Change Management-Management Skills Development Project Health Informatics Sunil Nair

B U S I 6 3 2 6 H I N F 6 3 1 0

MANAGEMENT CHALLENGE HUMAN AND CULTURAL FACTORS AFFECTING

SUCCESS OF MERGER AND ACQUISITION

R O D N I E A L L I S O N S U N I L N A I R

M A L L O R Y C R A I G M I L E J E N N A K A Y E

S E A N - P A T R I C K M A L O N E B R I A N N A O R R

3/11/2009

BUSI 6326 / HINF 6310 – PROJECT REPORT

PROBLEM STATEMENT HUMAN AND CULTURAL FACTORS AFFECTING THE SUCCESS OF MERGER &

ACQUISITION: THE CHALLENGES FACED BY MANAGEMENT.

INTRODUCTION

In times of globalization and economic turbulence, mergers and acquisitions (M&A) are seen as strategic

opportunities by which organizations ensure consolidation and growth (Diefenbach 2007). A 2006 M&A research

indicated that in the year 2004 there were more than 30,000 acquisitions in the world market worth a total of 1.9

trillion dollars (Cartwright and Schoenberg 2006). Contrastingly, studies have proven that most M&A’s do not meet

the expected goals and objectives (Pautler 2003). Booz-Allen & Hamilton report (2001) pointed out that more than

53% of M&A fail to reach the desired outcome (Adolph et al. 2001). Even though past experiences evidently suggest

the high chance of failure, organizations are forced to merge and integrate in order to cut costs and stay competitive

(Bligh 2007).

According to the federal trade commission review (2003), the main factors that influence success of M&A are (Pautler

2003):

• maintaining focus during the union;

• size of merging organizations;

• speed of integration;

• planning and leadership during change;

• managerial incentives;

• management of organizational cultural conflicts; and

• to preserve human and technical resources.

It is interesting to note that other than early planning, efficient management of human and cultural factors are most

critical in determining the success of post-merger integration. The role of cultural change and managerial actions as an

important component in post-merger integration has been well documented (Zuveva and Ghauri 2007). During

M&A, two or more organizational cultures come together thereby presenting a tough integration process. One of the

major challenges in executing a successful value added M&A strategy is to have a clear understanding of the

management style and culture of the merging organizations. Problems could also arise when the acquirer imposes an

unsuitable organizational design on the newly formed company. The communication skills, competence and credibility

of senior and middle management have a direct impact on the success or failure of the newly formed association. The

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events that follow M&A are perceived as very “stressful” by most employees and managers (Bligh 2006). The

managing leader of the new outfit, in addition to company culture clashes, has to deal with the low morale of the

employees due to change resistance and downsizing fears. The managing leader must not only tackle his or her own

reactions to change as an employee but also be accountable for the performance of the team. Zueva & Ghauri (2007),

state that managers’ actions have a direct correlation with “acceptance or rejection of cultural change.” Lack of proper

leadership at this time could lead to “reduced trust, commitment, satisfaction, and productivity, and increased

absenteeism, turnover, and attitudinal problems.”

Keywords: Merger & Acquisition, Change Management, Change leadership, Organizational Change, Organizational Culture, Change

process.

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CASE SUMMARY OF REAL WORKPLACE SITUATION

MANULIFE FINANCIAL AND JOHN HANCOCK ACQUISITION1: A CASE AT MARITIME LIFE,

HALIFAX

Maritime Life, Halifax based Atlantic Canadian Insurance Company, was a Canadian subsidiary of John Hancock

Financial Services, a major U.S Insurance Company. The company was formed in 1922 by group of families in Nova

Scotia. Within a decade, Maritime Life grew tremendously to become the top Insurance Company in Canada. For five

consecutive years after 2000, the company was rated by its employees and the market watchers as the one of the “top

50 best companies to work for”.

The Manufacturer’s Life Insurance Company is the largest financial institution in Canada. Also known as Manulife

Financial, the company is very strong and has major national and international presence. The company has a long

history of strategic Mergers and Acquisitions and uses this tactic to consolidate growth and innovation.

In 2003, Manulife Financial acquired John Hancock Financial Services. This was during a period of consolidation in

the financial services industry resulting in more mergers between insurance companies. The merger was completed in

2004 making the newly formed franchise the largest insurance company in Canada and the fifth largest in the world.

When the Maritime Life parent company was acquired by Manulife Financial, an average Maritime Life employee

would have had tenure of more than 10 years with the company and frequently had more than one family member

working within the company. This resulted in an “extended family” atmosphere at Maritime Life and a great cohesive

culture that was laid back and employee focused.

As was expected, the merger resulted in some downsizing at Maritime Life. Major cultural changes followed resulting

in change and integration related casualties in the recently formed association. Numerous senior and middle

management staff were moved around in the newly transformed Maritime Life. Some were given the option of

voluntary retirement. The Human resources department was entirely shut down at the Halifax headquarters of former

Maritime Life except for a few coordinators. New Managers were either transferred in or hired for the vacant

positions mostly from Toronto.

1 http://www1.manulife.com/corporate/corporate2.nsf/Public/maritimeHistory.html

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http://www1.manulife.com/corporate/corporate2.nsf/Public/maritimeHistory.html


In our specific case, the department XYZ had a new manager transferred in from Toronto whose leadership style

drastically differed from the predecessor who had opted for voluntary retirement.

Additionally, the employees had to undergo training in the new system implemented at Manulife financial.

Furthermore, the old maritime life employees were anxious and under enormous stress due to lack of appropriate

communication from both the HR department in Toronto and the local management in Halifax. The result was

major discontent and dissatisfaction among the employees leading to an unproductive work environment and

subsequently poor performance from the team.

Lesson learned: Change management and planning coupled with efficient change leadership skills are critical factors effecting successful

post-merger integration.

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SUMMARY OF CRITICAL FIVE ACADEMIC ARTICLES

As stated in the introduction, the last thirty years have provided researchers and behavioural scientists with literally

thousands of M&A case studies to explore. Below are five academic pieces that, in our opinion, best expose the

challenges that await merging organizations.

Mergers and Acquisitions in the Banking Industry: The Human Factor

By Arturo Rodriguez

Rodriguez’s article explores employee motivations at both the functional and managerial levels following an

acquisition. He develops a list of probable reactions that are commonly displayed after an acquisition. They are; loss of

identity, lack of information and anxiety, survival becoming an obsession, loss of talent and family repercussions. He

then goes on to examine the cultural “fit” of the two organizations, and how it can be used to forecast the aftermath

of an acquisition as well as employee reactions. Rodriguez gathered data through a series of multi-level employee

interviews within both the company being acquired, and the purchasing company. In this particular instance, the

purchasing company had prior experience with acquisitions and had developed (through trial and error) a sense of

how to handle new employees in a changing environment. The author derived the following theory from his

experience at the company(s):

During the pre-acquisition phase of an impending purchase of a Bank, the lower the levels of communication from

upper management to the rank and file, the higher the possibility of employees experiencing high levels of stress and

anxiety that may result in attrition, sabotage and alienation.

Rodriguez focused on communication and information as the two most critical issues that CEOs need to be aware of

in order for the merger to be successful.

The Impact of Leadership and Change Management Strategy on Organizational Culture and Individual

Acceptance of Change during a Merger

By: Marie H. Kavanagh and Neal M. Ashkanasy

Kavanagh and Ashkanasy’s article is based on a study that examined the mergers of three large multi-site public-sector

organizations. The purpose of the analysis was to determine to what degree leadership and change management

strategies affect the acceptance of cultural change by individuals after a merger. It was determined that the success of

a merger depends on the individual perceptions within the organization as to how the process is handled and the new

culture that forms. Kavanagh and Ashkanasy’s study involved three large universities that merged with other smaller

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colleges. These three schools were selected because of their similarities in location, number of merging partners and

the differences between the large school and the smaller merged colleges. This includes the size of the school,

orientation, the length of existence and the approach taken in the merger. The quantitative portion was conducted

across all three schools over six years through a process of surveys.

The results indicate that effective organizational change can be achieved by focusing on the following four areas of

organizational life:

1) “The behaviour of institutional leaders”

2) “The selection and execution of appropriate management strategies (particularly change management

strategies)”

3) “An understanding of the organization’s basic structure, systems and formal processes (culture)”

4) “Actions taken by leaders affecting acceptance of change by individuals who play key roles in both formal and

informal systems”

Making mergers and acquisitions work: What we know and don’t know

By Richard M. DiGeorgio

DiGeorgio, like Rodriguez above, explored the cultural “fit” existing between the two merging organizations. He

suggests that the best combinations do not occur when there is no culture clash, but instead when there is a fair

amount of culture clash. This medium degree of conflict creates positive dialogue in regards to what is best for the

combined organization. DiGeorgio suggests that culture change within the merged organization can take between

seven and ten years, but in the case of an M&A, the time frame can be significantly reduced. For example, by selecting

managers whose styles and beliefs are congruent with the new culture, the direction of the new culture can be

reinforced and strong messages can be sent about the new status quo. DiGeorgio points to the integral role that the

integration managers play in the amalgamation of the two cultures. This is a difficult task and requires a host of traits.

Integration manger competencies include: self-confidence, adaptability, achievement drive, optimism, political

awareness, influence, communication, conflict management, change management, and team capabilities. Top

leadership plays an important role in overseeing integration. They must bring the whole system together periodically

to ensure that individual pieces are fitting together well. DiGeorgio suggests that areas of interdependence and

conflict must be identified quickly. The first 100 days after a major change sets the tone and signals the true direction

of the new organization. The overall direction and plan to get there should be determined and the values and

performance evaluations should be established. Additionally, a 100 day plan covering diverse topics such as

infrastructure needs and key decisions to be made should be drafted and used to evaluate progress through this critical period.

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DiGeorgio makes it clear that a systematic attitude to both selection and integration can insure a successful M&A. A

good plan must be acted upon by top executives swiftly and logically. The right managers who have the right traits

and fit well with the culture should be put in leadership roles.

Uncertainty during Organizational Change: Managing Perceptions through Communication

By James Allen, Nerina L. Jimmieson, Prashant Bordia & Bernd E. Irmer

Allen, Jimmieson and Irmer’s study is an extensive exploration of factors that influence employee attitudes and

intentions towards change in an M&A environment. They specifically focused on the importance of the following: 1)

The Notion of Uncertainty, 2) Change Communication, and 3) The Role of Trust During Organizational Change.

1) The Notion of Uncertainty

• During organizational change, employees are likely to experience uncertainty in relation to a range of

different organizational issues including: the rationale behind the change, the process of

implementation, the expected outcomes of the change, the security of their position, and their future

roles and responsibilities.

• The degree to which specific informational needs are addressed through communication during

organizational change is critical.

2) Change Communication

• It is the perceived quality of the information that influences employees’ appraisal of change. Change

communication can facilitate openness and positive attitudes towards change to the extent that it

effectively addresses employee uncertainty.

3) The Role of Trust during Org Change

• Management practices that facilitate participative decision-making, organizational support and the

meeting of expectations have shown to influence employees’ perceptions of trust.

• Employees who trust management or their organization may be more willing to be vulnerable to the

actions of management (i.e. lack of trust leads to employees’ being critical of info received).

Allen, Jimmieson and Irmer’s study has several practical recommendations. First, management leadership must

recognize areas of uncertainty which employees are likely to experience. Then develop a targeted communication

strategy designed to facilitate employee acceptance of change. These open and readily available lines of

communication will act to decrease organizational friction during the change. Second, a cascading approach to

communication strategies can be beneficial in aiding the systematic transfer of information from various levels within

the organization (i.e. senior management provide more strategic information, while supervisors provide more practical

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information, etc). Finally, participative communication strategies (using supervisors as facilitators) can help establish

two-way-communication between employees and managers. This participative strategy furthers trust within the

organization and increases the chances for success in any future change intra-merger or post-merger event.

HR Issues and Activities in Mergers and Acquisitions

By Susan Jackson and Randall Schuler

Jackson and Schuler suggest that while some companies are skilled when it comes to negotiating M&A deals, the

ability to successfully integrate businesses after an M&A still requires improvement. Success in the market place

requires companies to be efficient, profitable, flexible, and future-focused, which leads many to look to M&A in order

to remain competitive. However, the likelihood of a successful M&A is low. This is not to say that success is

impossible, but in order to achieve greatness, companies must follow a systematic and people-focused approach that

addresses the key issues and activities broken out in a three-stage model.

1) Pre-Combination Stage first requires companies to identify why an M&A strategy is best for the company. A

team and leader must be selected to manage the M&A planning process and selection of M&A partner. This

ensures the company has a sufficient understanding and knowledge of the M&A, which leads to success.

2) Combination Stage occurs when the M&A companies began the integration process. First an integration

manager (often a person on loan to the business for a defined period of time) should be selected along with

an integration team. Together their main goal is to provide continuity between the integrating companies.

This is also the stage where key employees are retained and the process to establish a new culture is initiated.

Additionally, a leader is selected at this point to manage the newly merged businesses. The leadership style

should be strong to ensure appropriate communication and direction is maintained.

3) Solidification and Assessment of the New Entity is the finally stage of an M&A whereby the new company readjusts,

fine-tunes and solidifies its strategies, structures, and new culture.

Overall, Jackson and Schuler focused on clarity of the M&A process and communication throughout the M&A stages

as a prime directive for a successful integration. This communication includes incorporating an adequate

representation of teams and departments in decision making throughout the M&A stages. It is important to set

realistic expectations and goals throughout the M&A process and continuously measure whether they have been

achieved. Lastly, it is necessary for cultural differences to be tended to immediately because if left, they can lead to

miscommunication and misunderstanding.

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APPLICATION

A number of relevant points from the critical five articles are pertinent to the case analysis at hand. Common themes

include: understanding culture, understanding uncertainty about change, communicating the change, selecting the

right managers, and seizing the M&A as an opportunity for change. These concepts will be elaborated in the following

analysis of the case.

Case Issue #1 – Out With the Old (Manager) And In With The New (Manager)

The first problem identified in the case was the early retirement of the incumbent manager and the subsequent

transfer of the manager from Toronto. The new manager had a drastically different leadership style compared to that

of his predecessor which caused problems with Maritime Life employees who were used to a more “extended family”

atmosphere. The new manager from Toronto clearly did not fit in well with the existing culture at Maritime Life.

Furthermore, the employees were no doubt feeling abandoned by their former boss who chose to take early

retirement rather than deal with changes involved in the M&A. This action sent a negative message to the employees

and started them out on the wrong foot with the new manager.

The literature emphasizes the importance of understanding culture and the uncertainty that employees undoubtedly

feel during an M&A. In an effective M&A, it is vitally important to understand the combining organization’s cultures

(Kavanagh & Ashkanasy, 2006). It is apparent that Manulife did not fully understand Maritime Life’s culture in the

form of its basic structure, systems, and formal processes.

Rodriguez (2008) reports that the probable reactions following an M&A are loss of identity, lack of information,

anxiety, survival becoming an obsession, loss of talent, and family repercussions. After the retirement of their boss

during the transition period and the transfer of the new manager from Toronto, the employees at Maritime Life felt as

if they had lost their identity and felt anxiety about the situation. They did not appreciate the new culture that was

being forced upon them and became unsatisfied in the workplace resulting in underperformance. Rodriguez (2008)

advises that in order to create a positive environment for the M&A, the focus should be on communication and

information.

DiGeorgio (2003) suggests that the best M&As take place between two companies with a fair amount of culture clash

which encourages positive debate as to what is best for the new company. Too little or too much clash between the

company’s cultures can result in negative outcomes. In this case, the difference in culture between Maritime Life and

Manulife appears to be large. In order to overcome such a large difference in cultures the proper selection of an

integration manager is necessary (DiGeorgio, 2003; Kavanagh & Ashkanasy, 2006; Schuler & Jackson, 2001).

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An integration manager is a manager whose skill set is specifically suited for an M&A situation. The integration

manager must be supremely aware of their environment and understand the cultures of both combining organizations.

Specific competencies include: self-confidence, adaptability, achievement drive, optimism, political awareness,

influence, communication, conflict management, change management, and team capabilities (DiGeorgio, 2003). The

new manager from Toronto is not an integration manager as he did not adapt well to the situation. Instead of

cramming his style of management down his new subordinate’s throats, he should have instead analyzed his new

environment and changed his management style to suit it. The transfer of this manager to Maritime Life was a definite

error. During an M&A, there are a lot of changes and organizations must seize this opportunity to make smart

decisions that will propel the new combined companies forward. Thus, the selection of an appropriate integration

manager is paramount.

Case Issue # 1 Recommendations

• Manulife must truly understand the culture of Maritime Life in order to succeed. Without this crucial step the

M&A will not be successful. To do this, Manulife must spend time with Maritime Life employees at all levels in

their place of work. Before moving forward with any restructuring or hiring, they must understand the “extended

family” feeling that is a part of being an employee at Maritime Life.

• Communicate the change clearly and often. More communication and information sharing results in a deeper

understanding about what exactly is happening during the M&A. Multiple avenues of communication should be

used by the manager including group meetings, one-on-one discussions, and e-mails. The benefits of the M&A to

the company and its employees must be conveyed so that employees will work toward success instead of

accepting failure before even beginning.

• Manulife should hire a new manager to head the XYZ team at Maritime Life. This manager should have the

characteristics of an integration manager and can come from within one of the two companies or from outside.

The period of change and transition must be taken advantage of to bring in appropriate managers who can lead

the company to success.

Case Issue #2 – New Information System Implementation

The second problem identified in the case was the lack of acceptance of the new information system implemented by

Manulife. The employees at Maritime Life were used to their old information system and were already in a defensive

and unreceptive position after the transfer of their new boss from Toronto. This change to a new information system

affected how they carried out their day-to-day tasks and was perceived to be forced upon them.

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If employees do not know why a change is happening, they will experience high levels of stress and anxiety which may

result in attrition, sabotage, and alienation (Rodriguez, 2008). In the case, Maritime Life employees display signs of

stress and anxiety with respect to the new information system. They resisted this change because they did not

understand the reasoning behind the change. Even though the employees were given training, they resisted the change

because they did not understand, nor did they want to change. The more communication from upper management to

subordinates about changes, the higher the level of acceptance for these changes.

The M&A is a great opportunity to change. The first 100 days are very important and if a sense of urgency is created

in an organized fashion, it can be very effective (DiGeorgio, 2003). If employees are on board, the new information

system can be introduced as an integral part to the success of the newly combined organization. Creating this push to

get the information system up to date and uniform across the organization will encourage employees to embrace the

change and the new technology because there is a reason for the change and a defined timeframe.


• Higher levels of communication from upper management to Maritime Life staff. As staff learn more about the

benefits of the new information system, they will be more comfortable with the change. Communications should

come in a variety of formats and should encourage feedback.

• After effective communication is achieved, a sense of urgency should be created to encourage employees to

accept the change and the new information system. To do this, the manager must communicate the key benefits

that a swift change will have to both the company and the employees.

Case Issue #3 – Downsizing With Poor Communication

The third case issue identified was the downsizing, reshuffling and retirement that occurred at Maritime Life as a

result of the merger. While these changes are quite common and necessary during an M&A in order for the newly

formed organization to be streamlined and efficient, the downsizing process must be coupled with adequate

communication to employees explaining the new corporate structure and the justification behind the changes. As

mentioned in the second case, a lack of communication about the change will result in employee stress and anxiety

(Rodriguez, 2008).

In this case, employees may not feel safe in terms of their own job security and may draw back from the organization

culture. The added stress and anxiety they feel could lead to an increase in employee absenteeism and could decrease

the productivity of department XYZ. Too often, managers focus their attention during M&A on activities such as

finance, accounting, and production while they overlook the human capital issues within the company (Jackson &

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Schuler, 2001). We can assume that the employees remaining at Maritime Life add some value to the newly merged

company or else they would have been part of the downsizing that occurred. If Manulife is not careful, they might

lose the employee talent that exists at Maritime Life and these employees are a vital component of the newly merged

organization.

The uncertainty that employees in department XYZ feel due to the lack of communication about downsizing and

other role changes within the company leads to their distrust of management. Trust is an important factor within

M&A companies because there are many changes that are implemented during integration and it is necessary for the

employees to be both knowledgeable and supportive of the new company structure, system and culture (Allen, et all.,

2007). Downsizing and reshuffling is one of the first changes when two companies are integrating, therefore, this may

be management’s first opportunity to either gain the trust of the employees or start to lose their trust. While

downsizing is not pleasant for either company, it is a necessary component of the M&A process.


• Before the downsizing, reshuffling and retirement of employees began at Maritime Life; management should have

held a company-wide meeting to explain the new direction of the company. The purpose of this meeting is to

communicate the changes before they happen and to gain the trust of the employees rather than simply

blindsiding them with major changes.

• After the downsizing and reshuffling has been completed, a second company-wide meeting should be held to

explain the next stages of the integration process. At this meeting, it is necessary for management to overcome

the negativity some employees may feel after seeing their friend, or in the case of Maritime Life – their family

member, let go or moved to a different department. Management should reassure the remaining employees that

they are a vital component of the newly merged company, which should help employees regain their job security.

Specific examples of how the company will move forward and the benefits employees will notice as a merged

organization are important to point out at this time. Management could replace some of the negativity with

excitement for the future of the company and the role each employee will play in the company’s success.

• Separate department meetings should be held with the newly formed team of employees to discuss department-

specific roles in the organizational change that is occurring. Again, this will give management the opportunity to

gain employee trust by approaching them in a smaller group setting. Management should also take employee

feedback at this time and listen to the concerns of the remaining employees in department XYZ. By giving

employees a means of communicating the anxiety and stress they feel early on in the integration process,

management can start to gain their trust and clarify any confusion about job security. This should lead to higher

employee satisfaction and make the employees at XYZ more willing to accept future changes made by their new

management team, while building on company morale.

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Case Issue #4 – Elimination of Local HR Department at Maritime Life

The last case issue detected during the M&A at Maritime Life was the elimination of the local HR department in

Halifax. Only a few coordinators remain and the majority of HR-related matters are fed through the Manulife head

office in Toronto. This presents a problem because the HR department is where many employees would turn if they

had work-related issues that they could not discuss with their manager. It is important for the HR employees build a

relationship with employees so they feel comfortable approaching them with uncomfortable issues.

The employees in department XYZ at Maritime Life had likely established relationships with their HR team and losing

this component of their workplace could leave them feeling abandoned with nowhere to turn for assistance. This is

likely not the case at all because employees can turn to the HR team in Toronto; however, the perception employees

have in this situation is that they are being deserted and not truly a part of the newly merged company. Without a

local HR department they may wonder whether their own future at the company is in jeopardy and interpret the

elimination of the HR department as a message that they will be eliminated next (Kavanagh & Ashkanasy, 2006).

These employee perceptions are not true, but the validity of employee perceptions does not change the fact that

employees believe it to be the case. This is caused by a lack of communication between higher level management and

all lower levels of employees within the organization. In order to eliminate false employee perceptions, management

needs to communicate the true purpose of their actions (Jackson & Schuler, 2001).


• As part of the company-wide meetings mentioned in case issue three, management needs to explain the rationale

behind the elimination of the Maritime Life HR department. In doing this they must clearly explain that this

action in no way represents the future of the Halifax office. They must explain that in order to maximize

efficiencies and streamline the company’s HR system, the elimination was necessary. They should stress that this

is not a sign of what is to come in the Halifax office, but it is a sign of integration and becoming one united

company that is stronger and better because of the strengths of both.

• A proactive step that management could take is to bring several representatives from the Toronto HR department

to Halifax for a week or so to meet the employees at Maritime Life, establishing a bond and building trust

between the two groups. If the employees at Maritime Life are expected to feel comfortable approaching the

Toronto HR department with sensitive work-related issues, there must be some sort of relationship established.

During this visit, the Toronto HR department can talk one-on-one with employees, as well as meet with

departments overall. Different information can be shared during each interaction by both the HR department

and the employees at Maritime Life. The HR department can be an important component in the M&A process

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and by allowing the employees in department XYZ to meet their new HR reps face-to-face, they might be able to

eliminate the false perceptions about the future of the Halifax office.

In conclusion, the merger between Maritime Life and Manulife has not been handled appropriately. The key points

from critical five articles suggest that in order to achieve M&A success it is important to understand the existing

corporate culture at Maritime Life, understand the employee uncertainty about change, clearly communicate the

changes to all employees in the newly merged organization, select the right managers, and seizing the M&A as an

opportunity for change. If the management team is able to direct their behaviours towards these issues, the

department XYZ at Maritime Life might be able to get back on track towards a successful integration with Manulife.

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BIBLIOGRAPHY

Achilles, A.A. et al. (2007). “A Top Management Team’s Reactions to Organizational Transformation: The Diagnostic Benefits of Five Key Change Sentiments,” Journal of Change Management, Vol. 7 No. 3-4, pp. 273-290.

Adolph, G. et al. (2001). “Merger Integration: Delivering on the Promise,” Research Summary, Booz Allen & Hamilton (2001), available at http://www.boozallen.com/media/file/76776.pdf

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