1. Corporate Culture Index™ Overview
July 23, 2010
DISCLOSURE: Michael Brozzetti is CEO & President of Boundless LLC, an internal audit and risk advisory firm and is Chairman of the
Business Integrity Alliance™ which is a joint venture between zEthics, Inc. and Boundless LLC. Michael Brozzetti is a Certified Internal
Auditor® in good standing with the Institute of Internal Auditors and certifies his accountability to the principles within the Institute of
Internal Auditor „s Code of Ethics. Michael is a CIA Learning System training partner with the Institute of Internal Auditors, Villanova
University, and the Holmes Corporation. Michael Brozzetti is currently under consideration for the zEthics, Inc. Board of Directors.

2. Information Demand
Market Stakeholder Groups
Company &
Internal
Audit
Consumers
Research &
& General
Academics
Public
“True” state
of the
Company
External
Workers &
Audit &
Labor
Regulators
Investors &
Advisors
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3. Common Stakeholder Challenges
Level of transparency into Board and Company culture
 No practical way to measure the “Soft controls” that shape
cultural norms and risk appetites. Ethics
 Limited foresight into the cultural risks Governance
that manifest misconduct and fraud.
Risk Management
Disclosure and flow of risk information Compliance
Internal Control
 Often filtered and/or distorted.
Communication & Trust
Accountability and culpability Corporate Culture Index™
When the “top” and “bottom” are not in sync are the
 Case law suggests that not middle activities and related disclosures really effective?
knowing and ignorance is a
defensible claim.
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4. Corporate Culture Index™ (CCI)
Introduction
The CCI™ brings market level transparency to the layer of business integrity that matters
most – the People.
People Business Integrity Hierarchy ™
People
Process
Ethics Process
& Values
Technology
Technology
Governance,
Risk, and
Compliance
Internal & Enabler of “real-time”
Enterprise Quality of risk and
External communication of risk
Risk control information
Adjudication and control information
Management
zEthics.com is a secured 3rd party information service that brings dynamic risk
information into the hands of Companies and market place stakeholders - empowering
them to identify and thoughtfully respond to the people risk and safety on the horizon.
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5. Data Structure & Reporting
 The Corporate Culture Index™ is yielded from the zEthics.com
information service that administers and manages employee surveys and
data submission for subscriber reporting.
Corporate Culture Index ™ 10-point scale
1 2 3 4 5 6 7 8 9 10
Poor Excellent
 There are eight (8) key reporting categories rated on a 10-point scale,
which cover the following cultural dimensions:
 Ethics & Governance
 Risk Management
 Strategic Planning
 Management
 Communication
 Organization
 Empowerment
 Compliance (Audit & Quality)
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6. Data Structure & Reporting..cont’d
 #1 – Questionnaires & Surveys
 Mirrors the organizational hierarchy at the Company level, Business Unit level, and
Management level within four (4) personnel responsibility levels:
 Board Fiduciaries
 Officer Fiduciaries
 Non-Officer Fiduciaries
 Key Functional Management (non-fiduciaries)
 #2 - Ethics Action Reporting (“EARs”)
 Interactive communication for supporting;
 Complaint validation and documentation
 Case management
 Whistleblower protection
 #3 - Suggestion Reporting
 Identify and initiate improvement ideas that drive business returns
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7. Example CCI™ Dashboard
Business Unit & Executive Survey
Business Unit Survey Business Unit 1 Business Unit 2 Business Unit 3 Business Unit 4 Business Unit 5
Ethics & Governance 4.6 4.7 2.4 5.3 4.3
Risk Management 4.3 4.9 1.0 5.3 3.9
Strategic Planning 3.7 4.0 2.8 5.0 3.9
Management 3.6 4.1 1.3 4.9 3.5
Communication 5.0 5.6 4.3 5.9 5.2
Organization 4.0 4.8 2.5 5.1 4.1
Empowerment 4.5 4.9 2.8 5.6 4.5
Compliance (Audit & Quality) 5.2 5.4 3.8 5.6 5.0
CCI™ Composite Rating 4.4 4.8 2.6 5.3 4.3
Drill down and gain dynamic views into the organizational
corporate culture for internal benchmarking
BU #3 Executive Survey CEO CFO COO VP HR CIO
Ethics & Governance 8.6 8.2 2.1 1.6 5.8
Risk Management 8.0 7.2 3.1 3.0 5.8
Strategic Planning 7.4 7.6 3.6 3.4 5.2
Management 7.6 7.8 1.4 1.8 5.4
Communication 5.4 6.0 1.1 1.0 4.8
Organization 6.2 7.8 1.8 2.0 5.8
Empowerment 7.2 7.6 2.5 2.0 5.4
Compliance (Audit & Quality) 8.0 4.8 2.3 2.0 6.6
CCI™ Composite Rating 7.3 7.1 2.3 2.1 5.6
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This is fictitious data for illustrative purposes only

8. Example CCI™ Dashboard
Cultural Trend Analysis
Note: Chart is for illustrative purposes only. PY = Prior Year and CY = Current Year trending.
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9. Example CCI™ Dashboard
Industry Analysis
Note: Chart is for illustrative purposes only. Y = Year.
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10. Disclosure Policy
Information Access by Subscription Type
Information flow that supports market stakeholder groups
Company and External Audit Investors and Workers and General
Internal Audit and Regulators Advisors Labor Public
Generalized
Information
Company
X X X X X
Questionnaire
Company
Company voluntary /
Survey X subpoena
X X Company voluntary
8 Dimensions
Executive Company voluntary /
Survey X subpoena
X1 X Company voluntary
8 Dimensions
Ethics Action Company voluntary / Company voluntary /
X subpoena subpoena
X Company voluntary
Reports (EAR)
Specific Suggestion
X Company voluntary Company voluntary X Company voluntary
Information Reporting
X = Information Access
1 Executive name fields are restricted to the company and internal audit, reporting for this subscriber identifies the
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executive in a standard responsibility level; Board Fiduciary, Officer Fiduciary, Non-Officer Fiduciary, or Key Manager.

11. Company Benefits
 Quickly identify high risk areas of the business, including non-compliance,
weaknesses, mismanagement, fraud, and corruption
 Quantify how company goals, strategies, and objectives affect management
philosophy and operating style
 Plan for and manage the risks associated with organizational change events
 Support strategic decisions that affect organizational changes and
restructuring of authority and responsibility
 Transparency, accountability, and integrity that support the risk oversight
duties of care, loyalty, and prudence
 Demonstrate risk oversight and responsible corporate citizenship by
disclosing risk information and cultural trends in the proxy.
 Ensure that D&O liability coverage exclusions are not invoked (i.e. for fraud,
negligence, non-compliance, etc.)
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12. Internal Audit Benefits
 Empower Internal Audit with a source of risk intelligence that;
 Support dynamic audit planning
 Utilize resources more effectively
 Reduce audit cycle times; and
 Improves governance, internal control, and risk management
 Test, measure, and monitor the effectiveness of the Tone at the Top
and the corporate culture on a relative scale
 Become a catalyst for corporate culture excellence by fostering
honesty, loyalty, mutual trust and respect
 Support Internal Audit opinions and compliance with Institute of
Internal Auditors (IIA) Standards
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13. External Auditors
& Regulator Benefits
 Fast-track valid whistleblower complaints
 Timely access to original, independently derived information
 Improve transparency into the corporation to aid in audit planning,
investigations, etc.
 Support dynamic audit planning
 Utilize resources more effectively
 Reduce audit cycle times
 Effectively audit governance, internal control, & risk management
 Readily identify aggressive corporate cultures that discount risk
 Readily determine where delusion ends and dishonesty begins
 Early warning of fraud and misconduct at corporations
 Check & balance against disclosures in public filings
 Assist SEC with building the Investor Protection Fund
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14. Investor & Advisor Benefits
 Proxy access – board evaluation, selection, nomination and risk disclosures
 Say on pay – leverage to reign in excessive compensation
 Address shortcoming in the marketplace for due diligence
 Credit ratings are unreliable and impossible to measure
 The external audit report identifies limitations in finding fraud
 Stock analysts are not independent – often unreliable and biased
 Access to timely, reliable and comprehensive information about fraud and
high risks
 Early warning of potential problems
 Check & balance against public disclosures
 Collaborate with other investors to actively engage companies within
investment portfolios
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15. Worker & Labor Benefits
 Gain confidence that the peoples voice “will be heard” by participating
in periodic company and executive surveys.
 Gain confidence knowing a 3rd party reviews and validates complaints
while protecting workers anonymity.
 Qualified “whistleblowers” share in rewards and bounty programs.
 Gain confidence that competent Certified Internal Auditors® will help
you understand how to complete and validate complaints.
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16. General Public Benefit
 Know the unbiased truth about corporations
 Easy access to reliable information for due-diligence
 Readily identify aggressive corporate cultures that discount risk
 Safeguard investments and retirement savings
 Make better buying and investing decisions
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17. Business Integrity Alliance
Founders
 Michael Brozzetti, CIA®, CISA®, and CGEIT®
 President of Boundless LLC
 Internal audit Quality, Training, Education and Support
 Ethics, Governance, ERM speaker and workshop leader
 Qualified IIA Instructor
 Chairman of Business Integrity Alliance™
 Chairman of the Chief Audit Executive Roundtable
 Adjunct Instructor with Villanova University
 Mark Rome
 Founder of zEthics, Inc
 Co-Founder of Business Integrity Alliance™
 Member NACD, IIA and IMA
 Media and Publications
 Rome, Mark (2010), How CFO's can evolve the Corporate Culture to drive Business Returns, CFO.com
 Rome, Mark (2010), Using Analytics to Restore Public Trust, Taylor & Francis
 Brozzetti, Michael (2009). A New Era for Internal Auditors. IIA Insight.
 Brozzetti, Michael (2010). Internal Auditing and Fraud Interview (2010). Comcast MoneyMattersTV
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18. Strategic Partnerships
Case Study Highlights
 Villanova University
 Instrumental to the 2008 inception of the IIA/Villanova CIA Learning System university partnership program.
 Supported marketing and growth of the program increasing registration by over 150% from its inception.
 Over 85% of students rated instructor overall performance as exceptionally good during 2010 program.
 Holmes Corporation
 Successful collaboration and delivery of corporate on-site CIA training programs
 Over 100 course seats served
 IIA Philadelphia Chapter
 Founder and Chairman of the 2010 CAE Roundtable that attracted over 50 participants in 2 sessions
 100% of CAE participants rated Chairman performance as exceptionally good (35%) or above average (65%)
 95% of CAE participants rated overall value of roundtable as exceptionally good (15%) or above average (80%)
 Business Integrity Alliance™ Joint Venture
 Co-Founder and Chairman of the Business Integrity Alliance™ a joint venture with zEthics, Inc. committed to
advocating corporate governance excellence and supporting corporate governance market initiatives
 Awarded as one of only 11 consulting firms to participate in the California Public Employee Retirement System
(CalPERS) Corporate Governance Research Spring-Fed pool over the next 3-5 years to support market place.
 Aline
 Collaborative partnership to support the application of governance, risk, and performance methods to improve
organizational accountability, transparency, and integrity.
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19. Contact Information
Contact Information Contact Information
Michael Brozzetti Mark Rome
CEO, Boundless CEO, zEthics, Inc.
3513 Bowman Street 980 9th St., 16 Floor
Philadelphia, PA 19129 Sacramento, CA 95814
(215) 687-7376 (602) 358-9586
mbrozzetti@boundlessllc.com mrome@zethics.com
http://www.zethics.com
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