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Ethics Case Study for ABC Incorporated and Questions

This case, involving ABC Incorporated, contains various ethical issues confronted by members in business
and industry. It has been written in dialogue and begins on the morning of April 10, 2015 at the company's
audit committee meeting. The company has recently restated their financial statements and has assigned a
special investigation committee to address the matter. The following individuals participated in the
transactions in question or are involved in the investigation of the matter.

• Lewis – Chairman of the Audit Committee • George- Chair of the Special Investigation Committee
George, 52, is a CPA and is the newly appointed Director of the Company’s Internal Audit Department.
Prior to joining the company, he spent 6 years as the Director of Internal Audit with a company in a different
industry after retiring as a partner with regional public accounting firm. • Daniel (Former CEO) Daniel, 46,
was the Chief Executive Officer ("CEO") of the Company from 2005 until his departure in February 2015.
He had been the CEO of a competitor for over 10 years. In addition, Daniel worked for 9 years in charge
of the internal audit department of a major retail chain. Daniel has a BBA in Accounting and an MBA in
Finance. • Jan (CFO) Jan, 39, joined the Company in 2000 and has held various financial accounting
positions. In 2013 she was promoted to the position of Chief Financial Officer. Her previous professional
experience includes two years as an accounting manager in a major public firm, and 9 years in public
accounting, achieving the level of manager before leaving. In 1997 she obtained her CPA license. She has
an undergraduate degree in accounting and is a member of the American Institute of Certified Public
Accountants. • Gary (Controller) Gary, 41, began his career with the company back in 2001. He has held
various positions with the Company and is currently in the position of Controller. Prior to joining, Gary
spent 4 years in public accounting providing tax and accounting services. He attended ABC College and
received a BA in accounting. In 1995 he became a CPA and a member of the American Institute of Certified
Public Accountants. • John (Accounting Manager) John, 32, is the ABC's accounting manager. He only
recently joined the company in 2012. Prior to joining the Company, he was with one of the company’s
largest competitors. John is a CPA with 7 years’ experience in public accounting. He received an
undergraduate degree in accounting and is a member of the American Institute of Certified Public
Accountants. • Melanie (Senior Accountant) Melanie, 26, was recently promoted to the position of senior
accountant. She has been with the Company for 2 years. Previously she was with our accounting firm and
worked on the team providing audit services to our Company. Melanie has recently received her CPA
certificate and has joined the American Institute of Certified Public Accountants.

The chairman of the special investigation committee George has begun to address the audit
committee:

THE MORNING OF APRIL 10, 2015 "Good morning. I would like to thank you for inviting me to speak
at the Audit Committee meeting today. As some of you already know, my name is George and I am
Chairman of the Special Investigation Committee assigned to assist ABC Incorporated with its internal
investigation surrounding the recent restatement of the company's financial statements. In addition, the
Securities and Exchange Commission has begun their investigation and my Committee will be acting as a
liaison. In light of these events, I have notified some of the accounting and financial personnel that were
associated with the transactions in question that I would like to meet with them over the course of the next
week. In the packages before you, I have included a short biography on each employee so that you may
gain an understanding of each individual's professional experience. I will report my findings to the
Committee after the meetings have concluded. Thank you."

THE AFTERNOON OF APRIL 18, 2015 In the late afternoon George and Lewis, Chairman of the Audit
Committee, began talking. "George, it has been eight days since you first spoke to the Audit Committee
and tomorrow your Special Investigation Committee is scheduled to report back to them regarding the
recent employee inquiries. Are there any important findings that I should know about before the meeting?"
"Well Lewis, why don't I just walk you through my last week of inquiries?" "I began with the staff and
worked my way up the organizational chart. My first conversation was held with Melanie. She was
previously part of our audit engagement team. We courted her away from our auditors two years ago. We
made a promise to her that the Company would pay for her masters’ degree. Melanie was just promoted to
a senior accountant position and works in accounts receivable. She reports directly to John, the accounting
manager. I began my inquiry with Melanie by asking just one question."

"Melanie, if you thought the journal entry was false, why did you agree to record it?" Melanie responded
that "John gave me the journal entry. He told me to record a sale to our major customer. It was for two
million dollars. I asked why we weren't recording this sale through the sales journal, and where the
documents supporting the transactions were located. He said that, based upon his conversation with Gary,
the Controller, documentation would arrive within the next several days. Company sales have really been
down this year and recording such a material transaction with our major customer would have a significant
impact on revenue. Well as you already know, we never received any support for the transaction. I knew
the auditors would question the sale as I used to audit this Company. They asked the same questions I would
have asked and wanted us to provide them with the original supporting documentation and inquired about
our ability to override the internal controls. George, what was I suppose to do? Not record the transaction?
John told me to record it, and he's the Accounting Manager." I asked Melanie, “If you were uncomfortable
talking to John, why didn’t you speak to Gary, Jan or to the external auditors?” Melanie explained to me
that she didn't voice her concerns to anyone because she was afraid of losing her job and that she didn't
want to approach John's superior and cause any additional waves since John just gave her a promotion. She
also explained that the auditors were asking a lot of questions, but when they approached her, she told them
that they needed to speak to her boss, John. "Lewis, after my conversation with Melanie, I called John in to
speak with him. I wanted to know why he would direct Melanie to record the sales transaction."
"John, as you are aware, we have restated the Company's most recent financial statements. The Securities
and Exchange Commission is currently investigating all items associated with the restatement, the existence
of specific sales transactions and challenging our revenue recognition policies. One transaction under
investigation is the recording of a material sale made to our major customer. The Company is now aware
that it was a fictitious transaction and that you had requested your staff, Melanie, to record it."

"George, that sale to our major customer was recorded based upon my conversation with my superior Gary.
It all occurred on December 27th, the day I came back from vacation. Gary told me that he had received a
call from Daniel, now our former CEO and that Daniel had just gotten off the telephone with Susan. She is
the head of the Purchasing Department at our major customer. Gary said that Daniel told him that Susan's
company was in desperate need of our products. They wanted to know if we could accept a verbal request
for a two million dollar purchase and indicated that formal written documentation would be provided within
a few days. Additionally, the customer asked Daniel to hold the products being purchased in our warehouse
until they were ready to receive shipment. Daniel said that he and Susan had known each other for quite
some time, and that he could accept her word. Daniel said that he would authorize the verbal transaction.
Gary also said that Daniel appeared worried because the Company had been receiving a lot of pressure from
Wall Street to hit the projected numbers. Daniel thought that if we waited to receive the required
documentation from our major customer the sale might not be recorded until after year-end. If that
happened, Company earnings would be down, stock prices would be adversely impacted, and bonuses
would be substantially less because they are calculated as a percentage of net income. George, I have been
with ABC for less than a year and I didn't want to question the authority of any of my superiors, so I directed
one of my staff, Melanie, to make the entry."

"John, I know you are new to the Company, but when you finally realized that the transaction was false,
why didn't you correct it? You have the authority to correct entries in the system. The sale was so materially
false and misleading to the Company's books and records."

"George, I am not in the decision-making role for which I thought I was hired. When I finally discovered
that the transaction was false, I knew that if I corrected the entry, my correction would have been reversed."

"Lewis, at this point I called the controller, Gary, in to be interviewed."

"Gary, we were just discussing that material year-end sale to our major customer. As you are already aware,
it was false and subsequently reversed along with other transactions."

"Why did you direct John's department to record the false transaction?".

"George, initially, I was not sure if the transaction was false, but I did request that John's department record
it. The transaction had never been properly recorded through our system, and we were told to override the
internal controls. Subsequently we never received the promised supporting documentation and I became
concerned. I voiced my concern to the CFO, Jan. Jan said that she had been apprised of the major customer
transaction, but that she did not need to hear the details. “We need to meet our market expectations,” she
said. In any event, false or not, I knew this was exactly what upper management wanted and I didn't want
to have to deal with the ramifications if earnings were not met. Having a negative impact on bonuses could
cost me my job. You cannot imagine the type of pressure that has been placed on our department."
"Thank you both for speaking so candidly with me. There have also been inquiries from the SEC regarding
our revenue recognition policies on certain contracts, including a Telecommunications contract. Do either
of you have any direct knowledge or participation in the recording of revenue involving the
Telecommunications contract?"

"No, George. I recall Daniel, our former CEO, negotiating the terms in the contract. John and I had heard
from Jan that he was taking a very active role in the contract negotiations because the deal was unusually
large."

"Well, Daniel is no longer with the company, so perhaps I should make my additional inquiries with Jan.
Again I would like to thank both of you for providing valuable insight into the various transactions in
question. I may be contacting you if additional clarification is needed. On your way out, could you please
ask Jan to join me?"

"Hello Jan. I would like to discuss some of the transactions that have been restated in the company's
financial statements, in addition to the SEC investigation. Let us focus on two specific transactions, the
year-end major customer sale and the Telecommunications contract. I believe your testimony to the SEC
indicated that you are familiar with both."

"Yes George, I am."

"Jan, based upon my reading of the Telecommunications contract, it appeared that ABC was to provide a
series of services to them over the course of the next 5 years. Let me simply start out with the question of
who exactly made the determination to recognize revenue immediately when this contract clearly contained
various multi-element arrangements with varying deliverables?"

"George, the decision to recognize revenue up front was made by Daniel. He said that he specifically
reviewed the contract and that all criteria for revenue recognition had been met. Daniel has always been
very technical, but I decided to do some research on my own. Based upon my review of the applicable
accounting literature, the contract did contain arrangements with multiple components that should have
been evaluated separately for revenue recognition purposes. My final assessment was that the recognition
of revenue was being accelerated. Daniel is the CEO and it was his call. I did not feel the need to address it
any further."

"Jan, please tell me about the year-end major customer sale. Your deposition stated that you knew it was
false. Why didn't you correct the transaction?"

"How could I? Daniel authorized the transaction and he was the CEO and my boss. I thought I would
approach him after the year-end audit was over and request that we reverse the transaction in the current
year."

"Jan, why did you sign the representation letter dated February 25, 2015 to our auditors? You knew the
financial statements were materially misstated because of these two transactions. Additionally, you must
have also realized that you had misled them into believing that we were in compliance with our loan
covenants?"
"George, we were in compliance. I gave the auditors our loan covenant calculations. It was exactly what
they asked for and I believe that it was their job to test the validity of the numbers."

"Please Jan. We were only in compliance because of the materially false major customer sale and the
premature recognition of revenue for the Telecommunications contract. The company only appeared to be
in compliance. If the transactions were reversed, and they subsequently were, we were not in compliance."

"George, I would like to ask a question?"

"Certainly Jan."

"Doesn't the former CEO, Daniel, have any professional responsibility in this? He told me to sign the
representation letter and he had direct knowledge of the false material transactions as well as the
noncompliance with loan covenants."

"Yes, he does have professional responsibility in this matter, as do you. He directed you to sign a document
with knowledge of the false material transactions. He never brought these items to the attention of the audit
committee, but then again, neither did anyone in the department. In addition, ABC is a public company.
We have regulatory requirements with the SEC. They were never contacted."

"George, I know I have a professional responsibility in all of this. Right now, I believe there really isn't
anything else I can add." "and with that, Lewis, Jan left...and in quite a hurry I might add. I think tomorrow's
meeting is going to be a long one."

THE MORNING OF APRIL 19, 2015 – AUDIT COMMITTEE MEETING On the morning of April 19th
after receiving a verbal report from George concerning his discussions with staff, the Audit Committee
went into executive session to discuss the findings. Following this discussion, Lewis prepared a list of 16
points in the form of questions and answers that he disseminated to the Audit Committee for their review
and approval.

Komite Audit dengan suara bulat menyetujui ringkasan Lewis dan menjadwalkan pertemuan terpisah untuk
mempertimbangkan tindakan disipliner yang akan mereka ambil terhadap masing-masing staf. Berikut ini
adalah ringkasan yang Lewis siapkan:

1. Apakah George, Jan, Gary, John dan Melanie menyediakan layanan profesional untuk ABC
Incorporated?
2. Akankah Melanie melanggar Kode karena dengan sengaja memposting entri jurnal palsu secara
nyata meskipun dia diarahkan oleh atasannya untuk mencatat entri tersebut?
3. Langkah apa yang harus diambil Melanie ketika dia tidak setuju dengan atasannya, John, mengenai
posting jurnal palsu yang masuk ke laporan keuangan?
4. Apakah Daniel akan melanggar Kode karena dia hanya mengarahkan atau mengizinkan stafnya
untuk mencatat entri yang dia tahu salah secara materi?
 5. Apakah Gary dan John melanggar Kode karena mereka memiliki wewenang untuk memperbaiki
entri palsu yang salah dan menjaga agar laporan keuangan dan catatan tidak menyesatkan?
6. Apakah Jan akan melanggar Kode karena dia menandatangani dokumen yang mengandung
informasi palsu atau menyesatkan secara materi?

Jawab :

1. Benar, George, Jan, Gary, John dan Melanie menyediakan layanan professional untuk ABC
Incorporate. George menggunakan penunjukan CPA pada kartu nama dan kop suratnya. Melanie,
John, Jan dan Gary sebelumnya memberi tahu George bahwa mereka adalah CPA. Representasi
lisan atau tertulis kepada individu lain mengenai status mereka sebagai CPA dianggap sebagai
tindakan memberi tahu orang lain tentang penunjukan. Untuk keperluan Kode Perilaku Profesional
AICPA, Melanie, John, Jan dan Gary mewakili diri mereka sebagai CPA dan karenanya dianggap
berkinerja professional jasa.
2. Iya, Melanie melanggar kode tetapi karena dia sadar mencatat jurnal entri yang salah ke buku-buku
dan history keuangan catatan ABC Incorporated dan memberitahukan bahwa yang dilakukan salah
karena melanggar penilaiannya unggul yang ada padanya dalam kemungkinan pelanggaran
• Aturan Integritas dan Objektivitas (AICPA, Standar Profesional, ET) sebagai didukung
oleh
➢ paragraf .01a dari “Mengetahui Kesalahan Representasi dalam Persiapan Keuangan
Interpretasi Pernyataan atau Catatan (AICPA, Standar Profesional, ET)
➢ "Kewajiban Anggota untuk Akuntan Eksternal Majikannya"interpretasi (AICPA,
Standar Profesional, ET)
➢ interpretasi "Subordinasi Putusan" (AICPA, Standar Profesional, ET).
• Aturan Standar Umum (AICPA, Standar Profesional, ET) item b dan d)
• Aturan Prinsip Akuntansi (AICPA, Standar Profesional, ET)
• Undang-undang yang Dapat Didiskreditkan (AICPA, Standar Profesional, ET)
sebagaimana didukung oleh interpretasi "Kelalaian dalam Penyusunan Laporan Keuangan
atau Catatan" (AICPA, Standar Profesional, ET)
3. Melanie seharusnya tidak memposting jurnal entri dan seharusnya tidak menempatkan
penilaiannya di bawah. Sebagai gantinya, harus mempertimbangkan dampak dari jurnal entri
terhadap catatan keuangan dan apakah laporan keuangan dan catatan dapat salah saji secara
material dengan memposting jurnal entri tersebut. Jika dia ditentukan bahwa mungkin ada salah
saji material, dia seharusnya membawanya masalah kepada atasannya dan jika tidak diselesaikan
ke tingkat manajemen yang lebih tinggi (untuk misalnya, pengontrol, CFO, dan / atau komite audit).
 Seharusnya diskusi atau pun didokumentasikan dan dirangkum dengan pemahamannya tentang
fakta, prinsip akuntansi terlibat, penerapan prinsip-prinsip akuntansi tersebut serta pihak-pihak
yang terkait dengan hal tersebut untuk dibahas. Jika setelah mendiskusikan keprihatinannya dengan
manajemen, ia menyimpulkan itu tepat tindakan tidak diambil, Melanie seharusnya
mempertimbangkan perlindungan apa yang bisa dilaksanakan bahwa dia dengan tidak
mengesampingkan penilaiannya. Jika Melanie menyimpulkan bahwa tidak ada perlindungan yang
bisa dihilangkan atau mengurangi ancaman ke tingkat yang dapat diterima atau menyimpulkan
bahwa tindakan yang tepat tidak diambil, dia seharusnya mempertimbangkan untuk menghentikan
hubungannya dengan Perusahaan dan seharusnya mengevaluasi tanggung jawabnya untuk
memberi tahu auditor eksternal dan badan pengawas oleh berkonsultasi dengan penasihat
hukumnya.
4. Jika Daniel adalah seorang CPA dan anggota AICPA dan / atau masyarakat negara bagian yang
berpartisipasi, Daniel akan melakukannya tunduk pada ketentuan Kode Etik dan mungkin
melanggar Integritas dan Objektivitas, Prinsip dan Aturan Akuntansi Aturan yang dapat
didiskreditkan meskipun dia baru saja mengarahkan dan mengizinkannya staf untuk mencatat entri
yang salah secara materiil dan menyesatkan dalam catatan perusahaan.
5. Iya. Gary dan John memiliki tanggung jawab profesional untuk mengoreksi kesalahan materiil dan
menyesatkan jurnal entri. Mereka dengan sadar memutuskan untuk tidak memperbaiki entri
sementara memiliki wewenang untuk melakukannya. Keduanya kemungkinan melanggar Pedoman
Perilaku Profesional. Selain tanggung jawab mereka untuk membalikkan transaksi, mereka juga
memiliki tanggung jawab profesional sebagai karyawan untuk bersiap laporan keuangan sesuai
dengan GAAP dan mempertimbangkan untuk menginformasikan kepada komite audit, badan
pengatur, dan akuntan eksternal majikan mereka. Dalam keadaan yang berbeda, jika manajemen
atas tidak memiliki keterlibatan langsung dalam transaksi palsu, mereka seharusnya juga telah
diinformasikan. Selain itu, Peraturan juga melarang anggota mengizinkan staf mereka untuk
merekam jurnal entri material yang salah dan menyesatkan dalam catatan perusahaan.
6. Iya. Jan dengan sadar menandatangani dokumen yang salah mengartikan fakta kepada auditor
perusahaan. Di bawah Kode Perilaku Profesional, seorang anggota harus jujur dan dilarang dengan
sengaja salah mengartikan atau gagal mengungkapkan fakta material kepada auditor perusahaan.
Dia juga memiliki tanggung jawab, sebagai karyawan, untuk menyiapkan laporan keuangan sesuai
dengan GAAP dan mempertimbangkan untuk menginformasikan kepada komite audit, akuntan
eksternal perusahaan, dan badan pengatur.

Sumber : American Institute of CPAs Case Study, NC 27707-8110