© 2015 rittenhouse rankings, inc
TRANSCRIPT
© 2015 Rittenhouse Rankings, Inc. 2
Rittenhouse Rankings 2013 Culture & Candor SurveyTM
EXECUTIVE SUMMARY
CANDOR ANALYTICS TO DECODE CORPORATE CULTURE
Rittenhouse Rankings decodes corporate culture by measuring the amount of candor in
corporate communications. This measure allows investors, customers, employees,
directors, suppliers, journalists, and policymakers to quantitatively gauge the strength or
weakness of internal trust in a company and to predict future performance. Rittenhouse
Rankings’ Candor Scores reveal an “inside’” view of corporate culture and have been
endorsed by Warren Buffett.
The Rittenhouse Rankings Culture and Candor SurveyTM is based on in-depth, iterative
readings of shareholder letters. Financial analysts objectively and systematically
evaluate CEO commentary using protocols that help them identify strategic context,
innovative ideas, capital stewardship practices, financial results, competitive advantages,
mistakes, and customer focus. They search for key words, phrases and business
concepts and award positive points when these are found.
Candor scores help CEOs to identify gaps in corporate communications, which reveal
corporate vulnerabilities. These gaps can increase operational and financial risks and
erode performance if not recognized. Executives who address these gaps will strengthen
execution, protect corporate reputations and deliver better results. Candor rankings
reveal which CEOs are creating the most engaging and informative communications.
Financial linguistic analysts deduct points when they find commentary that includes
clichés, business jargon, incomplete explanations of key business topics, confusing
explanations, and omissions of key ideas or facts. These codes highlight negative candor
or F.O.G., an acronym for “Fact-deficient, Obfuscating, Generalities”. Other F.O.G. codes
include euphemisms, platitudes and contradictory statements.
Rittenhouse Rankings calculates a total score by combining positive candor points and
negative points for F.O.G., and then rank orders the representative sample of 100
Fortune 500 companies to create an annual benchmark of executive corporate candor.
This allows companies to measure their relative communication strengths and
weaknesses.
© 2015 Rittenhouse Rankings, Inc. 3
The Rittenhouse Culture and CEO Candor Rankings analytic tools are in the forefront of an
emerging field in financial analysis: “Financial Linguistics”.
This field focuses on the value of words as well as numbers in analyzing shareholder
value. It recognizes that linguistic analysis helps investors, boards of directors,
customers and employees to gauge the integrity of corporate accounting, culture and
management and to predict future results. Other financial linguistic players include:
The Securities & Exchange Commission which has developed powerful linguistic search
software to analyze MD&A and other corporate reports to identify potential accounting
fraud.
High-frequency traders who use linguistic search software to monitor stock market
sentiment and to position trades.
Business Intelligence Advisors (BIA) and also credit analysts at Valens-Credit Inc., who
are trained in forensic analysis, apply these techniques to analyzing quarterly earnings
teleconferences so they can determine if CEOs are telling or hiding important
information.
Why does Financial Linguistics provide trusted, actionable insights? Because language is
central to human behavior and determines business success or failure. In short: words
shape and determine actions which create the future.
Institutional Investor reporter Jan Alexander described this work in How to Tell if a CEO is
Lying: www.institutionalinvestor.com/article/3427665/banking-and-capital-markets-corporations/how-
to-tell-if-a-ceo-is-lying.html#.VWSp6kb9zZ8
“Data is an outcome, but people create the data,” says Jason Voss, a content director at the CFA
Institute in New York and a former portfolio manager for Davis Selected Advisers, a Tucson, Arizona–
based fund manager. Much of Voss’s work involves seeking out analytical strategies and ways to train
analysts and investors to probe deeper into a senior managers’ psyches. Other research groups working
in this field include Business Intelligence Advisors, a Boston company founded by former intelligence
officers, which uses a proprietary behavioral assessment model to evaluate the information that a
company discloses.
Laura Rittenhouse, a former Lehman Brothers corporate finance executive whom Voss calls one of the
foremost researchers in financial forensics, is the president, founder and CEO of Rittenhouse Rankings in
New York, a corporate consulting firm that advises clients how to develop their inner detector of
corporate spin. Rittenhouse publishes annual rankings of 100 companies in the Fortune 500, known as
the “CEO Candor and Corporate Culture Survey.” The survey, which comes out each April, rates
companies according to what their executive communication reveals about such qualities as strategy,
leadership, accountability and stakeholder relationships. Rittenhouse has found a close correlation
between high stock prices and executive candor in the eight years she’s been doing the study. Using a
detection method she calls F.O.G. — fact-deficient, obfuscating generalities — she subtracts points for
jargon and illogical statements.
© 2015 Rittenhouse Rankings, Inc. 4
KEY FINDINGS: DO WORDS MATTER?
The Candor scores in the 2013 Survey ranged from top-scoring Charles Schwab to ConAgra which
ranked at the bottom of the Survey. Ten companies repeated in both the top-candor quartile and
the bottom-candor quartile compared to the 2012 Survey.
2013 Rittenhouse Rankings Culture & Candor SurveyTM
Table 1: Top and Bottom-ranked Quartile Companies
Top-ranked in Candor Top-ranked in F.O.G.
2013 Rank Company
2013 Rank Company
1 Charles Schwab 100 ConAgra Foods*
2 Pitney Bowes 99 Johnson & Johnson*
3 Southwest Airlines* 98 Comcast
4 General Mills 97 Microsoft
5 Costco* 96 Citigroup
6 Amazon.com* 95 AIG*
7 Alcoa 94 Cigna*
8 JetBlue Airways* 93 Merck
9 CSX 92 Motorola
10 FedEx 91 PepsiCo
11 Air Canada 90 Bank of America*
12 Thermo Fisher* 89 Estee Lauder
13 Siemens 88 eBay
14 Lockheed Martin* 87 Harley-Davidson
15 CBS Corporation* 86 ExxonMobil*
16 Ford Motor* 85 L'Oreal*
17 Eaton* 84 Exelon
18 Fiat 83 News Corp*
19 Hewlett-Packard 82 DuPont
20 Home Depot* 81 Kellogg
21 Foot Locker 80 McDonald's*
22 Capital One 79 Southern Company
23 Schlumberger 78 General Motors
24 Church & Dwight* 77 Wal-Mart*
25 Wells Fargo 76 IBM
*Companies that repeat in the Top or Bottom-25 Ranking in the 2012 Survey.
© 2015 Rittenhouse Rankings, Inc. 5
1. Candor Scores and Market Performance
From the end of June 2013 to the end of June 2014, the average market performance of
companies in the top-quartile of candor rankings outperformed the prices of bottom-ranked
companies, 29.8 percent and 12.3 percent respectively.
The average market performance of companies ranked high in candor in the 2013 Survey
exceeded the performance of companies that ranked high in F.O.G. by 1,750 basis points.
2013 Rittenhouse Rankings Culture & Candor SurveyTM
Chart 1 Average 12-Month Market Performance Top and Bottom-Ranked Quartiles versus S&P 500
Over this eight-year timeframe, the aggregate market price change of top-quartile companies was
110.5 percent vs. the aggregate market price changes of the bottom-quartile companies of 15.7
percent.
The average market price change of top-quartile companies over the eight-year period was 13.8
percent vs. the 2.0 percent average stock price change of the bottom quartile companies.
In comparison, the aggregate change in the S&P 500 Index over this eight-year period was 58.5
percent versus the 22 percent increase year-over-year from Q2 2013 to Q2 2014.
Why is this important? Candor is a proxy for trust. Executives who choose to obfuscate will be
handicapped in creating trust and engagement with stakeholders. Companies with trust-deficient
cultures will be more likely to report disappointing results. A significant lack of candor over time
can foster toxic cultures that will erode shareholder wealth.
© 2015 Rittenhouse Rankings, Inc. 6
2. The Rittenhouse Rankings Model of Corporate Culture and CandorTM
Financial analysts use the Rittenhouse Rankings model below to score content in executive
communications. This model is composed of six primary-colored systems and a grey triangle depicting
corporate candor. Each system is defined by important business topics.
Rittenhouse Rankings Corporate Culture and Candor Model ™
Seven Systems of Candor-Advantaged Business
Model Overview
The hub of the culture and candor model is Capital Stewardship. It includes topics such as cash
flow, goals, capital discipline, and operating metrics. Topics in each of the systems are defined by
scoring protocols, so analysts can systematically and objectively code communications to calculate
measures of positive and negative Candor.
The remaining six systems are organized into three vectors. The red vector or left brain system (1)
combines Strategy and Accountability systems. Strategy topics include business opportunities,
markets and competitive advantages. Accountability topics include, progress reports and financial
results. Strong Accountability disclosure reveals a CEO’s commitment to rigorously execute
corporate strategy and create a culture of ownership and responsibility.
The blue vector or right brain system (2) combines Vision and Leadership. Vision topics include the
corporate purpose and value proposition, as well as statements about innovations. Leadership
topics include commentary about investor skepticism, and what CEOs learned in addressing
problems and failures. Strong, credible leadership supports the realization of a credible and
compelling Vision.
The third vector or backbone of the system (3) combines Stakeholder Relationships and Candor.
Stakeholder relationships include topics about customer needs, employee programs and corporate
empathy. High candor scores is an indicator of stronger and more trusting stakeholder
relationships. Because it is difficult to see the presence of Candor, and easier to code and score for
the absence of candor, points are deducted for Candor topics such as business jargon, confusing
statements, clichés, and contradictory explanations.
All the other systems are awarded positive points for relevant commentary. Negative candor
topics, as a whole, reveal corporate F.O.G; a term for “fact-deficient, obfuscating, generalities.”
(1) (2)
(3)
© 2015 Rittenhouse Rankings, Inc. 7
Culture and Candor Survey Benchmark Diagnostics
Chart 2: Candor Allocation for Total Survey Companies
2013 Survey 129 Net Content pts | 301 F.O.G. pts
Content Allocation
2012 Survey 153 Net Content pts / 298 F.O.G. pts
Net Content scores (total positive points less negative candor points) fell from 154 points in 2012 to
129 points in the 2013 survey. F.O.G. points were relatively flat year-over-year.
CEO obfuscation continues to grow.
Because positive points declined, year over year, F.O.G. commentary increased from 66 percent to
70 percent. This means that the trustworthiness of commentary in the 2013 Culture and Candor
survey was discounted an average 70 percent, up from 66 percent in the 2012 survey.
2013 2012
6% 5%
9% 11%
3% 4%
4% 5%
3% 4%
5% 5%
70% 66%
F.O.G. 70%
F.O.G. 66%
© 2015 Rittenhouse Rankings, Inc. 8
Culture & Candor Survey Benchmark Diagnostics
Chart 3: Top-Quartile Candor Scores
2013 Survey 384 Net Content pts | 201 F.O.G. pts
Content Allocation
2012 Survey 390 Net Content pts / 184 F.O.G. pts
In 2013, top-quartile companies averaged 384 points of net content or total positive candor points.
This was higher than the amount of total information delivered by the 100 company Survey which
averaged 301 points.
As well, top-ranked quartile companies achieved a balanced distribution of content over the six Topic
areas: Strategy (17%), Vision (14%), Leadership (10%), Accountability and Capital Stewardship both
(9%), and commentary related to Stakeholder Relationships scoring 7% of total net content, while
F.O.G. accounted for only 34%.
2013 2012
14% 14%
17% 19%
9% 10%
10% 9%
7% 7%
9% 9%
34% 32%
F.O.G. 34%
F.O.G. 32%
© 2015 Rittenhouse Rankings, Inc. 9
3. Innovative Commentary in Top-ranked Shareholder Letters
Excerpts below from the top six-ranked companies in the 2013 Survey illustrate either a
unique way of looking at the world, or business or even about stakeholders that engages
readers and investors and made these shareholder letters stand out.
1. Charles Schwab reported on the year’s depressed earnings, the ongoing lack of consumer trust
for financial services companies – and how Schwab plans to turn these around.
In my letter last year, I made a few observations about the challenges we would likely face in 2012:
a bruising presidential election, ongoing sovereign debt problems in Europe, continued deleveraging
by consumers, and the Federal Reserve’s doubling down on their extraordinary efforts to anchor
interest rates at record low levels. These all came to pass, making the environment difficult for our
company and our clients.
For Schwab, this environment once again depressed earnings to a level below what we expect to
deliver to stockholders in a more normal environment. For investors, the continued uncertainty
prompted a move out of equities in search of yield and security. Similarly, trading was muted as
investors struggled to see any signs of confidence and conviction in the equity market. Perhaps the
most damaging aspect of 2012 was the ongoing lack of trust that consumers felt toward financial
services firms. According to a recent major survey, trust in financial services companies ranked
near the bottom among all industries.
For many competitors, this lack of trust is a building crisis. But at Charles Schwab, we see an enormous
opportunity. Our vision is clear: We want to be the most trusted leader in investment services.
2. Pitney Bowes reported on new cryptographic technology that provides customers with secure
systems, verifies the authenticity of sensitive documents and finds a balance between customers’
desire for personalized offers and privacy.
Our cryptographic technology is built into our e-commerce and pbSmartPostage™ offerings, and
our expertise in architecting secure systems was essential in the creation of the Volly™ digital
delivery service. Our technology also informs our new pbSecure™ evidencing platform for verifying
the authenticity of diplomas, employment records and other sensitive documents in business and
academia. Our scientists are also working on ways to couple our data security technologies with
our location intelligence applications to help marketers find the best way to balance their
customers’ desire for personalized offers with their concerns about privacy.
3. Southwest Airlines reported fuel conservation practices from lighter-weight, recyclable aircraft
interiors to replacing petroleum-fueled ground-servicing equipment with electric ones.
As fuel is our largest cost and our largest contributor to GHG emissions, our fuel conservation
initiatives are crucial. Our most recent conservation efforts have centered on modernization of our
fleet—including new, more efficient aircraft and the new lighter-weight, recyclable Evolve interior for
the majority of our existing aircraft. Related to this, we continue to increase the number of electric-
powered ground support equipment (GSE) to replace older, petroleum-powered GSE in our fleet.
© 2015 Rittenhouse Rankings, Inc. 10
4. General Mills continued its exemplary reporting of transparent and detailed financial results
that include market-to-market impacts of commodity positions and sales break downs from
acquisitions and the base business.
General Mills’ net sales grew 12 percent in fiscal 2012 to reach $16.7 billion. The international
Yoplait yogurt business that we acquired in July 2011 contributed 7 points of net sales growth, and
sales for our base business grew 5 percent. Segment operating profit increased 2 percent to
exceed $3 billion for the first time in company history. Profits grew at a slower rate than sales
primarily due to the higher input costs, the change in our business mix to include the Yoplait
acquisition, and an 8 percent increase in worldwide advertising and media investment supporting
our brands.
Diluted earnings per share (EPS) of $2.35 were below prior-year results primarily due to changes in
mark-to-market valuation of certain commodity positions in both years, as well as restructuring
charges recorded in the fourth quarter of fiscal 2012. Adjusted diluted EPS, which excludes
restructuring expense, mark-to-market effects, and certain other items affecting comparability of
results, totaled $2.56 in 2012 compared to $2.48 a year ago.
5. Costco focused on corporate culture and defined it as “the way we treat our members.” After
all, these people “pay for the right to shop” and “deserve full attention and respect.”
Member service has always been an area of emphasis for our employees. The way we treat our
members defines who we are – it is an essential part of our corporate culture: Take Care of Our
Members. When people pay for the right to shop, they expect and deserve our full attention and
respect – and we strive to do this with each and every member visit. In this vein, our employees are
Costco’s most important asset; and their attention to “member service” is one of our greatest
strengths.
6. Amazon responded to a company critic who described Amazon as “a charitable organization”
run by investors for the benefit of consumers. He justified the investments in new technologies and
products by invoking Ben Graham’s description of the market as a weighing, not a voting machine.
Our heavy investments in Prime, AWS, Kindle, digital media, and customer experience in general
strike some as too generous, shareholder indifferent, or even at odds with being a for-profit
company. “Amazon, as far as I can tell, is a charitable organization being run by elements of the
investment community for the benefit of consumers,” writes one outside observer. But I don’t think
so. To me, trying to dole out improvements in a just-in-time fashion would be too clever by half. It
would be risky in a world as fast-moving as the one we all live in. More fundamentally, I think long-
term thinking squares the circle. Proactively delighting customers earns trust, which earns more
business from those customers, even in new business arenas. Take a long-term view, and the
interests of customers and shareholders align.
As I write this, our recent stock performance has been positive, but we constantly remind ourselves
of an important point – as I frequently quote famed investor Benjamin Graham in our employee all-
hands meetings – “In the short run, the market is a voting machine but in the long run, it is a
weighing machine.” We don’t celebrate a 10% increase in the stock price like we celebrate
excellent customer experience. We aren’t 10% smarter when that happens and conversely aren’t
10% dumber when the stock goes the other way. We want to be weighed, and we’re always working
to build a heavier company.
© 2015 Rittenhouse Rankings, Inc. 11
4. In the 2013 Survey, fewer companies reported on cash flow than in 2012
Fewer companies reported on cash and cash flow in the 2013 Survey compared to the 2012 Survey,
66 companies vs. 70 respectively. This declining number reflects a similar pattern last observed in
the Surveys during the 2006-2007 pre-bubble market.
The following companies are the top scorers in reporting on cash and cash flow in the 2013 Culture
and Candor Survey. Select cash flow language examples are also presented.
Loews (select excerpts)
Loews ended 2012 with $3.9 billion in cash and investments at the holding
company. In the last few years we have used our cash to help our
subsidiaries make tuck-in acquisitions, to offer bridge financing to our
subsidiaries when conditions in the capital markets were not ideal, and to
buy back our own shares.
We are attracted to companies that have long-term staying power and can
thrive throughout a business cycle. We will consider both cyclical and non-
cyclical companies, as both can contribute meaningfully to shareholder
value if we capitalize and operate them prudently. We are drawn to
companies with undervalued assets and the ability to generate cash flows
over a business cycle for both internal reinvestment and the payment of
dividends.
Church & Dwight
Our annual adjusted free cash flow has increased by $327 million over the
past 10 years. This reflects excellent working capital management by our
financial and supply chain teams in managing our working capital and has
enabled us to achieve free cash flow conversion that leads the consumer
packaged goods industry. Over the next 3 years, we anticipate that we will
generate over $1.2 billion in free cash flow. This will enable us to
aggressively pursue acquisitions, make capital investments to continue to
support the profitable growth of our existing businesses, and return cash to
our shareholders. We have paid consecutive quarterly dividends since
1901.
IBM
Cash flow: IBM has consistently generated strong cash flow, a key indicator
of real business performance. In 2012 our free cash flow was $18.2 billion,
a record for IBM and $12 billion higher than a decade ago. We ended 2012
with $11.1 billion of cash and marketable securities.
Sherwin-Williams
Consistent investment relies on strong, dependable cash generation. In
2012, our net operating cash increased $152 million to $888 million, or
approximately 9.3 percent of net sales. After adding back the cash
settlement paid to the IRS in the first quarter of 2012, cash from operations
for the year approached 10 percent of net sales, a long-term objective for
the Company.
Company Pts.
1. Loews 72
2. Church & Dwight 69
3. IBM 57
4. Sherwin-Williams 51
5. Alcoa 42
6. Dow Chemical 39
7. Eastman Chemical 39
8. Ford Motor 36
9. General Motors 36
10. Costco 33
11. Lockheed Martin 33
12. Xerox 33
13. UPS 27
14. Cisco Systems 24
15. Entergy 24
16. Hewlett-Packard 24
17. Kellogg 24
18. Comcast 21
19. Emerson 21
20. Texas Instruments 21
© 2015 Rittenhouse Rankings, Inc. 12
6. Corporate F.O.G. increases after declining in the 2011 Survey.
In the 2013 Survey, F.O.G. decreased over 2012, however the overall total points for F.O.G.
increased and ranked the second highest in twelve years, signaling future market volatility.
2013 Rittenhouse Rankings Culture & Candor SurveyTM
Chart 4 Toxic and Benign F.O.G. Levels
Examples of F.O.G. from the 2013 Candor Survey
Citigroup
My team and I will continue to seek ways to refine and optimize the execution of our strategy and
improve operating efficiency. [Platitude] As a company, we need to show expense discipline [What is
this “expense discipline”?] and be what I like to call “maniacal allocators of our resources.” [Why
“maniacal”?] Success depends on investing our resources in the right places, in the right businesses,
at the right time. [Cliché] We can’t be everything to everyone. [States the obvious] Our business model
is simple and straightforward: to provide the best core banking products and services What are their
metrics for “the best core banking products and services”? to people and institutions through
leveraging our global footprint, which includes the world’s fastest-growing markets and cities. [Jargon]
ConAgra Foods
We reorganized our sales organization [What changed?], built and launched a customer development
organization [What does this customer development organization do?] and began new joint business
planning processes. [Joint with whom?] These moves are enabling us to transform our relationships with
customers by providing proactive, strategic solutions [Jargon].
© 2015 Rittenhouse Rankings, Inc. 13
7. Reporting on Leadership and Underperformance
In the 2013 Survey, 51 companies reported on underperformance – or “What Went Wrong” in the
2013 Survey down from the 72 companies reporting on this topic in the 2010 survey at the height of
the economic collapse. Contrary to what many investors believe, a majority (54 companies over the
past eight years), provided reports of operating or other kinds of problems in their shareholder letters.
Chart 5: Companies Reporting on What Went Wrong
Top 25 Companies
on What Went Wrong
Rank Company #pts.
1 Novartis 30
2 Exelon 25
3 General Mills 25
4 Citigroup 20
5 Entergy 20
6 FedEx 20
7 Loews 20
8 Sony 20
9 Tim Hortons 20
10 Whirlpool 20
11 Alcoa 15
12 BHP Billiton 15
13 ConocoPhillips 15
14 CSX 15
15 Dow Chemical 15
16 Kellogg 15
17 Pitney Bowes 15
18 Toyota 15
19 3M 10
20 ADP 10
21 Avon 10
22 CIBC 10
23 Eaton 10
24 Edison Intl. 10
25 Fiat 10
Exelon: Most difficult pricing environment since 1997
We are experiencing the most difficult pricing environment the company has faced
since market deregulation in 1997, and our stock price remains correlated to
natural gas prices as well as overall economic conditions. Exelon’s share price on
December 31, 2012, was $29.74, down 31 percent from (pre-merger) Exelon’s
2011 year-end share price of $43.37. Both natural gas and power prices are at or
near 10-year lows. 2012 day-ahead prices in the Electric Reliability Council of
Texas (ERCOT) market dropped 45 percent from 2011, and PJM West prices fell
more than 20 percent from the prior year. 2011-12 was the warmest winter on
record, and load growth for our utilities remained generally flat due to a slow
economic recovery. All of these forces negatively affected our stock price in 2012.
© 2015 Rittenhouse Rankings, Inc. 14
CANDOR RANKINGS METHODOLOGY
Rittenhouse Rankings has developed a proprietary analytic model that includes over 150 topics
typically found in CEO communications. These are organized into six categories: 1) Capital
Stewardship; 2) Strategy; 3) Accountability; 4) Vision; 5) Leadership; and 6) Stakeholder Relations.
Each topic within these categories is defined by a set of rules or protocols. Each topic is assigned
a number and scoring formula that weights its relevance in determining corporate success.
Our goal is to objectively analyze CEO words and context to produce reliable, relevant, and
comparable Candor Scores and Rankings. Letters to shareholders are an important measure of CEO
authenticity because CEOs sign their names to them. A shareholder letter will reveal how much a
CEO understands his business and can articulate how it makes money in order to increase intrinsic
value.
The Culture & Candor methodology can be applied to any corporate communication: MD&A
documents, earnings teleconference calls and shareholder letters. Selected documents are first
scanned and searched for relevant topical statements. Points are awarded for factual details and
context. In addition, documents are analyzed for statements that qualify as “F.O.G.”: Fact-deficient,
Obfuscating, Generalities.” These include platitudes, clichés, business jargon, confusing statements
that lack context and those indicating a loss of direction and focus. Points are deducted for these
examples.
The benchmark Rittenhouse Rankings Culture & Candor ScoreTM is derived by totaling all negative
(F.O.G.) points found in annual shareholder letters and dividing these points by all positive points to
calculate a F.O.G. percentage.
Sorting the relative measures of F.O.G. creates the 100-company rankings in the Rittenhouse Culture
& Candor SurveyTM. The companies that comprise the Rittenhouse Rankings Culture & Candor Survey
were selected in 2000 to create a representative sample of companies based on four business
characteristics: 1) capitalization, 2) financial performance; 3) Fortune 500 reputation; and 4)
industry representation.
All the companies in the sample are U.S.-based except for Siemens, Schlumberger, Novartis, CIBC,
Air Canada, FIAT, Toyota, L’Oreal, and BHP Billiton. Over the past 10 years, approximately 25 percent
of the original sample companies have been replaced due to acquisitions, privatizations, and failure
to publish shareholder letters. Two companies were dropped from the 2011 Culture and Candor
Survey: Rite Aid and Yahoo because they did not publish shareholder letters.