This document provides an overview of the Corporate Culture Index (CCI) which is an online service that assesses and monitors corporate culture. The CCI uses employee surveys to measure and report on 8 dimensions of culture on a scale of 1-10. It provides dashboards and trend analysis at different organizational levels. The goals of the CCI are to identify risks, empower management, and gain assurance over ethical behavior and soft controls. Benefits include risk oversight, transparency, and supporting internal audit functions and strategic decisions.

1. Corporate Culture Index™ Overview
July 9, 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. Corporate Culture Index™ (CCI)
Introduction
What is zEthics.com and the CCI™? an online 3rd party information service that
brings dynamic dashboard information into the hands of the Board, Management, and
Internal Audit - empowering them with the intelligence to identify and respond to the
people risk and safety on the horizon.
People Business Integrity Hierarchy ™
Ethics Process
& Values
Governance,
Risk, and
Compliance Technology
Corporate Enabler of “real-time”
Enterprise Quality of risk and
Culture communication of risk
Risk control information
Excellence and control information
Management
The zEthics.com and the CCI™ solution enables companies to validate the layer of business
integrity most important to achieve and sustain organizational success – its People
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3. Corporate Culture Index™ (CCI)
Introduction
 The Corporate Culture Index™ provides new insight into strategy,
operations, risk and control management
 Measure and monitor success through organizational
Ethics
change events triggered by:
Governance
 New company goals, strategies, and objectives
Risk Management
 Management and Personnel changes
 Organizational Restructuring Compliance
 Charter and Policy changes Internal Control
 Mergers & Acquisitions Communication & Trust
 IT Implementations Corporate Culture Index™
 External Factors
When the “top” and “bottom” are not in sync are the
 Challenges assumptions and gains positive middle activities really effective?
assurance over ethical behavior
and the “soft controls.”
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*** Proprietary Information ***

4. Data Structure & Reporting
 The Corporate Culture Index™ is yielded from the zEthics.com
information service that administers and manages employee surveys and
data for management 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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*** Proprietary Information ***

5. Data Structure & Reporting..cont’d
 Data structures mirror 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)
 Ethics Action Reporting - Interactive communication for supporting
complaint documentation and case management
 Suggestion Reporting – Identify and initiate improvement ideas that drive
business returns
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*** Proprietary Information ***

6. 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 *** Proprietary Information ***

7. Example CCI™ Dashboard
Cultural Trend Analysis
Business Unit #3 Company
10
9
8
7
6
5
4
3
2
1
0
PY Q2 PY Q3 PY Q4 CY Q1 CY Q2
Note: Chart is for illustrative purposes only. PY = Prior Year and CY = Current Year trending.
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8. Corporate 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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*** Proprietary Information ***

9. 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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10. 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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11. 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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12. 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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