Other developments here include[36] agency theory, which analyses the difficulties in motivating corporate management (the "agent") to act in the best interests of shareholders (the "principal"), rather than in their own interests. Clean surplus accounting and the related residual income valuation provide a model that returns price as a function of earnings, expected returns, and change in book value, as opposed to dividends. This approach, to some extent, arises due to the implicit contradiction of seeing value as a function of dividends, while also holding that dividend policy cannot influence value per Modigliani and Miller's "Irrelevance principle"; see Dividend policy § Irrelevance of dividend policy.