content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes board and committee oversight of cybersecurity, with the Board and Committee as grammatical subjects receiving briefings and education on cyber matters. The CISO is a cybersecurity-specific role that makes this firm-specific rather than generic boilerplate.

provider: z-ai

stage: benchmark


content_category: Risk Management Process

reasoning: The paragraph describes the company's internal cybersecurity risk monitoring processes and activities, not the qualifications or background of specific individuals. The PERSON-VS-FUNCTION test confirms this is about what the management team does (monitoring, briefings, threat intelligence, security tools) rather than about the person.


content_category: None/Other

reasoning: This paragraph contains forward-looking risk disclaimers and a cross-reference to the Risk Factors section, with no substantive disclosure about governance, processes, incidents, or specific company practices.


reasoning: The paragraph describes the company's internal approach to cybersecurity risk assessment and management, and its integration with the overall risk management system, which fits the Risk Management Process category. It contains no specific facts, named frameworks, or unique identifiers—only generic language that could apply to any company.


reasoning: The paragraph describes board and Audit Committee oversight of cybersecurity risks, with the Board and Audit Committee as grammatical subjects, fitting the Board Governance category.


reasoning: The paragraph describes the company's internal cybersecurity processes including threat identification, risk evaluation, and participation in cybersecurity forums, with no specific frameworks, tools, dates, or named entities that would distinguish it from any other company's disclosure.


content_category: Strategy Integration

reasoning: This paragraph is a materiality disclaimer stating that cybersecurity threats and incidents have not materially affected the company, which falls under Strategy Integration per the guidelines. The cross-reference to Risk Factors does not change the classification.


reasoning: This is a materiality disclaimer stating that no cybersecurity incidents have materially affected the company's business strategy, financial condition, or results of operations. Per the guidelines, materiality disclaimers fall under Strategy Integration even when boilerplate. The paragraph contains no specific facts beyond the company name (which is excluded as a self-reference), no named frameworks, and uses standard materiality language that could appear in any filing.


reasoning: The paragraph describes board committee oversight of cybersecurity risks, with 'The Committee' as the grammatical subject receiving reports from management. No specific facts are present—'The Committee,' 'management,' 'regular reports,' and 'as necessary' are all generic terms that could appear in any company's disclosure.


reasoning: The paragraph describes the company's internal cybersecurity processes including asset protection, monitoring, vulnerability testing, and incident response activities. It contains no named frameworks, specific cybersecurity roles, dates, named vendors, or other firm-specific details—only generic descriptions that could apply to any company.


reasoning: The paragraph describes the Board's oversight role through annual briefings from management and participation in cybersecurity strategy discussions, with the Board as a key grammatical subject. CIO and CISO are cybersecurity-specific titles that qualify as firm-specific facts, but named roles alone do not reach the Quantified-Verifiable threshold.


reasoning: The paragraph describes Tredegar's internal Cybersecurity Program and its risk-based approach to preventing, identifying, and mitigating vulnerabilities—this is a description of the company's own risk management processes. The mention of third-party service providers is a component of the internal process, not the central topic.


reasoning: This paragraph presents a materiality conclusion stating that prior cybersecurity incidents have not materially affected the company, without describing any specific incident details. Per the tiebreakers, materiality disclaimers and conclusions fall under Strategy Integration even when boilerplate.


reasoning: This paragraph is a standalone materiality disclaimer stating that no cybersecurity threats or incidents have materially affected the company, followed by a cross-reference to risk factors. Per the guidelines, materiality disclaimers are classified as Strategy Integration even when boilerplate, and appended cross-references do not change the classification.


reasoning: This paragraph is a materiality disclaimer stating that cybersecurity breaches have not materially affected the company's business strategy, results of operations, or financial condition, with appended cross-references to Risk Factors. Per the guidelines, materiality disclaimers belong in Strategy Integration even when boilerplate.


reasoning: This paragraph is a materiality disclaimer stating that cybersecurity risks have not materially affected the company's business strategy, results of operations, or financial condition, which per the guidelines falls under Strategy Integration even when boilerplate language is used.


reasoning: This paragraph contains a materiality disclaimer stating that cybersecurity incidents have not materially impaired operations or financial standing, which falls under Strategy Integration per the category guidelines. The cross-reference to Risk Factors appended to the materiality assessment does not change the classification.


reasoning: The paragraph describes the company's internal processes for assessing, identifying, and managing cybersecurity risks, including organizational structure, risk assessments, incident response teams, and incident response plans. The CISO is a cybersecurity-specific title on the ✓ IS list, and the 'IT Cybersecurity and Compliance team' represents a specific team composition, making this Firm-Specific.


reasoning: This paragraph is a general description of IT systems and their importance to operations, not substantive cybersecurity disclosure about governance, risk management processes, incidents, or strategy. It does not describe any cybersecurity oversight, processes, or controls.


reasoning: The paragraph contains a materiality conclusion stating that cybersecurity incidents have not materially affected the company's business, followed by forward-looking materiality disclaimers about potential future impacts on business strategy, results of operations, and financial condition. Per the guidelines, materiality disclaimers fall under Strategy Integration even when boilerplate.


reasoning: This paragraph describes the company's internal security awareness and training processes, including employee education, phishing tests, and remedial training protocols, which fits the Risk Management Process category.


content_category: Incident Disclosure

reasoning: This paragraph describes an actual cybersecurity incident (ransomware attack), including the specific date of detection (May 4, 2022), what systems were affected, and the response actions taken to contain and restore systems. The specific date provides one firm-specific fact, but with only one hard verifiable fact, this does not reach the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal processes for integrating cybersecurity risks into its enterprise risk management program, including risk identification, prioritization, monitoring, and mitigation workflows.


reasoning: This paragraph is a forward-looking risk disclaimer acknowledging general cyber threats and stating no material incidents have occurred to date. It does not describe governance structures, management roles, internal processes, third-party oversight, actual incidents, or business strategy integration—just a generic risk acknowledgment that could apply to any company.


reasoning: This paragraph contains a materiality conclusion about prior cybersecurity incidents without describing any specific incident, which per the tiebreaker rules falls under Strategy Integration. The language is entirely boilerplate with no firm-specific details, named frameworks, or verifiable facts.


reasoning: The paragraph primarily describes the cybersecurity team's responsibilities and the security steering committee's oversight activities, which constitute internal risk management processes. While the Senior Director's qualifications are mentioned, the main focus is on what the team and committee do rather than the person's credentials. The paragraph contains firm-specific facts including a cybersecurity-specific title, a named internal committee, and specific departmental composition.


reasoning: The paragraph describes the company's internal processes for evaluating cybersecurity program effectiveness and oversight through an executive security council, which constitutes risk management process disclosure rather than board governance or management role.


content_category: Management Role

reasoning: Management roles (General Counsel, Assistant General Counsel, executive leadership team, IT leaders) are the grammatical subjects describing who is responsible for cybersecurity risk management. The paragraph contains only generic roles and responsibilities with no cybersecurity-specific titles, named frameworks, dates, or other firm-specific facts.


reasoning: The Audit Committee (a board committee) is the grammatical subject throughout, describing its oversight activities, information received, and reporting cadence to the Board. No specific facts qualify under the IS list—Audit Committee is explicitly excluded as a standard committee, 'quarterly' is a generic cadence without exact dates, and no cybersecurity-specific roles, named frameworks, or verifiable details appear.


reasoning: This paragraph describes an actual cybersecurity incident with specific dates, scope of impact (domestic operations, production delays), and response actions, meeting the definition of Incident Disclosure. Three specific dates (two 8-K filing dates and the incident detection date) constitute hard verifiable facts, qualifying for Quantified-Verifiable specificity.


reasoning: The paragraph describes internal security investments and organizational growth efforts, which constitutes risk management process disclosure. It contains no specific facts—no named frameworks, dates, amounts, headcounts, products, or cybersecurity-specific roles—making it generic boilerplate that could apply to any company.


reasoning: The paragraph describes the company's internal risk management program structure and how cybersecurity is integrated into it, with the CISO responsible for the cybersecurity component. The focus is on the function/process rather than the person's qualifications, and the named IT/Cybersecurity Committee is a non-generic committee that identifies this firm's specific governance structure.


reasoning: This paragraph is a materiality disclaimer stating that no material cybersecurity incidents have occurred and future incidents could materially affect the business, which falls under Strategy Integration per the category guidelines for materiality conclusions.


reasoning: The paragraph describes BD's internal cybersecurity policies, framework alignment, and ISO certification achievements, which constitute the company's own risk management processes. The certification claims (achieving ISO 27001 certification and completing surveillance audits) are firm-specific facts that go beyond merely naming standards.


reasoning: This paragraph describes an actual cybersecurity incident with specific dates, response actions, operational impact, and quantified financial losses, which clearly fits the Incident Disclosure category per the tiebreaker rules for paragraphs that describe what happened in an incident.


reasoning: The paragraph describes the company's internal cybersecurity training and technology tools, which are risk management processes. It contains no named frameworks, specific roles, dates, products, or any verifiable facts—only generic statements about training and tools that could apply to any company.


reasoning: The paragraph describes the company's internal incident response framework, including its structure, escalation protocols, and leadership oversight, which constitutes a risk management process. It contains firm-specific facts: a named internal program (IR Plan) and two cybersecurity-specific executive titles (CITO and CIRO).


reasoning: The Board of Directors and its Risk Assessment and Technology Committees are the grammatical subjects, describing their oversight role, quarterly meeting cadence, and reliance on management-level committees for cybersecurity risk management—clearly fitting Board Governance.


reasoning: The CTO is the grammatical subject and the paragraph describes reporting lines to the Audit and Finance Committee and executive leadership, which fits the Management Role category definition. The CTO is explicitly listed as a cybersecurity-specific title, and 'Digital Quarterly Business Review (Digital QBR)' is a named internal program with a unique identifier, meeting the Firm-Specific threshold.


reasoning: The paragraph describes the company's internal processes for designing, implementing, maintaining, and monitoring safeguards following risk assessments, which is a classic Risk Management Process disclosure. It contains no specific facts, named frameworks, dates, roles, or any details that would distinguish it from any other company's disclosure.


reasoning: The paragraph describes internal processes for cybersecurity risk review (CIO meetings with IT leaders) and incident response planning, which are core risk management activities. The CIO title qualifies as a firm-specific fact per the guidelines.


reasoning: This paragraph describes an actual cybersecurity incident (the MOVEit filesharing vulnerability) with specific dates, scope of affected data (names, SSNs, tax IDs of 429,252 customers), and response actions (email and mail notifications), meeting the definition of Incident Disclosure.


content_category: Third-Party Risk

reasoning: The paragraph's central topic is vendor oversight—describing security assessments and ongoing monitoring of third parties to ensure compliance with cybersecurity standards. No specific facts, named frameworks, or unique details are present; the language could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity processes including assessments, testing, internal audits, threat intelligence, and employee training. CIST is a named internal team identifier unique to this company's disclosure.


reasoning: The paragraph describes an actual cybersecurity incident with specific details about when it occurred (February 16, 2022), what happened (cybersecurity intrusion causing network disruption), scope (certain systems), and response actions (engaging internal resources and third-party experts), which classifies it as Incident Disclosure. The specific date provides one hard verifiable fact, making it Firm-Specific but not reaching the two-fact threshold for Quantified-Verifiable.


reasoning: This paragraph is primarily a forward-looking disclaimer acknowledging general cybersecurity risks with a cross-reference to Risk Factors. It mentions prevented breach attempts in passing but provides no substantive disclosure about governance, management, processes, or an actual incident—only boilerplate risk acknowledgment language.


reasoning: The paragraph describes the company's internal cybersecurity processes including incident response planning, technical reviews, and patch management, which clearly fits Risk Management Process. No specific frameworks are named (only 'multiple cybersecurity risk frameworks' generically), no cybersecurity-specific roles, dates, named tools, or verifiable facts appear—only common security practices that could apply to any company.


reasoning: The paragraph describes the company's internal incident response procedures, including activation criteria, team composition, notification chains, and materiality determination processes. This is Risk Management Process because it details the company's own internal IR planning and procedures.


reasoning: The paragraph describes the company's internal incident response processes, including threat triage, escalation procedures, and management committee involvement. The CISO and Chief Enterprise Technology Officer are cybersecurity-specific titles that qualify as firm-specific facts, but there are no quantified verifiable facts (dates, amounts, named third parties) to reach that threshold.


reasoning: The paragraph primarily describes Board and committee oversight structures for cybersecurity risk, with multiple named non-generic committees (Governance and Compliance Committee, Technology Committee) and the CISO mentioned in the context of reporting to these committees.


reasoning: The paragraph describes the company's internal risk identification process, detailing assessment activities, vendor engagement, training programs, and policy distribution—all characteristic of risk management process disclosure. It contains no named frameworks, specific dates, named third-party firms, cybersecurity-specific roles, or other verifiable facts; the practices described could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment program, policies, and controls, which fits Risk Management Process. It contains no specific facts, named frameworks, or unique identifiers—only generic descriptions of security practices that could apply to any company.


reasoning: The paragraph identifies specific cybersecurity management roles (CISO and Director of IT Security, Risk and Compliance) and describes their qualifications and combined experience, which fits the Management Role category under the person-vs-function test.


reasoning: The paragraph focuses on Board and Audit Committee oversight of cybersecurity risk management, with the Board and its committees as the grammatical subjects throughout. The mention of CIDO and Senior Director, Global IT Security identifies who provides updates to the Board, but the main focus remains on governance structure.


reasoning: The paragraph describes the company's internal cybersecurity processes including framework adoption (CIS controls), vulnerability testing, auditing cadence, and training—classic Risk Management Process content. It names the CIS framework, which qualifies for Sector-Adapted, but contains no firm-specific facts from the IS list (no CISO title, no specific dates, no named tools/firms, no headcounts, no certification claims).


reasoning: The paragraph describes an internal process for reviewing cybersecurity policy, which is a risk management activity. It lacks any specific facts from the ✓ IS list - the team names (Information Security team, Legal Department) and program name (Cybersecurity Policy) are generic, and 'annually' is a vague cadence without exact dates.


reasoning: The Audit Committee is the grammatical subject throughout, and the paragraph describes its oversight role, the annual briefing cadence from management, and the types of cybersecurity information it receives — classic board governance disclosure.


reasoning: The paragraph describes the company's internal cybersecurity incident response procedures, including detection, analysis, mitigation, prioritization, escalation criteria, and internal/external reporting processes, which fits the Risk Management Process category. No named frameworks, specific roles, dates, or verifiable facts are present; the Audit and Finance Committee is a standard governance committee, and all other language is generic boilerplate that could apply to any company.


reasoning: The paragraph describes the activities and processes managed by the GPO (privacy management software, privacy impact assessments, regulatory guidance compliance) rather than the person's qualifications or reporting lines, making it about the function/process. No specific facts qualify under the IS list—GPO is not a cybersecurity-specific title, and the software, team composition, and practices mentioned are all generic.


reasoning: The paragraph describes the company's internal risk assessment process, including how third-party experts support the internal audit team. Third-party experts are mentioned as a component of the internal process rather than as the subject of vendor oversight, so this is Risk Management Process, not Third-Party Risk.


reasoning: The paragraph describes the company's internal cybersecurity strategy and risk management processes, including framework adoption and risk identification activities. It names the NIST Cybersecurity Framework as the basis for their approach, but contains no facts unique to this company beyond the named standard.


reasoning: This paragraph describes an actual cybersecurity incident with specific details about timing (April 2022), scope (disruption to hospital operations, exfiltration of company and patient information), and response actions (enhancements to Security Operations Center, backups, training, detection tools). This clearly fits Incident Disclosure as it narrates what happened in a real event.


reasoning: The paragraph describes the company's cybersecurity risk management program, including framework adoption (NIST, ISO) and integration into overall ERM processes. While board and management roles are mentioned briefly, the central topic is the internal risk management process itself.


reasoning: The paragraph focuses on the CAO's cybersecurity responsibilities, reporting structure over the Enterprise Security Director, and professional qualifications including 24 years of company experience and prior CIO role, making this about the person rather than processes.


reasoning: The paragraph primarily describes the company's internal incident response communication and escalation framework, including processes for escalating cybersecurity events to various stakeholders. The materiality disclaimer at the end is a common appendage but does not change the primary focus on the company's risk management processes.


reasoning: The paragraph describes the company's internal committee structure and processes for overseeing cybersecurity risk, including escalation procedures and reporting channels, which constitutes Risk Management Process. It contains multiple named non-generic committees (ORMC, ERMC, Risk Committee) that are firm-specific facts, but lacks two or more hard verifiable facts like specific dates, dollar amounts, or named third-party firms needed for Quantified-Verifiable.


reasoning: The paragraph describes generic incident response process steps (containment, remediation, recovery) without referencing any specific incident, making it Risk Management Process under IR planning. The language is entirely boilerplate with no named frameworks, specific roles, dates, or firm-specific details.


reasoning: The paragraph focuses on Board and Audit Committee oversight of cybersecurity risks, describing the reporting cadence from management to these governance bodies. The CISO and CIO titles are cybersecurity-specific roles that qualify as firm-specific facts, but no hard verifiable facts (dates, amounts, named third parties) are present to reach Quantified-Verifiable.


reasoning: The paragraph describes the Company's internal cybersecurity risk management structure (Information Security Office) and processes (Incident Response Plan), which fits Risk Management Process. The CIO title is a cybersecurity-specific role per the specificity guidelines, making this Firm-Specific rather than generic boilerplate.


reasoning: This paragraph describes an actual cybersecurity incident with specific timing (September 23, 2023), scope (internal IT infrastructure and applications), and operational/financial impacts (revenue disruption, billing system issues), which constitutes an Incident Disclosure. The specific date provides one hard verifiable fact, making it Firm-Specific, but without a second hard fact (no dollar amounts, named third parties, or named tools), it does not reach Quantified-Verifiable.


reasoning: The paragraph describes the Company's internal cybersecurity monitoring and defense processes, including threat intelligence monitoring, network monitoring, penetration testing, and third-party support, which constitutes risk management process disclosure. No specific facts from the ✓ IS list are present - the Information Security team is a generic team name (not a cybersecurity-specific title like CISO), the managed security service provider and cybersecurity companies are unnamed entities, and no frameworks, dates, or verifiable specifics are included.


reasoning: The paragraph describes the company's internal cybersecurity risk management governance structure, specifically the Information Security Council's composition, authority, and responsibilities for monitoring and mitigating information security risks.


reasoning: The paragraph describes the key features of MetLife's cybersecurity program, covering incident response, policies, testing, risk assessments, vendor management, and training—clearly the company's own internal processes for managing cybersecurity risk. The disclosure includes the CISO role (cybersecurity-specific title) and a detailed cross-functional departmental composition, meeting the Firm-Specific threshold.


reasoning: The paragraph describes the company's internal processes for evaluating and assessing third-party risks as part of its information security program, which constitutes risk management rather than pure third-party risk oversight. It contains no named frameworks, specific dates, named roles, or other verifiable facts—only generic descriptions of vendor risk evaluation practices.


reasoning: This paragraph addresses cyber insurance coverage and materiality considerations (potential material adverse effect), which are Strategy Integration topics. It contains no specific facts—no named insurers, dollar amounts, dates, or other verifiable details—and could appear in any company's filing unchanged.


reasoning: The paragraph's central topic is the company's oversight of cybersecurity risks from third parties, with the third sentence describing a specific process for identifying and overseeing vendor/service provider risks. While the first two sentences discuss using third parties for business functions and cybersecurity assistance, the most substantive content focuses on third-party risk oversight.


reasoning: The paragraph focuses on the CISO as a person—their tenure, experience, and professional credentials—which makes it Management Role under the person-vs-function test. It contains multiple hard verifiable facts: a specific year (2012) and four named certifications (CISM, CISA, CDPSE, CCNA), meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal process for integrating cybersecurity risks into its enterprise risk management program, including assessment activities, which fits the Risk Management Process category. No specific facts are present—'enterprise risk management program' is a generic program name, 'annual' is a vague cadence without exact dates, and 'ADP' is a company self-reference, all of which appear on the NOT list.


reasoning: The paragraph focuses on the qualifications, experience, and credentials of the IT Director and IS Director, making it about the persons in management roles rather than the processes they oversee. The specificity is Quantified-Verifiable because it contains a specific number (over ten years of experience) and multiple named certifications (CISSP, CCSP, GIAC, GCFA, GCIH) that can be independently verified.


reasoning: The paragraph describes an actual cybersecurity incident with a specific date (February 16, 2022), what occurred (intrusion causing network disruption), scope (certain systems impacted), and response actions (engaging internal resources and third-party experts), which meets the criteria for Incident Disclosure. The single specific date qualifies as Firm-Specific but falls short of Quantified-Verifiable which requires two or more hard verifiable facts.


category_confidence: medium

reasoning: The paragraph briefly references the company's internal processes (frameworks informing security controls, Information Security Program design), but the bulk consists of forward-looking disclaimers and a cross-reference to Risk Factors. No specific frameworks are named, no cybersecurity-specific roles are mentioned, and all terms are generic, making this boilerplate language that could appear in any company's filing.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and ERM integration, with no named frameworks, specific roles, dates, or unique identifiers that would distinguish it from any other company's disclosure.


reasoning: This paragraph contains a materiality disclaimer stating that cybersecurity incidents have not materially affected and are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which falls under Strategy Integration per the guidelines. The cross-references to Risk Factors appended to the materiality assessment do not change the classification.


reasoning: The paragraph describes the company's internal cybersecurity function and the processes used to identify, assess, and manage cybersecurity threats and risks, which is the core definition of Risk Management Process. No named frameworks, specific dates, named third-party firms, cybersecurity-specific roles, or other verifiable facts appear—only generic descriptions of security practices and unnamed service providers.


reasoning: The paragraph describes the company's internal cybersecurity risk management activities, including engaging third-party experts for assessments, tabletop exercises, and audits. No named frameworks, specific dates (month+year), named third-party firms, or other verifiable facts appear—only unnamed entities ('external security firm,' 'audit firm') and common practices.


reasoning: This paragraph describes an actual cybersecurity incident (ransomware attack) with a specific date and scope, meeting the criteria for Incident Disclosure. The materiality conclusion is appended to the incident narrative rather than being the sole focus.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including team structure, safeguards, third-party assessments, and framework adoption. The CIO is a cybersecurity-specific title on the IS list, making this Firm-Specific rather than Sector-Adapted despite the NIST CSF framework mention.


reasoning: This paragraph is purely a cross-reference directing readers to other sections of the 10-K (Item 1A and Item 7) for cybersecurity risk discussion, with no substantive disclosure about governance, processes, or incidents.


reasoning: The paragraph describes response actions and remediation measures taken following a disclosed cybersecurity incident, which falls under Incident Disclosure per the guidelines. No firm-specific facts are present—'zero trust' is an architecture concept not a named framework, 'Endpoint Detection and Response' is a tool category not a named product, and 'quarterly' is a generic cadence on the exclusion list.


reasoning: The paragraph describes the company's internal processes for monitoring, detecting, and responding to cybersecurity incidents through an InfoSec Leadership Team and incident response plan, which fits Risk Management Process. No specific facts from the IS list are present—'InfoSec Leadership Team' is a team name rather than a cybersecurity-specific title like CISO, and 'incident response plan' is explicitly listed as a generic program name.


reasoning: The paragraph focuses on identifying management roles responsible for cybersecurity (CIO and SDIS) and details the SDIS's specific qualifications, credentials, and experience. This is about the person holding the role rather than just the function, satisfying the person-vs-function test for Management Role.


reasoning: This paragraph describes an actual cybersecurity incident with specific dates, scope (personal information of substantially all current and former customers), and response actions taken, which clearly fits the Incident Disclosure category.


reasoning: The paragraph describes management's responsibilities for cybersecurity risk management activities including integrating risk considerations, approving budgets and processes, and reviewing security assessments, which fits Risk Management Process. It contains no specific facts, named cybersecurity roles, frameworks, or verifiable details—only generic language applicable to any company.


reasoning: The paragraph describes management's activities in cybersecurity oversight (receiving briefings, threat intelligence gathering, reporting cadences) rather than specific person qualifications, making it Risk Management Process under the person-vs-function test. No specific facts remain after filtering—'management team,' 'Audit Committee,' 'Board of Directors,' and 'quarterly' are all generic governance terms or cadences.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including ERM integration, monitoring activities, and reporting cadences. It lacks any named frameworks, specific dates, cybersecurity-specific titles, or other distinguishing facts—only generic references to 'cybersecurity team,' 'security management,' 'executive management,' and 'audit committee' with vague cadences like 'monthly' and 'periodic.'


reasoning: The paragraph contains a materiality disclaimer stating the company is not aware of cybersecurity risks that have materially affected or are reasonably likely to materially affect the company, which falls under Strategy Integration per the tiebreaker rules. The cross-reference to Risk Factors does not change the classification.


reasoning: This paragraph is a pure cross-reference directing readers to the Risk Factors section with no substantive disclosure about cybersecurity governance, processes, or incidents.


reasoning: The paragraph focuses on the CIO's qualifications, tenure (nearly twenty-five years), career history, and previous roles—this is about the PERSON, not the function, so it qualifies as Management Role under the person-vs-function test. The CIO title is a cybersecurity-specific role on the IS list, and September 2020 is a specific date, providing two Firm-Specific facts, but only one hard verifiable fact (the date) for Quantified-Verifiable threshold purposes.


reasoning: The paragraph describes internal risk assessment and audit processes, with the VP of Internal Audit mentioned only in the context of conducting these processes rather than describing the person's qualifications or background.


reasoning: The paragraph describes the company's internal incident response processes and how they use third-party providers to supplement their capabilities, which is a risk management process. It contains no named entities, frameworks, dates, or specific details — only generic references to 'third party providers' and incident types.


reasoning: The paragraph focuses on the qualifications, experience, and responsibilities of the CISO and CIO, making it about management roles rather than processes. The presence of cybersecurity-specific titles (CISO and CIO) satisfies the Firm-Specific threshold, though the years of experience are approximate ranges rather than exact figures.


reasoning: This paragraph is a pure cross-reference directing readers to the Risk Factors section, containing no substantive cybersecurity disclosure.


reasoning: The paragraph describes the Board's oversight responsibility for cybersecurity risk management and the Chief Risk Officer's supporting role, but Chief Risk Officer is not a cybersecurity-specific title (CISO/CTO/CIO), and no specific facts from the IS list are present.


reasoning: The paragraph describes the governance structure for overseeing technology and cybersecurity risk management practices through the TRCC, a management-level committee. This fits Risk Management Process as it details internal oversight processes, escalation procedures, and risk tolerance monitoring, rather than focusing on individual management roles or board-level governance.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risks through its enterprise risk management team working with the CSO and IT risk management team. The Chief Security Officer (CSO) is a cybersecurity-specific title that qualifies as a firm-specific fact.


reasoning: This paragraph describes external regulatory trends and the general regulatory environment rather than the company's internal cybersecurity governance, processes, or specific incidents. It contains no firm-specific facts, named frameworks, or verifiable details.


reasoning: The paragraph describes the qualifications, credentials, and career backgrounds of specific management personnel (VP/GM and VP of Managed Services), which fits the Management Role category as it focuses on the persons rather than processes or functions.


reasoning: This paragraph describes an actual cybersecurity incident with specific details about what happened (security breach via third-party vendor's file transfer platform), when (February 13, 2023), and scope (patient personal information exposed). The specific date makes it Firm-Specific, but without a named vendor or second hard fact, it does not reach Quantified-Verifiable.


specificity_confidence: medium

reasoning: The paragraph describes management's involvement in cybersecurity processes (three lines of defense model, incident response procedures) rather than identifying specific management personnel or their qualifications, making it Risk Management Process per the person-vs-function test. The three lines of defense model is a general governance concept, not a named cybersecurity framework like NIST or ISO 27001, and no other firm-specific facts are present.


reasoning: This paragraph describes an actual cybersecurity incident with specific timing (April 2023) and details the company's response actions including investigation, law enforcement engagement, and security enhancements, which clearly fits the Incident Disclosure category.


reasoning: The paragraph describes the company's internal risk assessment process for identifying and assessing cybersecurity threats, including how the GRC team and enterprise risk professionals collaborate. No specific facts, named frameworks, or unique identifiers appear—'GRC' is a common industry acronym, and the language could apply to any company's risk assessment process.


reasoning: The paragraph focuses on identifying the Director of Information Technology, their reporting line to the CFO, and their detailed professional qualifications (education, certification, and years of experience), which aligns with the Management Role category. The specificity is Quantified-Verifiable because it contains two hard verifiable facts: a named certification (Microsoft Certified Information Systems Professional) and a specific number (28 years of experience), matching the calibration example for credentials.


reasoning: This paragraph contains a materiality disclaimer stating that cybersecurity challenges have not materially impaired operations or financial standing, which falls under Strategy Integration per the guidelines. The cross-reference to Risk Factors does not change the classification.


reasoning: The paragraph's primary content is a materiality conclusion stating the company has not experienced material cybersecurity breaches or incurred material costs, followed by forward-looking disclaimers about potential business and financial impacts. The brief ERM mention is contextual rather than a substantive process description.


reasoning: The paragraph describes the company's internal risk assessment processes, including annual assessments, risk register updates, and evaluation of policies and safeguards—classic Risk Management Process content. No specific facts, named frameworks, or unique identifiers appear; the language is entirely generic and could apply to any company.


reasoning: The paragraph describes the company's internal process for designing and assessing their cybersecurity program using recognized frameworks, which is a core risk management activity. It names three recognized standards (ISO 27001, CIS 18, NIST) but explicitly disclaims certification and contains no facts unique to this company.


reasoning: The paragraph describes the company's internal risk management processes, including the integration of cyber risk strategy into the ERM program, establishment of the IRM program, and governance structure through multiple named committees. The focus is on the company's own internal processes for managing cyber risk rather than board oversight or management qualifications.


reasoning: The paragraph focuses on management roles (CIO, CISO, VP of Product Security) and their reporting lines to committees, which is the core definition of Management Role. The grammatical subjects are the management positions describing their reporting responsibilities.


reasoning: This paragraph contains a materiality disclaimer stating no cybersecurity risks materially affected the company during the specified period, which falls under Strategy Integration per the guidance that materiality disclaimers belong in this category even when boilerplate. The cross-reference to Risk Factors does not change the classification.


reasoning: This paragraph describes internal governance, risk, and compliance processes including policies, standards, and control systems, which constitutes a Risk Management Process disclosure. It contains no named frameworks, specific dates, named roles, or other distinguishing facts—only generic language about 'industry best practices' and 'regulatory requirements' that could apply to any company.


reasoning: The board of directors is the primary grammatical subject throughout, describing its oversight role for cybersecurity risk and administration through the audit committee. No specific facts remain after filtering—Audit Committee is a standard committee explicitly excluded from the specific facts list, and all other entities (board, executive officers, senior management) are generic governance terms.


reasoning: The audit committee is the grammatical subject receiving quarterly reports on cybersecurity matters, which constitutes board committee oversight of cyber risk. No specific facts remain after filtering—'audit committee' is a standard committee and 'quarterly' is a generic cadence without exact dates.


reasoning: The paragraph describes what the CDO role does (directs, coordinates, plans, organizes information security activities, leads strategy development), which constitutes internal processes and activities rather than person-specific qualifications—triggering the Person-vs-Function test for Risk Management Process. CDO is not a cybersecurity-specific title like CISO/CIO/CTO, and no other firm-specific facts appear.


reasoning: The paragraph focuses on the CISO and CIO roles, their reporting relationships, and how information security personnel are organized under them. The grammatical subjects are management roles (CISO, CIO, Chief Compliance Officer), with the Audit Committee mentioned as the recipient of reports rather than the primary focus.


reasoning: The paragraph describes the Audit Committee's oversight of cybersecurity through regular updates and quarterly reports from the cybersecurity team, making board governance the central topic. No specific facts qualify—Audit Committee is a standard committee (explicitly excluded), 'quarterly' is a generic cadence, and 'cybersecurity team' and 'third-party assessments' are unnamed entities.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including the security team's responsibilities and employee training, which fits Risk Management Process. It contains no specific facts—no named roles, frameworks, dates, or verifiable details—making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal incident response planning and escalation processes, which are core risk management activities. The detailed team composition listing multiple departments provides a firm-specific fact that distinguishes this disclosure from generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management approach, program development, and integration with overall risk governance. It contains no specific facts from the IS list—no named frameworks, cybersecurity-specific roles, specific dates, named third parties, or quantified details—making it generic boilerplate that could apply to any company.


reasoning: The paragraph identifies specific management roles (Information Security Director, CIO), their reporting relationship, responsibilities, and quantified experience credentials. The Person-vs-Function test indicates Management Role because the paragraph emphasizes the individuals' qualifications and tenure rather than solely describing program processes.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment processes, monitoring activities, and tools employed to identify and assess material risks, which fits the Risk Management Process category. No specific facts are present—no named frameworks, roles, dates, or unique identifiers—making it generic boilerplate that could apply to any company.


reasoning: The paragraph describes the company's internal data protection processes, specifically encryption methods used to protect various types of sensitive data, which is a core component of cybersecurity risk management.


reasoning: This paragraph provides a standalone materiality assessment concluding that the company has not experienced material cybersecurity incidents and is not aware of risks likely to materially affect the business, which falls under Strategy Integration per the guidelines for materiality disclaimers.


reasoning: The paragraph describes the company's internal processes for continuously evaluating and assessing its cybersecurity program, including self-evaluations, vulnerability management, and third-party maturity assessments. The named external evaluators (DCMA and CMMC Third Party Assessment Organization) provide firm-specific facts that distinguish this disclosure from generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes (implementing a protection program, incident response, and risk management with mitigation/transference/acceptance) rather than the qualifications or credentials of the Director – Information Systems role, so it falls under Risk Management Process per the person-vs-function test. No specific facts meet the threshold for Firm-Specific—the title 'Director – Information Systems' is not explicitly cybersecurity-specific like the listed examples (CISO, Director of IT Security), and 'incident response plans' is explicitly excluded as a generic program name.


reasoning: This paragraph is a materiality disclaimer stating that no cybersecurity incidents have materially affected or are reasonably likely to materially affect the company, which falls under Strategy Integration per the guidelines. The cross-reference to Risk Factors appended to the materiality assessment does not change the classification.


reasoning: The paragraph describes the company's internal incident response, business continuity, and disaster recovery programs and their functions, which constitutes risk management process disclosure. It contains no specific facts, named frameworks, or unique identifiers—only generic program names and common practices that could apply to any company.


reasoning: The paragraph describes the company's internal processes for risk assessment, vulnerability identification, and compliance maintenance, with third-party engagement as a component of these processes rather than the central topic of vendor oversight.


reasoning: The paragraph's primary purpose is a materiality disclaimer stating that cybersecurity risks have not materially affected the company's business strategy, results of operations, or financial condition, with only a brief, non-specific acknowledgment of past incidents. Per the tiebreaker rules, materiality disclaimers are classified as Strategy Integration even when boilerplate.


reasoning: This is a materiality disclaimer stating that cybersecurity threats have not materially affected the company's business strategy, results of operations, or financial condition, which falls under Strategy Integration per the guidelines. The paragraph contains no specific facts, named frameworks, or unique details—it is standard boilerplate language with a generic cross-reference to Risk Factors.


reasoning: This paragraph describes an internal cybersecurity process—specifically employee training—which is a component of the company's risk management program.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including framework adoption (NIST), ERM integration, threat assessment approach, and company-wide policies and procedures.


reasoning: The paragraph describes the company's internal incident response and escalation processes, including the Incident Response Team structure and reporting chains. No firm-specific facts are present—BCC is not a cybersecurity-specific title per the ✓ IS list, CLO is generic C-suite, Audit Committee is a standard committee, and 'business continuity plan' is a generic program name.


reasoning: The paragraph describes the company's internal cybersecurity organizational structure and capabilities—the Cyber Security Office, its leadership by the CISO, team composition, and certifications held—which constitutes internal processes for managing cybersecurity risk rather than focusing on individual management qualifications.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including framework adoption (NIST 800-171) and integration with enterprise risk management, which is a classic Risk Management Process disclosure.


reasoning: The paragraph describes the company's internal cybersecurity processes, specifically framework adoption (NIST CSF, C2M2) and alignment with regulatory requirements (BPU), which constitutes risk management process disclosure.


reasoning: The paragraph describes the company's internal processes for supervising and managing cybersecurity risks through briefings, threat intelligence, and security tools, which fits Risk Management Process. No specific facts, named frameworks, or verifiable details are present—only generic descriptions applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment processes, including framework adoption (NIST) and how third-party considerations are incorporated into their own risk management. The third-party mention is a component of internal processes, not the central topic of vendor oversight requirements.


reasoning: The paragraph describes the company's internal cybersecurity risk management approach, including framework adoption (NIST, CIS, COBIT, ISO), policy development, protection techniques, and employee training programs.


reasoning: The paragraph describes the company's internal cybersecurity processes including training programs, phishing simulations, security policies, and enterprise-wide testing - all standard risk management activities.


reasoning: This paragraph contains a materiality disclaimer stating that cybersecurity threats and incidents have not materially affected and are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which falls under Strategy Integration per the category guidelines. The cross-reference to Risk Factors appended to the materiality assessment does not change the classification.


reasoning: The paragraph describes the company's internal cyber risk management process, including who manages it and what resources are invested, but the titles mentioned (SVP Operations, VP Deputy General Counsel, CEO) are not cybersecurity-specific roles, and no named frameworks, dates, products, or verifiable facts are included.


reasoning: The paragraph describes the company's high-level approach to cybersecurity measures and objectives (securing information systems, preserving data confidentiality/integrity/availability), which falls under risk management process, though it lacks specific details about actual processes or frameworks.


reasoning: The paragraph describes the company's internal cybersecurity processes including SLA coverage, security controls for unsupported applications, incident response procedures using third-party consultants, and disaster recovery planning. This is about the company's own internal processes for managing cyber risk.


reasoning: The paragraph focuses on management-level committee structure and CISO/CIO roles—the IT/Cybersecurity Committee is a management committee chaired by the CIO, and the CISO's reporting lines are detailed. Board involvement is limited to approving the committee structure.


reasoning: The paragraph describes an actual cybersecurity incident from 2020 involving a systems intrusion and malware infection, including when it occurred and what happened. While brief and accompanied by materiality conclusions, it meets the threshold for Incident Disclosure by referencing a real event with descriptive details about the incident itself.


reasoning: The paragraph contains a standalone materiality conclusion stating the company is not aware of any previous cybersecurity threats that have materially affected or are reasonably likely to materially affect the Company, followed by forward-looking risk disclaimers and a cross-reference to Risk Factors.


reasoning: The CISO is the grammatical subject, and the paragraph describes reporting lines and information flow from the CISO through management to the Audit Committee, which fits the Management Role category definition for CISO identification and reporting lines.


reasoning: The paragraph describes the company's internal cybersecurity controls, risk assessment process, and security awareness training program. The grammatical subject is the company's own processes and programs, not board oversight, management qualifications, or third-party risk.


reasoning: The paragraph focuses on the ISO role—identifying responsibilities, team composition, and reporting lines. The ISO is the grammatical subject, and the disclosure describes organizational structure rather than specific processes or frameworks.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including the establishment of an internal working group, program implementation for protecting information systems, ongoing monitoring, and incident response protocols. The CISO title constitutes a firm-specific fact, while CCO and COO are generic C-suite roles that do not count toward specificity.


reasoning: This paragraph contains forward-looking risk factor language describing potential cybersecurity threats and their possible impacts, without disclosing any actual governance structures, management roles, risk management processes, or incidents. It is generic risk disclosure that does not fit any substantive category.


reasoning: The paragraph describes Honda's internal cybersecurity risk assessment and reporting processes, including the organizational structure for monitoring and supervising cybersecurity risks. The headcount of 64 members is one hard verifiable fact, but there is no second hard fact (no dates, dollar amounts, named third-party firms, or named tools), so this reaches Firm-Specific but not Quantified-Verifiable.


reasoning: The paragraph focuses on Board and Audit Committee oversight of cybersecurity, including reporting cadences and briefings. The CISO and CIO are mentioned only in the context of their reporting duties to the Board, not their qualifications or background.


reasoning: The paragraph describes the company's internal organizational structure for cybersecurity oversight, including a management-level steering committee and local Information Security Officer roles with their monitoring and certification processes. This is about what the roles and program do rather than specific persons' qualifications.


reasoning: The paragraph describes the company's internal cybersecurity processes including threat monitoring, vulnerability scanning, incident response workflows, and escalation procedures. The focus is on how the organization manages cybersecurity risks from detection through resolution.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, with the Board of Directors and Board Risk Committee as the primary grammatical subjects in the opening sentence, establishing board oversight as the main focus. Management roles are mentioned but in the context of reporting to and being overseen by the board.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including risk assessment, framework adoption (NIST CSF), vulnerability management, monitoring, and ERM integration. The grammatical subject is 'we' (the company) describing its own processes.


reasoning: Paragraph describes an actual cybersecurity incident with specific details about what happened (unauthorized access, encryption, exfiltration), when (February 3, 2025), and response actions taken (activated incident response plan, engaged third-party experts).


reasoning: This paragraph contains a materiality disclaimer stating that cybersecurity threats have not materially affected the company's business strategy, results of operations, or financial condition. Per the guidelines, materiality disclaimers are classified as Strategy Integration even when boilerplate, and a cross-reference appended to a materiality assessment does not change the classification.


reasoning: This paragraph contains a materiality conclusion ('to date these incidents have not had a material impact') and discusses potential business/financial impacts without describing any specific incident, which fits Strategy Integration. It contains no specific facts—no dates, named entities, frameworks, or cybersecurity-specific roles.


reasoning: The paragraph describes the company's internal cybersecurity program, including framework adoption (CRI Cyber Profile, NIST), control assessments, policies, and training initiatives. The grammatical subject is the company's own processes.


reasoning: The paragraph describes an actual cybersecurity incident with specific details about what happened (targeted cyber-attack), when (February 2022), scope (most connectivity, operating and accounting systems globally), response actions (shut down systems, initiated incident response plan), and operational impact (limited ability to conduct operations for approximately three weeks).


reasoning: The paragraph describes Board and committee oversight structures for cybersecurity, including the Audit Committee's delegated responsibility and the establishment of a Cybersecurity Steering Committee with named directors and management roles.


reasoning: The paragraph focuses on identifying specific management roles (CDIO and VP of Platforms, Infrastructure and Cybersecurity) and their qualifications, credentials, and career experience—this is about the persons, not the processes they oversee.


reasoning: The paragraph describes DFIN's internal cybersecurity training and awareness programs, including monthly phishing simulations, quarterly IT training, and incident response tabletop exercises, which are all components of the company's risk management process.


reasoning: The paragraph primarily focuses on identifying the management team structure (CTO, VP of IT, Senior Director of IT Security) and their qualifications, with Board oversight mentioned as the audience for management reports rather than as the primary subject.


reasoning: The paragraph's central topic is vendor oversight, describing vetting processes, attestation reviews, and contractual security requirements imposed on third parties. It contains no named frameworks, specific roles, dates, or other facts that would distinguish it from generic disclosure.


reasoning: This paragraph describes an actual cybersecurity incident (MOVEit Transfer) with details about what happened, when (during 2023), scope (customer data potentially exposed through online/mobile banking), and response actions (vendor patched, customer notification). The incident narrative with specific facts clearly fits Incident Disclosure.


reasoning: The paragraph focuses on the CISO's role, responsibilities, and professional qualifications, including their years of experience and career background. The PERSON-VS-FUNCTION test confirms this is about the person (qualifications, credentials, career history) rather than the function's processes.


reasoning: This paragraph describes the scope of a cybersecurity incident (ransomware actors exfiltrated personal information) and response actions taken (notifications to individuals and regulators), which fits the Incident Disclosure category. No specific facts are present—no dates, named products, named third parties, or specific numbers—only generic incident response language.


reasoning: The paragraph covers multiple topics including CISO qualifications, reporting lines, and risk management processes, but the Board and Audit Committee are the primary grammatical subjects receiving reports and exercising oversight over cybersecurity risks, making Board Governance the most applicable category under the tiebreaker rules.


reasoning: The paragraph focuses on management roles (CISO, CIO, CFO), their qualifications, reporting lines, and responsibilities for cybersecurity oversight. The CIO's 35 years of experience and degree are detailed, and the CISO's reporting structure is described.


reasoning: The paragraph has two distinct parts: the first sentence describes the CISO's credentials (Management Role), while the second sentence details Board committee oversight activities. The second sentence is longer and more detailed about governance activities, making Board Governance the primary focus per the tiebreaker rules.


reasoning: The Risk Committee (a board committee) is the primary grammatical subject and is explicitly identified as having oversight responsibility for cybersecurity. The paragraph describes the governance structure through which the Risk Committee oversees cyber risk via multiple management-level subcommittees.


reasoning: The paragraph describes the company's internal incident response program, escalation protocols, and severity assessment processes—classic Risk Management Process content. The third-party service providers are mentioned as assisting the company's own processes, not as vendors being overseen, so this does not qualify as Third-Party Risk.


reasoning: This is a materiality disclaimer stating that no cybersecurity threats have materially affected or are reasonably likely to materially affect the company, which falls under Strategy Integration per the guidelines. The paragraph contains no specific facts—only boilerplate materiality language and a standard cross-reference to Risk Factors.


reasoning: The paragraph primarily describes the company's cybersecurity program, systems, training, and risk management processes, with management qualifications mentioned as one component of program oversight. The CISO title is a cybersecurity-specific role that qualifies as firm-specific, but the experience years are approximate ('over thirty', 'nearly twenty') and don't reach the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal cybersecurity risk management activities including security investments, testing, monitoring, risk assessments, and third-party risk evaluation as part of their overall framework. No specific facts are present—no named roles, frameworks, dates, tools, firms, or quantified details; all elements are generic practices that could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including ERM integration, ISO certification, incident response procedures, and internal reporting flows. It contains firm-specific facts (CTO role, ISO 27001:2013 certification claim, IT Security Team, Legal and Compliance teams) but lacks two or more hard verifiable facts such as specific dates, dollar amounts, headcounts, or named third-party firms required for Quantified-Verifiable.


reasoning: This paragraph is forward-looking risk factor language describing hypothetical breach scenarios and potential consequences, not substantive disclosure about governance, processes, or actual incidents.


reasoning: This paragraph describes the company's internal cybersecurity risk management process, including how they use a third-party IT firm to identify, assess, and manage threats. The third-party is a component of their internal process rather than the central topic of vendor oversight. No specific facts qualify for Firm-Specific status—the IT Lead and CFO are generic roles, the IT Firm is unnamed, and no frameworks, dates, or verifiable details are provided.


reasoning: The audit committee is the grammatical subject receiving reports on cybersecurity threats and risk, which constitutes board/committee oversight of cyber risk. The paragraph contains no specific facts—'Audit Committee' is explicitly a standard committee, 'regular' is a vague cadence, and 'Security Team' is a generic team name without composition details.


reasoning: The Audit Committee is the grammatical subject and the paragraph describes its oversight role in receiving reports on cybersecurity threats and risks, which is classic board governance content.


reasoning: The paragraph focuses on the CISO as a person—their responsibilities, career history, qualifications, and reporting lines—including specific details about their promotion to CISO in 2013 and 14 years at a previous employer, which makes this a Management Role disclosure with Firm-Specific details.


reasoning: This is a materiality disclaimer stating no material cybersecurity risks have affected or are likely to affect the company, which falls under Strategy Integration per the explicit tiebreaker rule. The paragraph contains only standard boilerplate language with no specific facts, named standards, or unique company details.


reasoning: The paragraph focuses on management structure with CTO and CISO as grammatical subjects, describing their reporting relationship and the CTO's qualifications (over twenty years of experience). While it includes elements of Risk Management Process, the PERSON-VS-FUNCTION test points to Management Role due to the emphasis on the CTO's credentials and oversight role.


reasoning: The paragraph describes the company's approach to managing privacy risks through external benchmarking and peer collaboration via membership in the Data Privacy Board, which constitutes a risk management activity. However, the Data Privacy Board is an external industry consortium rather than a named framework, internal role, or verifiable third-party firm, so no facts qualify under the specificity criteria.


reasoning: This paragraph is forward-looking risk factor language describing potential cybersecurity threats and consequences without any substantive disclosure about the company's actual governance structures, management roles, internal processes, or specific incidents.


reasoning: The board of directors is the grammatical subject and the paragraph describes board oversight of cybersecurity risk management activities, fitting the Board Governance category. The language is entirely generic with no named committees, specific roles, dates, frameworks, or other firm-specific details.


reasoning: The paragraph describes the company's internal risk management reporting processes, including what information is reported (risk assessments, control decisions, testing results) and the cadence. The grammatical subject is the IT Management team (management), not the board or a committee, so this fits Risk Management Process rather than Board Governance.


reasoning: The paragraph is primarily a materiality disclaimer stating the company has not experienced a material cybersecurity incident, which falls under Strategy Integration per the tiebreaker rules for materiality conclusions without incident narrative.


reasoning: The paragraph describes the company's internal responsibility structure for assessing and managing cybersecurity risks, which falls under risk management process. All mentioned roles (COO, CFO, General Counsel) are generic C-suite positions, and the Nominating and Corporate Governance Committee is a standard corporate governance committee rather than a cybersecurity-specific committee, so no firm-specific facts are present.


reasoning: This paragraph contains a materiality disclaimer stating that cybersecurity risks have not materially affected the company, followed by a cross-reference to risk factors. Per the guidelines, materiality disclaimers are classified as Strategy Integration even when boilerplate, and the appended cross-reference does not change this classification.


reasoning: The paragraph focuses primarily on the Audit Committee's central role in Board oversight of cybersecurity risks, with management roles (CIO, CSIRT, SVP Technology and Innovation) mentioned only in the context of informing the Audit Committee. Two of three sentences directly address the Audit Committee's oversight responsibilities and composition.


reasoning: The paragraph describes the company's internal organizational structure for cybersecurity risk management, including an incident response team and information security advisory board with their composition and responsibilities. This fits Risk Management Process as it details the company's own internal processes and governance structures for managing cyber risk.


reasoning: This paragraph contains a materiality disclaimer stating that cybersecurity risks have not materially affected and are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which falls under Strategy Integration per the category tiebreakers. The cross-reference to Risk Factors does not change the classification.


reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity risk, with both serving as grammatical subjects throughout. No specific facts remain after filtering—the COO is generic C-suite, Audit Committee is a standard committee, and GECM is a company self-reference.


reasoning: The paragraph describes the company's general approach to identifying, assessing, and managing cybersecurity risks, which constitutes a risk management process disclosure. It contains no specific facts, named frameworks, or verifiable details—only generic risk categories that could apply to any company.


reasoning: The paragraph discusses cyber insurance coverage and potential material adverse effects from cybersecurity incidents, which aligns with Strategy Integration's coverage of business/financial impact and insurance. No specific facts are present—no named insurers, coverage amounts, frameworks, dates, or cybersecurity-specific roles—making it generic boilerplate that could apply to any company.


reasoning: The paragraph describes the company's internal risk-based approach to identifying cybersecurity risks, which is a risk management process. While third parties are mentioned, the focus is on the company's own process for identifying risks, not on vendor oversight requirements, so it falls under Risk Management Process per the tiebreaker for internal processes mentioning vendors as a component.


reasoning: The paragraph describes board and committee oversight structures for cybersecurity risk, with the Board and its committees as the grammatical subjects throughout. The Technology and Cybersecurity Committee is a named non-generic committee, and the CIO and CISO are cybersecurity-specific roles, meeting the Firm-Specific threshold.


reasoning: The paragraph describes the company's internal safeguards and disaster recovery capabilities, which are risk management processes. It contains no named frameworks, specific dates, named products, named third parties, cybersecurity-specific titles, or other facts that would identify this company uniquely.


reasoning: This paragraph contains a materiality disclaimer stating the company has not experienced a cybersecurity incident that materially affected its business, which falls under Strategy Integration per the guidelines. The cross-reference to Risk Factors does not change the classification. No specific facts remain after filtering—filing form type and boilerplate materiality language do not qualify.


reasoning: This paragraph describes the company's internal cybersecurity risk management activities (designing controls, framework development, penetration testing, monitoring, incident response) with third-party support as a component of those processes, not vendor oversight as the central topic.


reasoning: The paragraph describes board-approved committees (ITAC, ERM, ITSC) that provide oversight of technology and information security programs, with ITAC and ERM chaired by board members. Management roles are mentioned as participants in these governance structures, but the central focus is on committee-level oversight and reporting lines to the board.


reasoning: The paragraph is primarily a materiality disclaimer stating that cybersecurity risks have not materially affected the company's business strategy, results of operations, or financial condition, with a generic acknowledgment of past threats and a cross-reference to risk factors. The materiality conclusion is the main point, and no specific incident details, dates, or verifiable facts are provided.


reasoning: The paragraph describes the company's internal processes for evaluating cybersecurity risks, detecting vulnerabilities, and incident notification procedures. The CISO is mentioned as part of the collaborative risk management function, not as the primary subject describing qualifications, so this is about the process rather than the person.


reasoning: The paragraph's central topic is vendor oversight—describing the company's vendor management program and the specific assessment activities and contractual requirements imposed ON third-party providers, which fits Third-Party Risk. No named frameworks, cybersecurity-specific roles, specific dates, named firms, or unique program identifiers appear; the policy name is descriptive rather than a unique identifier, so specificity is Generic Boilerplate.


reasoning: The paragraph describes the oversight structure for cybersecurity, with the Board and Audit Committee as the primary oversight bodies and the SVP, Head of Legal and Compliance serving as the management layer that reports up through the governance chain. No specific facts qualify for Firm-Specific status: the SVP role is a legal/compliance position (not a cybersecurity-specific title like CISO/CTO/CIO), Audit Committee is explicitly excluded as a standard committee, and 'quarterly' is a generic cadence without exact dates.


reasoning: The paragraph describes the company's internal cybersecurity strategy, policies, and assessment processes, which is a classic Risk Management Process disclosure. No named frameworks, specific roles, dates, named third parties, or other firm-specific facts appear—only generic policy areas and common practices that could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity team structure, responsibilities, and risk mitigation measures, which is a classic Risk Management Process disclosure. The CIO is explicitly listed as a cybersecurity-specific role on the IS list, making this Firm-Specific.


reasoning: This paragraph describes internal incident response procedures and IRT coordination activities, which are part of the company's risk management process. It contains no named frameworks, specific roles, dates, or other firm-unique details that would distinguish it from boilerplate language.


reasoning: This paragraph is a risk acknowledgment stating the company lacks the manpower, expertise, and financial resources to effectively manage cybersecurity risks. The absence of a cybersecurity program is not a description of a program, and this represents a disclaimer rather than substantive disclosure about governance, management, processes, or incidents.


reasoning: The paragraph focuses on identifying the CTO, their reporting relationship to the Risk Committee, and their professional qualifications including specific degree and years of experience, which clearly centers on the management role rather than processes.


reasoning: This paragraph describes potential business and operational impacts of cybersecurity incidents (production delays, delivery disruptions, fulfillment issues), which falls under Strategy Integration's coverage of business/financial impact. The language is entirely hypothetical and generic, with no firm-specific details.


reasoning: The paragraph describes the company's approach to managing cybersecurity risk through outsourced service providers and oversight by the Principal Financial Officer. The grammatical subjects are the Information Security Team and service providers, not the management role itself, making this about the company's internal processes rather than management identification. No specific facts qualify for Firm-Specific—the Principal Financial Officer is a generic C-suite role (not a cybersecurity-specific title like CISO/CTO/CIO), and 'two separate service providers' is a vague quantifier without named firms.


reasoning: The paragraph focuses on the qualifications, credentials, and career history of the CISO, cybersecurity team members, and other executives, which is about the person rather than the function per the person-vs-function test.


reasoning: The paragraph describes the company's internal processes for identifying and assessing cybersecurity risks, including monitoring, threat intelligence analysis, and vulnerability scanning. The Director of Information Technology is a cybersecurity-specific role that qualifies as a firm-specific fact, but no named frameworks, dates, or quantified details are present.


reasoning: The paragraph identifies specific management roles responsible for cybersecurity oversight and describes their collective qualifications, making it a Management Role disclosure. However, all titles mentioned (CFO, VP Finance, SVP Legal, VP Quality) are generic corporate roles—not cybersecurity-specific positions like CISO or CTO—and no named frameworks, dates, or verifiable facts appear, resulting in Generic Boilerplate specificity.


reasoning: The paragraph focuses on the qualifications, credentials, educational background, and career history of two named cybersecurity executives (CSO and CISO), which is about the persons filling these roles rather than the functions or processes they manage.


reasoning: The paragraph's central and sole topic is vendor security oversight, describing assessments conducted on service providers during onboarding and contract review. No named frameworks, specific vendors, dates, or other firm-specific facts appear—only generic descriptions of vendor assessment practices.


reasoning: This paragraph discusses the potential material effects of cybersecurity threats on the Company's business, financial condition, and results of operations, along with a materiality disclaimer and cross-reference to Risk Factors—classic Strategy Integration content. It contains no specific facts, named frameworks, or verifiable details, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity training and awareness programs, including phishing exercises, safety meetings, and tabletop exercises, which are components of the company's risk management processes.


reasoning: The paragraph describes the CyTOC committee's oversight activities, including receiving updates from the CISO and other executives, reviewing cybersecurity metrics, and briefing the Board. The primary grammatical subjects are the CyTOC and the Board, which fits Board Governance. Specific facts include the named committee (CyTOC) and cybersecurity-specific titles (CISO, Chief Digital and Information Officer).


reasoning: The paragraph describes the company's internal cybersecurity risk management processes including prevention, detection, response, and recovery activities. It contains no named frameworks (only 'industry standard security frameworks'), no specific roles, no dates, and no other firm-specific details that would elevate it above generic boilerplate.


reasoning: This is a standard executive biography with no cybersecurity content. Travis Smith is a business segment leader (AFP segment), not a cybersecurity role, and the paragraph contains no cybersecurity-related information.


reasoning: This is an introductory paragraph describing the general cybersecurity threat landscape without substantive disclosure about governance structures, management roles, internal processes, third-party oversight, or specific incidents.


reasoning: The paragraph's central and sole focus is on identifying and overseeing cybersecurity risks from third parties and their systems, which fits the Third-Party Risk category definition for vendor oversight as the primary topic.


reasoning: The paragraph describes the company's internal cybersecurity policy framework, detailing the standards, controls, and management responsibilities across multiple security domains. This is a description of the company's own internal processes for managing cyber risk.


reasoning: This paragraph consists entirely of forward-looking disclaimers, generic risk acknowledgment, and a cross-reference to Risk Factors. It contains no substantive disclosure about governance, processes, roles, or incidents—only boilerplate cautionary language about potential future risks.


reasoning: The paragraph primarily describes the CSIRT's internal processes for cybersecurity risk assessment and management, including reviewing initiatives, incident response planning, compliance, and training. While the Director of IT's qualifications are mentioned, the paragraph's focus is on what the team does (processes) rather than the person, satisfying the person-vs-function test for Risk Management Process.


reasoning: The paragraph describes the company's internal incident response planning and its integration with the overall risk management system, which is a Risk Management Process. It contains one firm-specific fact: a named internal program with a unique identifier, the Cybersecurity Incident Response Plan (IRP).


reasoning: The paragraph describes the company's internal processes for integrating cybersecurity risk assessment into enterprise risk management, including how management prioritizes and evaluates risks, which fits Risk Management Process. No cybersecurity-specific roles (CISO, CTO, CIO), named frameworks, specific dates, or other qualifying facts appear—only generic C-suite roles (COO, General Counsel) and the standard Audit Committee.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment methodology, detailing the three-part process for identifying assets, assessing criticality, and determining threat impact and likelihood.


reasoning: The paragraph describes the company's internal cybersecurity processes including risk assessments, security protocols, and engagement of external assessors for risk management.


reasoning: The paragraph describes the company's internal processes for threat intelligence gathering and staying informed about cybersecurity developments through various third-party engagements and information-sharing communities.


reasoning: The paragraph describes the company's internal cybersecurity processes including security testing, threat intelligence review, and third-party consultation as part of their risk management strategy.


reasoning: The paragraph describes the company's internal cybersecurity processes including automated tools, testing practices, employee training, and third-party oversight mechanisms. The third-party vendor mention is a component of internal processes rather than the central topic, and no specific frameworks, roles, dates, or named entities are disclosed.


reasoning: This paragraph is a materiality disclaimer stating that no incident has occurred and discussing potential material effects on business strategy, results of operations, and financial condition, followed by a cross-reference to Risk Factors. Per the category tiebreakers, materiality disclaimers are classified as Strategy Integration even when boilerplate.


reasoning: The paragraph describes the company's internal security governance structure for evaluating and addressing cyber risk, with the company ('we') as the grammatical subject. The Board and CFO are mentioned as components of this structure, but neither is the primary focus. No specific facts are present—CFO is generic C-suite, Board is generic governance, and no named frameworks, dates, or firm-specific details appear.


reasoning: The Board of Directors and Audit Committee are the grammatical subjects overseeing cybersecurity risks, which fits Board Governance. No specific facts qualify after filtering—the Senior Director of Information Technology title is not explicitly cybersecurity-specific, and the Audit Committee, CFO, and 'periodic updates' are all generic elements.


reasoning: The paragraph describes the company's internal risk management program and cybersecurity framework adoption, with the Board mentioned only briefly as part of oversight. It names NIST and ISO as recognized frameworks but contains no facts unique to Velo3D.


reasoning: The paragraph describes the company's internal product cybersecurity risk assessment and management processes, including framework adoption (ISO 21434) and certification, which are the company's own internal processes.


reasoning: The paragraph discusses the company's general approach to cybersecurity measures and acknowledges dependence on IT systems, which relates to internal processes. However, it contains no specific processes, frameworks, or activities - only high-level statements about cybersecurity importance and IT dependence that could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including third-party security testing and external assessments. It names two recognized standards (NIST Cybersecurity Framework and PCI DSS) but contains no facts unique to this specific company, making it Sector-Adapted.


reasoning: The paragraph describes the company's internal process for engaging external assessors and consultants as part of their information security program, covering activities like threat evaluation, forensic reviews, and security assessments.


reasoning: The paragraph describes the company's internal cybersecurity processes including training, policies, and third-party assessments, which fits Risk Management Process. No specific facts, named frameworks, or unique identifiers are present - the policy areas mentioned are generic categories and third-party consultants are unnamed.


reasoning: The paragraph describes the company's internal cybersecurity processes, specifically how its client-facing cybersecurity consulting practice supports internal security posture through threat intelligence, expert advice, and supplemental incident response capabilities.


reasoning: The paragraph describes the company's internal disclosure procedures and compliance programs for handling cybersecurity incidents, which constitutes the company's own risk management processes.


reasoning: This paragraph describes two actual cybersecurity incidents with specific dates, scope of impact (global shutdown, Canadian subsidiary), and response actions, which constitutes incident disclosure. Two specific dates (December 2021 and March 2024) qualify as hard verifiable facts, meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal cybersecurity controls, defensive approach, and monitoring tools, which constitutes risk management process disclosure. It contains no named frameworks, specific cybersecurity roles, dates, named products, or other verifiable facts that would distinguish it from generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal information security processes for identifying, assessing, and managing cybersecurity risks to their systems and data, which is a classic Risk Management Process disclosure. It contains no specific facts—no named roles, frameworks, dates, tools, or verifiable details—and could appear in any company's filing unchanged.


reasoning: This paragraph describes an actual cybersecurity incident including the timing, nature of the attack (access and exfiltration of data including employee PII), operational impact, and response actions, which clearly fits the Incident Disclosure category.


reasoning: The paragraph centers on the CISO as the primary subject, covering their qualifications (20 years experience), reporting structure, and responsibilities, with processes described as activities the CISO implements rather than standalone company processes.


reasoning: The paragraph describes the company's internal processes for conducting risk assessments, evaluating security posture, and continuous threat monitoring with deployed technologies. The CISO is mentioned in context of what the function does (oversight of processes), not the person's qualifications, so this falls under Risk Management Process per the Person-vs-Function Test.


reasoning: The paragraph describes the cybersecurity team's ongoing activities—monitoring, vulnerability scanning, penetration testing, threat intelligence, and incident escalation protocols—rather than focusing on Mr. Daly's personal qualifications or career history. Applying the person-vs-function test, the paragraph would still make sense if Mr. Daly's name were removed, indicating it is about the function/process rather than the person.


reasoning: The paragraph describes the company's internal risk management processes, with third-party engagement as a component of those processes rather than vendor oversight as the central topic. No named firms, frameworks, dates, or other specifics appear—only unnamed 'cybersecurity assessment firm' and generic practices like 'regular system audits' and '24-hour monitoring.'


reasoning: This paragraph is a materiality disclaimer stating that no cybersecurity incidents have materially affected the company's business strategy, results of operations, or financial condition, which the guidelines explicitly classify as Strategy Integration even when boilerplate. The cross-reference to Risk Factors appended to the materiality assessment does not change the classification.


reasoning: The paragraph describes the company's internal processes for monitoring threats, assessing incident severity, and escalating cybersecurity issues through defined reporting channels. The focus is on operational procedures rather than board oversight, management qualifications, or a specific incident.


reasoning: The paragraph focuses on the CISO's qualifications, credentials, and career history, making it about the person rather than the function or process.


reasoning: The paragraph describes board and committee oversight structures, including the board enterprise risk committee's cybersecurity subcommittee review process and the board's engagement with the CISO on cybersecurity matters.


reasoning: The paragraph discusses cybersecurity insurance coverage, which falls under Strategy Integration as it addresses financial protection and resources related to cyber risk. It contains no specific facts—no named insurer, policy limits, coverage amounts, or other verifiable details—making it generic boilerplate that could appear in any company's filing.


reasoning: This paragraph describes the company's general technology environment and data holdings (IT systems, cloud, industrial control systems, types of data collected) without addressing board oversight, management roles, risk management processes, third-party risk, incidents, or strategy/materiality. It is contextual background about the attack surface rather than a substantive cybersecurity disclosure under the defined categories.


reasoning: The paragraph focuses on the Enterprise Security Director's qualifications, credentials, and experience (26+ years, CISSP certification, professional memberships), which fits the person-focused criteria for Management Role under the person-vs-function test.


reasoning: The paragraph describes the company's internal processes for cyber risk management oversight, administration, and incident response, including how management works with third-party providers and threat intelligence sources. While management is the grammatical subject, the focus is on what the management function does rather than individual qualifications.


reasoning: The first sentence describes the company's systems and processes for overseeing third-party vendors and service providers, making vendor oversight the central topic. The second sentence briefly mentions cyber insurance, which would normally be Strategy Integration, but the paragraph's primary focus is third-party risk management. No specific facts, named frameworks, or verifiable details are present.


reasoning: The paragraph describes the company's internal cybersecurity risk management program components, which is a classic Risk Management Process disclosure. It contains no specific facts (no named roles, frameworks, dates, tools, or third-party firms), no named standards, and consists entirely of generic descriptions that could apply to any company.


reasoning: The paragraph centers on the VP of IT's qualifications, tenure, responsibilities, and reporting relationships, making it about the management role rather than internal processes. It contains two hard verifiable facts: the cybersecurity-specific title (VP of IT/Information Security Officer) and the specific tenure duration (two years).


reasoning: This paragraph describes an actual cybersecurity incident with specific details about what happened (CrowdStrike-caused systems disruption), when it occurred (July 19, 2024), and the response actions taken, meeting the definition of Incident Disclosure.


reasoning: The paragraph focuses on identifying the management roles (CTO and CISO) responsible for the cybersecurity program, their qualifications (25 years of experience), and the cross-functional team composition supporting them—making Management Role the appropriate category. The specificity is Firm-Specific due to the cybersecurity-specific titles (CISO, CTO) and detailed departmental team composition, though it lacks two or more hard verifiable facts needed for Quantified-Verifiable.


reasoning: This paragraph contains a materiality disclaimer stating that cybersecurity risks have not materially affected the company's business strategy, results of operations, or financial condition, which falls under Strategy Integration per the tiebreaker rules. The cross-reference to Risk Factors appended to the materiality assessment does not change the classification.


reasoning: The paragraph focuses centrally on vendor oversight, with three of four sentences describing due diligence processes, risk assessments, and contractual requirements imposed ON third-party providers, meeting the threshold for Third-Party Risk rather than internal Risk Management Process.


reasoning: This paragraph contains a materiality assessment stating the company has not experienced material adverse effects from cybersecurity threats to date, followed by a cross-reference to Risk Factors. Under the guidelines, materiality disclaimers and conclusions fall under Strategy Integration even when boilerplate in nature.


reasoning: The paragraph primarily focuses on management roles—the IT Director's qualifications, responsibilities, and reporting line to the CFO, along with the CFO's reporting duties. While the first sentence mentions Board and Audit Committee oversight, the majority of the content (3 of 4 sentences) centers on management roles, triggering the tiebreaker for Management Role. No cybersecurity-specific titles (CISO, CTO, CIO, VP of IT/Security, Director of IT Security) or other firm-specific facts appear—'IT Director' is a general IT role, not a cybersecurity-specific title, and 'CFO' and 'Audit Committee' are generic.


reasoning: The Board and Audit Committee are the grammatical subjects throughout, describing oversight responsibilities, delegated monitoring roles, and briefing cadences for cybersecurity risk—classic board governance content. CTO is a cybersecurity-specific title that qualifies as a firm-specific fact, but there are no hard verifiable facts (dates, amounts, named firms, or tools) to reach Quantified-Verifiable.


reasoning: This paragraph is a pure cross-reference directing readers to the Risk Factors section, containing no substantive cybersecurity disclosure.


reasoning: The paragraph describes the company's internal security capability structure, covering both cybersecurity and product security functions, which constitutes a risk management process disclosure. It contains no named frameworks, specific roles, dates, numbers, or other verifiable facts—only generic descriptions that could apply to any technology company.


reasoning: This paragraph contains a materiality disclaimer stating the company has not experienced material cybersecurity incidents, which falls under Strategy Integration per the guidelines for materiality conclusions without incident narrative.


reasoning: The audit committee is the primary grammatical subject throughout the paragraph, which describes its oversight of cyber risks, reporting relationships, and briefing cadence with Apollo's CSO or CISO presenting at least annually.