liability payable on demand is not less than its face value). The fair value of loans that have no specified repayment dates and that are not repayable on demand should reflect a market participant’s assumptions about the timing of the future cash flows. Thus, XYZ should estimate the timing of the future cash flows (i.e. after five years), and discount these cash flows to their present value using a market-related interest rate. The discount would be recognised as an additional investment in ABC (unless XYZ expects to receive goods or services from ABC on favourable terms, in which case it might be recognised as a prepayment). In conclusion: It is possible to have different classifications and measurements in the financial statements of the lender and the borrower, as a consequence of applying the requirements in IAS 1 and IAS 39 respectively. If the loan is payable / callable on demand, it should be presented as current and measured at face value (no discount). In most cases, the loan should be discounted based on a market rate with the initial resulting difference between fair value and face value recognised as additional investment / equity contribution or liability; the portion to be paid / recovered within 12 months after the reporting period (the amount of which might differ between borrower and lender) is to be presented in current, and the rest in non-current.
Global Contacts Americas
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Richard Stuart T +1 203 905 5027 E richard.stuart@rsmus.com
Chandra Sekaran T +965 2245 2680 E chandra.sekaran@rsm.com.kw
Europe
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Nicky Warburton T +44 1772 216000 E nicky.warburton@rsmuk.com
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Asia Pacific
RSM Global Executive Office – UK
Gary Stevenson T +852 2598 5123 E garystevenson@rsmhk.com
David Carlisle T +44 20 7601 1080 E david.carlisle@rsm.global
Editor Prof. Marco Mongiello ACA Deputy Head of School Executive Director MBA and MSc Programmes Surrey Business School T +44 01483 683995 E m.mongiello@surrey.ac.uk
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