Ethical Tech Matters

Governance Dividend Model

Model the downside exposure tied to AI disclosures and estimate the value of board-defensible governance controls.

Inputs

Enterprise tier

Regulatory exposure

AI claims in current 10-K / 20-F14

Forward-looking and material AI / model statements across MD&A, risk factors, and product narrative.

Senior leaders in filing review6

GC, CFO, CISO, CTO, audit chair, IR — anyone whose calendar the filing actually clears.

Hours per leader, per filing cycle12 hr

Time spent reviewing, redlining, and re-litigating AI language in the run-up to filing.

Modeled outputs

Modeled enforcement exposure

AI-washing / disclosure violation risk

$2,136,750

Illustrative range $1,175,213 – $3,525,638

Board firefighting cost, this cycle

Senior time priced at executive opportunity cost

$43,200

6 leaders × 12 hr × $600/hr blended

ETM fixed-scope engagement

No retainer. No hourly meter.

$25,000 – $45,000

7–10 day pre-clearance review or board packet

Board prep time recovered, per cycle

Pre-cleared language and decision log displace re-review

40 hr

≈ $23,760 of senior time returned

Modeled enforcement exposure vs. ETM review cost

Range

Mid $2.1M

ETM fixed-scope review $25K–$45K

$925K

$1.9M

$2.8M

$3.7M

Modeled enforcement exposure (low–high)Mid estimateETM engagement cost

Illustrative modeled range, not a prediction.

Net Governance Dividend

Modeled

$2,125,510

Range $1,153,973 – $3,524,398

Next step

Get a tailored pre-clearance scope for your filing.

We'll review the modeled snapshot you just generated and send a fixed-scope engagement memo. No retainer, no hourly meter.

Modeled downside avoided, plus senior time recovered, less the fixed-scope ETM engagement cost. Directional figure for board discussion — not a guarantee of outcome.

Assumptions & method

Enforcement exposure is modeled from publicly reported SEC AI-washing and AI-related disclosure matters (e.g. Delphia, Global Predictions, Presto Automation, Rimar Capital), scaled by enterprise tier and a claim-density factor applied to the count of forward-looking AI statements in the filing.

EU AI Act overlays use the published administrative-fine bands — up to €35M or 7% of worldwide annual turnover for prohibited practices, up to €15M or 3% for other obligations, and up to €7.5M or 1.5% for supplying incorrect information — discounted to a modeled likelihood-weighted figure rather than statutory maximum.

Adds illustrative EU AI Act administrative-fine exposure for high-risk and GPAI obligations.

Board firefighting cost prices senior-leader time at a $600/hr blended rate. Time recovery assumes ~55% of pre-filing review hours are displaced once a pre-clearance pack, claim ledger, and decision log are in place.

All figures are illustrative ranges for board-level discussion. They are not legal advice, not an audit opinion, and not a guarantee of enforcement outcome.