Non-GAAP Disclosures In its 2015 annual report, Kellogg reported the following non-GAAP reconciliation.

Reconciliation of Certain Non-GAAP Financial Measures Consolidated Results ($ millions) 2015 2014 2013 2012 Reported net income . . . . . . . . . . . . . . . . . . . . . $ 614 $ 632 $1,807 $ 961 Mark-to-market . . . . . . . . . . . . . . . . . . . . . . . . . (298) (513) 628 (304)

Project K and cost reduction activities. . . . . . . . (229) (218) (183) (38)

VIE deconsolidation and other costs impacting comparability . . . . . . . . . . . . . . . . . 50 (4) —

Integration and transaction costs. . . . . . . . . . . . (22) (31) (46) (34)

Acquisitions/divestitures . . . . . . . . . . . . . . . . . . 5 — 2 —

Shipping day differences . . . . . . . . . . . . . . . . . . —25——

Venezuela remeasurement . . . . . . . . . . . . . . . . . (149) — (11) —

Comparable net income. . . . . . . . . . . . . . . . . . . 1,257 1,373 1,417 1,337 Foreign currency impact. . . . . . . . . . . . . . . . . . . (100) — —

Currency neutral comparable net income . . . . . $1,357 $1,373 $1,417 $1,337

???? The mark-to-market adjustment pertains largely to unrealized gains and losses on the company’s pension plan assets. These assets are held in marketable securities and earn returns that will be used to make retiree pension payments in future years.

???? Integration and transaction costs pertain to the cost associated with mergers and acquisitions.

The company makes the following additional statements about the non-GAAP measures.

• Non-GAAP currency-neutral comparable definitions of these metrics are reconciled to the directly comparable measure in accordance with U.S. GAAP within our Management’s Discussion and Analysis. We believe the use of such non-GAAP measures provides increased transparency and assists in understanding our underlying operating performance.

• “These non-GAAP measures focus management and investors on the amount of cash available for debt repayment, dividend distribution, acquisition opportunities, and share repurchase.”

Required

a. Does Kellogg’s reasoning for using and reporting the non-GAAP numbers ring true? Explain.

b. What does Kellogg mean by “currency-neutral” in its reconcilliation?

c. Calculate the year-over-year change (in % terms) in reported net income for the four years presented.

Calculate the year-over-year change (in % terms) in the non-GAAP net income. Which trend do we believe more accurately depicts Kellogg’s performance over this period?

d. In 2015, did the mark-to-market adjustment increase or decrease GAAP net income? Did the pension assets have additional unrealized gains or losses during fiscal 2015?

e. Explain a potential rationale for the “integration and transaction costs” adjustment. Is there a counter-argument?