content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company's internal processes, including employee training, cyber insurance, and vendor contract review procedures.

provider: google

stage: benchmark


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risk, including integration into the enterprise risk management program, evaluations of IT infrastructure, and compliance audits.


reasoning: The paragraph describes management's approach to the cybersecurity program, specifically mentioning a 'three lines of defense' model and how the organization monitors, assesses, and responds to incidents. This focuses on the internal processes and framework used by the company.


reasoning: The paragraph describes the company's internal cybersecurity incident response plan, protocols, and tabletop exercises, which are core components of the risk management process.


content_category: Board Governance

reasoning: The paragraph discusses the reporting cadence and oversight structure involving the ITSC and Chief Information Officer providing updates to the Board of Directors, making it primarily about Board Governance.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, specifically detailing the frameworks and standards it uses to identify, assess, and manage cybersecurity risks.


reasoning: The paragraph explicitly discusses the Board of Directors and the Audit Committee's oversight responsibilities regarding cybersecurity risks.


reasoning: The paragraph focuses on the Board's oversight of cybersecurity, specifically detailing the briefing cadence and strategy discussions involving the Board and senior management.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and prioritizing cybersecurity risks, including the use of third-party assessors, internal audits, and testing exercises.


reasoning: The paragraph describes the company's internal cybersecurity strategy and risk management processes, specifically noting its alignment with the NIST Cybersecurity Framework.


reasoning: The paragraph focuses entirely on the Audit Committee's oversight responsibilities, briefing cadence, and interactions with the CISO regarding cybersecurity risk management.


content_category: Strategy Integration

reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity threats and includes boilerplate disclaimers about potential future impacts.


content_category: Incident Disclosure

reasoning: The paragraph explicitly describes a past cybersecurity incident, including the date it occurred, the operational impact, response actions taken, and the specific financial losses incurred.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including ERM integration, specific security controls, training, and external assessments.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity incidents and ongoing risks, which falls under Strategy Integration according to the guidelines.


reasoning: The paragraph explicitly describes a past cybersecurity incident from April 2022, detailing its operational impact, data exfiltration, financial consequences, and subsequent remediation efforts.


reasoning: The paragraph describes the company's internal processes regarding disclosure controls and insider trading compliance programs related to cybersecurity incidents.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity incidents, which falls under Strategy Integration according to the guidelines.


content_category: Management Role

reasoning: The paragraph primarily describes the reporting responsibilities and cadence of specific management roles (CIO, CISO, VP of Product Security) to board committees.


reasoning: The paragraph details the company's internal cybersecurity risk management program, including specific assessment toolkits, training, and incident response planning.


reasoning: The paragraph describes the company's internal risk management processes, specifically the use of third-party experts to conduct risk assessments, tabletop exercises, and audits.


reasoning: The paragraph focuses on the management structure of the cybersecurity team, identifying the CISO, reporting directors, and detailing the specific professional certifications held by the team members.


content_category: Third-Party Risk

reasoning: The paragraph is entirely focused on the company's use of third-party providers and its processes for identifying and overseeing cybersecurity risks presented by these vendors and service providers.


reasoning: The paragraph consists of a standalone materiality conclusion regarding past cybersecurity challenges, followed by a standard cross-reference to the Risk Factors section.


reasoning: The paragraph focuses entirely on the educational backgrounds, professional experience, and certifications of the CISO and CIO, which clearly falls under Management Role.


reasoning: The paragraph provides a standalone materiality conclusion regarding past incidents and the potential financial/strategic impact of future incidents, which falls under Strategy Integration.


reasoning: The paragraph describes the company's internal security awareness and training programs, including phishing tests and mandatory education, which are core components of its risk management process.


reasoning: The paragraph focuses on the reporting cadence between management and a board committee regarding cybersecurity risks and incidents, which falls under board oversight.


reasoning: The paragraph describes the company's participation in an external benchmarking group to support its privacy and risk management processes.


reasoning: The paragraph details the specific management-level committees and officers responsible for cybersecurity oversight, including their escalation and reporting lines.


reasoning: The paragraph describes the company's internal processes, tools, and threat intelligence activities for managing cybersecurity risks.


reasoning: The paragraph primarily discusses the materiality of past cybersecurity incidents, concluding that none have materially affected the company, which aligns with Strategy Integration.


reasoning: The paragraph discusses the potential material impact of cybersecurity threats on the company's business strategy and financial condition, along with boilerplate disclaimers and a cross-reference to Risk Factors.


reasoning: The paragraph explicitly details the Board and Audit Committee's oversight of the security program, including reporting cadences and the integration of cybersecurity into the top enterprise risks.


reasoning: The paragraph describes how the enterprise risk management team works with the CSO and IT risk management team to evaluate and address cybersecurity risks, focusing on internal processes.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including risk assessments, vulnerability identification, and continuous threat monitoring, despite briefly mentioning the CISO's oversight.


reasoning: The paragraph provides a comprehensive overview of the company's internal cybersecurity risk management processes, detailing its technical safeguards, incident response planning, third-party risk management, and training programs.


reasoning: The paragraph serves as a high-level introduction to the company's cybersecurity program and its goals of preserving confidentiality, integrity, and availability of data.


reasoning: The paragraph provides a comprehensive overview of the company's cybersecurity risk management processes, including systems, training, and incident response planning, while also detailing the specific qualifications and experience of the CISO and COO who oversee the program.


reasoning: The paragraph explicitly discusses the company's internal processes for assessing and managing cybersecurity risks and their integration into the overall risk management system.


content_category: None/Other

reasoning: The paragraph consists entirely of forward-looking disclaimers and boilerplate risk factor language regarding potential future cyber attacks and their possible material adverse effects, containing no substantive disclosure about the company's actual cybersecurity program.


reasoning: The paragraph describes an internal cybersecurity process, specifically the provision of annual training for employees handling sensitive data.


reasoning: The paragraph focuses on the specific management roles (ISO, Senior Risk Officer) and the cross-functional team composition responsible for implementing and maintaining the cybersecurity program.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including its Incident Response Policy, system monitoring, and employee training programs.


reasoning: The paragraph describes the organizational structure of the company's cybersecurity risk management and the implementation of an incident response plan, focusing on the function rather than the specific qualifications of the management personnel.


reasoning: The paragraph details the company's internal cybersecurity risk assessment process, including asset identification, criticality assessment, and control selection.


reasoning: The paragraph consists of forward-looking disclaimers and a standalone materiality conclusion stating that cybersecurity incidents have not materially affected the business to date, which falls under Strategy Integration.


reasoning: The paragraph describes the integration of cybersecurity risks into the company's enterprise risk management program and the annual assessment process.


reasoning: The paragraph provides a standalone materiality conclusion stating that past cybersecurity incidents have not materially affected the company's business strategy or financial condition, followed by cross-references to Risk Factors.


reasoning: The paragraph focuses on the specific management roles (CIO and SDIS) responsible for cybersecurity, detailing their reporting structure, years of experience, and professional certifications.


reasoning: The paragraph describes the internal process of reviewing the company's Cybersecurity Policy by specific internal teams, which falls under risk management processes.


reasoning: The paragraph focuses entirely on the qualifications, experience, and responsibilities of management roles (CISO and CIO), making Management Role the most appropriate category.


reasoning: The paragraph describes the company's internal procedures for detecting, analyzing, mitigating, and escalating cybersecurity incidents, which falls under the risk management process.


reasoning: The paragraph primarily discusses the Board of Directors' oversight structure for cybersecurity risk and the reporting relationship between the Chief Risk Officer and the Board.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight of cybersecurity, detailing their meeting cadences with the CISO and CIO, onboarding briefings, and external expert sessions.


reasoning: The paragraph briefly mentions a past ransomware incident primarily to state its lack of material impact on the business and its effect on IT initiative timelines, fitting the Strategy Integration category.


reasoning: The paragraph explicitly identifies the management roles responsible for cybersecurity (CDIO and VP of Platforms, Infrastructure and Cybersecurity) and details their professional experience and qualifications.


reasoning: The paragraph focuses entirely on the Chief Security Officer (CSO), detailing their responsibilities, reporting lines, tenure, and professional background.


reasoning: The paragraph focuses on the responsibilities of the CDO in directing information security activities and leading the cybersecurity risk management strategy.


reasoning: The paragraph focuses on the role of the 'Director – Information Systems' and management's involvement in implementing the cybersecurity program and incident response, making Management Role the most appropriate category.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management program, its integration into the enterprise risk management program, and its foundational policies and procedures.


reasoning: The paragraph focuses entirely on the company's oversight of cybersecurity risks associated with third parties and their systems.


reasoning: The paragraph primarily discusses the Risk Committee's oversight of cybersecurity and the reporting structure from various management-level subcommittees up to the Board.


reasoning: The paragraph focuses entirely on the oversight and management of cybersecurity risks associated with vendors and third-party service providers.


reasoning: The paragraph discusses the general cybersecurity threat landscape and the potential material adverse effect of incidents on the company's operations and performance, which falls under strategy integration and business impact.


reasoning: The paragraph describes the company's internal cybersecurity risk mitigation efforts, including its adoption of specific frameworks and regulatory standards to evaluate and improve its processes.


reasoning: The paragraph describes the company's internal cybersecurity risk management activities, such as penetration testing, vulnerability assessments, and threat intelligence reviews.


reasoning: The paragraph describes the company's internal cybersecurity processes, including asset protection, environment monitoring, and vulnerability testing.


reasoning: The paragraph explicitly identifies the management roles (CISO and Sr. Director of Information Security) responsible for monitoring and managing cybersecurity risks, making Management Role the most appropriate category.


reasoning: The paragraph describes internal cybersecurity training, phishing simulations, and tabletop exercises, which are core components of the company's risk management process.


reasoning: The paragraph explicitly describes a past cybersecurity intrusion that occurred on February 16, 2022, detailing the resulting network disruption and the company's response actions.


reasoning: The paragraph details the company's internal processes for identifying and managing cybersecurity risks, including risk assessments, employee training, and policy distribution.


reasoning: The paragraph explicitly describes a past cybersecurity incident that occurred in November 2022, detailing the scope of access (PII), operational impact (loan origination delays), response actions, and subsequent litigation.


reasoning: The paragraph focuses on the Board of Directors and its specific committees (RAC and TEC) providing oversight and direction for the cybersecurity risk management programs.


reasoning: The paragraph primarily focuses on the specific management roles (Director of Enterprise Information Security, Information Security Officer) responsible for cybersecurity, detailing their reporting structure and specific years of professional experience.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risks, including conducting annual risk assessments, enhancing IT infrastructure, and engaging external assessors.


reasoning: The paragraph details the company's internal processes for identifying, assessing, and responding to cybersecurity threats, including the specific workflow and cross-functional teams involved in incident response.


reasoning: The paragraph is a standalone boilerplate disclaimer stating that the company has not experienced any material cybersecurity incidents affecting its business strategy or financial condition.


reasoning: The paragraph explicitly describes a past cybersecurity incident, detailing the dates of occurrence and reporting, the operational impact on production and shipments, and the subsequent recovery actions.


reasoning: The paragraph describes the company's internal cybersecurity training and use of technology tools to mitigate risks, which are components of its risk management process.


reasoning: The paragraph primarily focuses on the Audit and Finance Committee's oversight responsibilities and the updates it receives from management regarding cybersecurity risks.


reasoning: The paragraph details the company's internal procedures for evaluating and maturing its cybersecurity program, including vulnerability management, internal audits by the InfoSec team, and external assessments.


reasoning: The paragraph focuses entirely on the qualifications, career history, tenure, and responsibilities of the Caterpillar CIO, making Management Role the most appropriate category.


reasoning: The paragraph focuses on the board of directors and its committees (enterprise risk committee, cybersecurity subcommittee) overseeing cybersecurity risks and engaging with the CISO.


reasoning: The paragraph primarily focuses on identifying the management roles responsible for cybersecurity (CISO, CRO, CTO), detailing their reporting lines, committee memberships, and specific professional qualifications and experience.


reasoning: The paragraph consists of a boilerplate materiality disclaimer regarding cybersecurity threats and incidents, followed by a cross-reference to the Risk Factors section, which falls under Strategy Integration.


reasoning: The paragraph focuses on the Board of Directors and the Audit Committee's oversight of cybersecurity risks, including the reporting cadence from management.


reasoning: The paragraph focuses entirely on the qualifications, experience, and educational backgrounds of the executives leading the cybersecurity program, which aligns perfectly with the Management Role category.


reasoning: The paragraph focuses entirely on the oversight of third-party service providers, including due diligence, ongoing monitoring, and incident notification requirements for vendors.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats and their impact on the company's business strategy and financial condition, along with a cross-reference to risk factors.


reasoning: The paragraph focuses on assessing the materiality of past cybersecurity incidents and ongoing threats on the company's financial condition and operations, which falls under Strategy Integration.


reasoning: The paragraph focuses entirely on the Chief Information Security Officer (CISO), detailing their responsibilities, tenure, and professional background.


reasoning: The paragraph describes the company's internal cybersecurity program, control assessments, policies, and training procedures, which are core components of its risk management process.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity incidents and risks, followed by a cross-reference to the Risk Factors section, which falls under Strategy Integration.


reasoning: The paragraph explicitly details the reporting lines of the CISO to a specific management steering body and ultimately to the Audit Committee, which aligns with the Management Role category.


reasoning: The paragraph focuses on management-level oversight, specifically detailing the roles of the CRO, CIO, and interim CISO within the executive risk committee (ERC).


reasoning: The paragraph details the company's internal security practices and defensive measures, such as implementing zero trust, MFA, and EDR, which were adopted to strengthen its risk management program following a past cybersecurity event.


reasoning: The paragraph describes the integration of cybersecurity risks into the company's enterprise risk management program and the general process for identifying, assessing, and mitigating these risks.


reasoning: The paragraph describes the company's risk management process, specifically its practice of engaging external consultants and assessors to support its information security program.


reasoning: The paragraph describes the company's internal cybersecurity processes, specifically focusing on employee training, phishing simulations, and information security policies.


reasoning: The paragraph focuses entirely on the Enterprise Security Director, detailing her responsibilities, reporting lines, experience, and certifications.


reasoning: The paragraph explicitly describes a past cybersecurity incident, detailing the date, the affected system, the response actions taken, and the scope of the impact.


reasoning: The paragraph explicitly describes a past ransomware incident, including the specific date of discovery and the subsequent containment and restoration actions taken by the company.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and past incidents, stating they have not materially affected the company's business strategy or financial condition, which falls under Strategy Integration.


reasoning: The paragraph describes the reporting cadence and topics presented to the Audit Committee of the Board regarding the cybersecurity program, making it a Board Governance disclosure.


reasoning: The paragraph focuses on the Board's oversight of cybersecurity, detailing the reporting cadence from committees and management, as well as continuing education presentations to the Board.


reasoning: The paragraph explicitly describes a past cybersecurity incident that occurred in April 2022, detailing its operational impact, data exfiltration, and subsequent remediation efforts.


reasoning: The paragraph is a pure cross-reference to other sections of the filing (Item 1A and Item 7) and contains no substantive cybersecurity disclosure.


reasoning: The paragraph describes the company's process for gathering threat intelligence and maintaining visibility into current events by engaging with external organizations and communities, which is a core component of its risk management process.


reasoning: The paragraph explicitly focuses on the oversight, evaluation, and mitigation of cybersecurity risks associated with third-party service providers.


reasoning: The paragraph primarily describes the company's internal processes, tools, and teams (SOC, CSIRT) used to assess, identify, and manage cybersecurity risks, including vulnerability testing and NIST assessments.


reasoning: The paragraph primarily details the Board of Directors' and its specific committees' (Governance and Compliance, Technology, Audit) oversight of cybersecurity risks and the reporting cadence from management.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including the adoption of industry frameworks, security controls, and employee training.


reasoning: The paragraph explicitly describes a past cybersecurity incident that occurred in March 2021, detailing its operational impact on brewery operations and shipments, as well as the specific financial costs incurred.


reasoning: The paragraph primarily details the reporting structure and roles of management, specifically identifying the CISO, Chief Risk Officer, and Risk Management Council, and how they report up to the Board Risk Committee.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, its foundational frameworks, and its integration into the broader enterprise risk management framework.


reasoning: The paragraph is a biography of a non-cybersecurity executive officer and contains no substantive cybersecurity disclosure.


reasoning: The paragraph primarily focuses on the responsibilities, reporting lines, and oversight structures of management, specifically detailing the roles of the CIO, CISO, and various internal information security committees.


reasoning: The paragraph describes the company's overall Cybersecurity Program, its risk-based approach, and its objectives for managing vulnerabilities, which falls under internal risk management processes.


reasoning: The paragraph primarily focuses on the Audit Committee's oversight of cybersecurity risks and the expertise of its members, while also detailing how specific management roles report to the committee.


reasoning: The paragraph describes the company's Information Security Program and its alignment with regulatory requirements and industry frameworks, which falls under internal risk management processes.


reasoning: The paragraph describes the company's internal incident response and escalation procedures, detailing how specific internal teams (IRT and CIEC) handle threat communication and materiality assessments.


reasoning: The paragraph describes a specific historical cybersecurity incident involving a third-party vendor, including the date of notification and the scope of affected data.


reasoning: The paragraph focuses on the CTO's reporting lines, detailing the cadence and content of cybersecurity briefings provided to the Audit and Finance Committee and executive leadership.


reasoning: The paragraph describes the company's internal processes for protecting sensitive data through encryption methods.


reasoning: The paragraph provides a standalone materiality conclusion stating that the company has not experienced any material cybersecurity incidents to date.


reasoning: The paragraph describes the company's internal risk management processes, specifically the use of third-party service providers to test and audit internal cybersecurity controls.


reasoning: The paragraph details the company's internal cybersecurity processes, including the adoption of the CIS framework, audit cadences, vulnerability testing, and employee training.


reasoning: The paragraph details the company's internal cybersecurity policies, controls, and various security domains covered by its risk management program, such as vulnerability management, incident response, and network security.


reasoning: The paragraph explicitly describes a past ransomware incident, detailing when it occurred, the specific systems affected, the findings of the investigation regarding data exfiltration, and the overall materiality of the event.


reasoning: The paragraph explicitly describes a past cybersecurity incident, including the date of occurrence, the nature of the attack (encryption and exfiltration), and the immediate response actions taken.


reasoning: The paragraph focuses on management-level roles and committees, specifically the Executive Cybersecurity Steering Committee and local Information Security Officers, detailing their responsibilities in overseeing and monitoring cybersecurity risks.


reasoning: The paragraph discusses the company's internal investments in IT security capabilities, preventive measures, and growing the security organization, which falls under risk management processes.


reasoning: The paragraph primarily describes the responsibilities, composition, and escalation processes of a management-level Compliance Committee and the Chief Information Officer in managing cybersecurity risks.


reasoning: The paragraph describes the company's internal cybersecurity policies, framework alignments, and certification processes, which are core components of its risk management program.


reasoning: The paragraph consists entirely of a boilerplate materiality conclusion regarding cybersecurity risks and past incidents, which falls under Strategy Integration.


reasoning: The paragraph details the company's internal cybersecurity controls, risk assessment processes, and security awareness training program.


reasoning: The paragraph focuses on the management structure for cybersecurity, specifically detailing the VP of IT's responsibilities, reporting lines, committee memberships, and years of experience.


reasoning: The paragraph describes the company's internal product cybersecurity risk assessment and management processes, including its alignment with specific industry standards and certifications.


reasoning: The paragraph explicitly identifies the management roles (Acting CISO and Acting CIO) responsible for cybersecurity, detailing their combined experience and reporting structure.


category_confidence: medium

reasoning: The paragraph provides introductory context regarding the company's operational reliance on information technology systems and the types of sensitive data it stores, establishing the business context for cybersecurity risks.


reasoning: The paragraph describes the company's internal information security program, including its policies, procedures, and annual cyber risk assessments, which squarely fits the Risk Management Process category.


reasoning: The paragraph describes the company's internal cybersecurity program, including its layered security controls, third-party risk oversight processes, and employee training.


reasoning: The paragraph explicitly identifies the Chief Security and Trust Officer and describes their reporting line to the executive leadership team, making Management Role the most appropriate category.


reasoning: The paragraph's grammatical subjects are the Chief Information Officer and General Counsel, detailing their reporting lines and the specific cybersecurity topics they review with the Board.


reasoning: The paragraph primarily describes the management team's responsibilities in overseeing the cybersecurity program, receiving internal briefings from specific committees, and reporting to the board.


reasoning: The paragraph primarily describes the company's Incident Response Plan, its framework, and its integration with crisis management, which falls under internal risk management processes.


reasoning: The paragraph focuses entirely on the qualifications, educational background, certifications, and years of experience of the CISO, the cybersecurity team, and other executives.


reasoning: The paragraph focuses on the qualifications, experience, and responsibilities of management roles, specifically the CTO, CSO, and CIO, in overseeing the cybersecurity program.


reasoning: The paragraph outlines the company's internal processes for assessing and managing cybersecurity risks, including risk assessments, incident response planning, and integration into the overall risk management system.


reasoning: The paragraph describes the scope and response actions of an actual cybersecurity incident, specifically noting the potential exfiltration of personal information by ransomware actors and subsequent regulatory notifications.


reasoning: The paragraph focuses on the roles, reporting structure, and specific years of experience of the Information Security Director and CIO.


reasoning: The paragraph primarily describes the Audit Committee's oversight of cybersecurity risks, including its reporting cadence and engagement with specific management roles.


reasoning: The paragraph explicitly describes a past cybersecurity incident, including the date it occurred, the systems affected, and the resulting operational and financial impacts.


reasoning: The paragraph outlines the governance structure for cybersecurity risk, detailing the oversight responsibilities of the Board Risk Committee and the reporting cadence from management back to the board.


reasoning: The paragraph consists entirely of boilerplate disclaimers regarding the limitations of security systems and a cross-reference to the Risk Factors section, providing no substantive cybersecurity disclosure.


reasoning: The paragraph describes a specific past ransomware attack, including when it occurred, the operational impact, response actions taken, and the ultimate materiality of the event.


reasoning: The paragraph exclusively details the professional backgrounds, years of experience, degrees, and certifications of the CISO, CIO, CRO, and other management figures, clearly falling under the Management Role category.


reasoning: Although a management role (GPO) is the subject, the paragraph focuses entirely on the processes and activities the role executes, such as managing privacy software and conducting privacy impact assessments, making it a Risk Management Process description.


reasoning: The paragraph primarily details the identification, organizational structure, and reporting lines of management roles, specifically focusing on the CISO and CIO.


reasoning: The paragraph describes the company's internal risk management and threat intelligence processes, specifically highlighting how it leverages its own client-facing cybersecurity experts to bolster internal defenses and incident response.


reasoning: The paragraph is entirely dedicated to describing the company's vendor management program and how it assesses and oversees cybersecurity risks associated with third-party service providers.


reasoning: The paragraph details the company's internal IT and security processes, specifically outlining how security controls, user access reviews, and disaster recovery plans are applied to applications covered and not covered by their internal Service Level Agreement (SLA).


reasoning: The paragraph provides a detailed narrative of a specific past cybersecurity incident, including dates, the software involved, the type of data compromised, and the response actions taken.


reasoning: The paragraph focuses on the roles, responsibilities, and qualifications of management personnel, specifically the CAO and Enterprise Security Director, in overseeing the cybersecurity program.


reasoning: The paragraph primarily discusses the potential impact of cybersecurity risks, cross-references risk factors, and provides a standalone materiality conclusion regarding past incidents and expenses.


reasoning: The paragraph primarily describes the company's internal processes for managing cybersecurity risks and their integration into the overall Enterprise Risk Management process, despite briefly mentioning the management roles that oversee it.


reasoning: The paragraph focuses entirely on the qualifications, titles, educational backgrounds, and career histories of the management team members overseeing cybersecurity.


reasoning: The paragraph describes the company's internal cybersecurity processes, including threat monitoring, vulnerability scanning, and the use of managed service providers, which falls under Risk Management Process.


reasoning: The paragraph explicitly describes a real cybersecurity incident involving the MOVEit Transfer vulnerability, detailing the scope of the data exposure, the third-party vendor's involvement, response actions taken, and the overall impact on the company.


reasoning: The paragraph primarily focuses on the CIO and SIRT, detailing their specific expertise, monitoring responsibilities, and reporting cadence to the Audit Committee.


reasoning: The paragraph primarily describes the company's internal organizational structure and processes for managing cybersecurity risk, including its integration into the broader ERM program and the specific IRM program.


reasoning: The paragraph is entirely dedicated to the company's processes for evaluating and monitoring cybersecurity risks associated with third-party service providers and vendors.


reasoning: The paragraph explicitly discusses the Board of Directors and the Audit Committee's oversight of the cybersecurity risk management program, including their briefing cadence.


reasoning: The paragraph details the company's internal incident response workflow, including threat identification, severity assessment, and escalation procedures involving specific roles and cross-functional teams.


reasoning: The paragraph focuses entirely on the CISO, detailing their reporting structure, tenure, educational background, and specific professional certifications.


reasoning: The paragraph focuses entirely on the qualifications, experience, and specific certifications of the IT Director and IS Director, making it a clear fit for Management Role.


reasoning: The paragraph explicitly identifies the Chief Information Security Officer (CISO) as the individual responsible for the cybersecurity component of the risk management program and details their reporting line to a specific board committee.


reasoning: The paragraph primarily focuses on the management hierarchy responsible for cybersecurity, detailing specific roles (CTO, VP of IT, Senior Director of IT Security) and their qualifications, before describing their reporting cadence to the Board.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight responsibilities, the specific cyber expertise of two directors, and the reporting cadence from the CISO to the committee.


reasoning: The paragraph focuses entirely on the oversight of cybersecurity risks presented by third parties, including vendors and service providers, and the contractual terms used to ensure they maintain security programs.


reasoning: The paragraph primarily discusses the Board of Directors' risk oversight and the Audit Committee's cadence for receiving cybersecurity updates, making Board Governance the most appropriate category.


reasoning: The paragraph explicitly identifies management roles (CISO and Director of IT Security, Risk and Compliance) and details their professional experience and qualifications.


reasoning: The paragraph describes the company's internal risk assessment process, specifically the use of third-party experts and the internal audit team to evaluate their cybersecurity program.


reasoning: The paragraph primarily describes the company's internal processes for identifying, assessing, and managing cybersecurity risks, including its security controls, testing procedures, and incident response escalation protocols.


reasoning: The paragraph explicitly describes a past cybersecurity incident from 2017, detailing the nature of the attack and the specific populations affected, before discussing potential future impacts.


reasoning: The paragraph primarily details the qualifications of the CISO and the information security team, along with their reporting lines to specific board committees.


reasoning: The paragraph primarily focuses on the qualifications, reporting structure, and incident response responsibilities of the Vice President of Information Technology and Security and CIO.


reasoning: The paragraph focuses entirely on the Audit Committee of the Board of Directors and its oversight role, specifically receiving reports from management regarding cybersecurity threats and risks.


reasoning: The paragraph focuses entirely on the board's oversight of cybersecurity risks, specifically detailing the delegation to the Audit Committee and the creation and composition of a Cybersecurity Steering Committee.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats and their impact on business strategy and financial condition, followed by a cross-reference to risk factors.


reasoning: The paragraph explicitly identifies the management team and the COO as the parties responsible for managing cybersecurity risks and supervising external consultants.


reasoning: The paragraph primarily describes the company's cybersecurity policies, processes, and their integration into the overall risk management system based on recognized frameworks, despite brief introductory mentions of the board and management.


reasoning: The paragraph consists of a standalone materiality conclusion regarding cybersecurity threats and a cross-reference to the Risk Factors section, which falls under Strategy Integration.


reasoning: The paragraph describes internal processes related to governance, risk, and compliance policies and controls, which falls under Risk Management Process.


reasoning: The paragraph primarily details the roles, qualifications (15+ years of experience), and reporting structure of the CISO and CIDO, making Management Role the most appropriate category despite additional mentions of board oversight and risk processes.


reasoning: The paragraph describes the reporting cadence and topics presented to the Risk Committee, focusing on board-level oversight of the cybersecurity program.


reasoning: The paragraph describes the company's internal incident response process, specifically the use of third-party providers to supplement their capabilities.


reasoning: The paragraph explicitly identifies the management roles responsible for cybersecurity (CTO, SVP of IT & Security) and details their specific years of experience.


reasoning: The paragraph discusses the potential material impact of cybersecurity threats on the company's business strategy and financial condition, and includes a standalone materiality conclusion stating no material adverse effects have been experienced to date.


reasoning: The paragraph focuses on the management team, specifically Mr. Daly and his team's qualifications (CISSP, SANS certifications), as well as their reporting structure and oversight responsibilities.


reasoning: The paragraph is entirely focused on the oversight and vetting of third-party vendors, including contract language and compliance practices, making Third-Party Risk the most applicable category.


reasoning: The paragraph describes internal procedures for coordinating incident response activities and documenting security incidents, which falls under the company's risk management processes.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and mitigating cybersecurity threats, including monitoring, vulnerability simulation, and employee training.


reasoning: The paragraph explicitly describes a past security breach involving a third-party vendor and the exposure of patient data, including the specific date it was disclosed.


reasoning: The paragraph describes the company's internal risk management processes, specifically noting the use of third-party consultants for framework design, penetration testing, and threat monitoring.


reasoning: The paragraph primarily identifies the management roles (IT management team, COO, CFO, GC) responsible for assessing and managing cybersecurity risks, while briefly mentioning board committee oversight.


reasoning: The paragraph consists entirely of a standalone materiality conclusion regarding cybersecurity risks and their impact on business strategy and financial condition, followed by a cross-reference to the Risk Factors section.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including penetration testing, monitoring, risk assessments, and evaluating third-party risks as part of its overall framework.


reasoning: The paragraph focuses entirely on the qualifications, career history, and specific roles of the CISO and the Senior Vice President of Global Security, making it a clear fit for Management Role.


reasoning: The paragraph describes the company's internal risk management processes, specifically its engagement of a third-party firm to assist with system audits, threat assessments, and monitoring.


reasoning: The paragraph details the company's internal cybersecurity processes, including automated tools, testing, training, and third-party oversight mechanisms, which are core components of risk management.


reasoning: The paragraph focuses on the qualifications, experience, and responsibilities of the management team, specifically highlighting the Director of Information Technology.


reasoning: The paragraph describes the internal processes for monitoring, mitigating, and disclosing cybersecurity incidents, focusing on the activities and procedures executed by the InfoSec Leadership Team rather than their personal qualifications.


reasoning: The paragraph primarily details the reporting structure between the CTO and CISO, their oversight responsibilities, and the CTO's specific career experience, making Management Role the most appropriate category.


reasoning: The paragraph explicitly details the cybersecurity responsibilities of management personnel, including the Chief Business Officer and other executives, making it a Management Role disclosure.


reasoning: The paragraph describes the company's internal cybersecurity strategy, policies, and risk assessment activities, including penetration testing and audits.


reasoning: The paragraph consists entirely of a boilerplate disclaimer regarding general, unsuccessful cyber threats (e.g., 'bots') and a cross-reference to the Risk Factors section, containing no substantive disclosure about the company's cybersecurity program or a specific incident.


reasoning: The paragraph focuses on the roles of the CISO, CCO, and COO in forming an internal working group to implement the cybersecurity program and monitor threats, which aligns with the Management Role category.


reasoning: The paragraph discusses the potential business and financial impacts of cyber threats and includes a boilerplate materiality conclusion stating that past incidents have not materially impacted the business.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents, stating they have not materially affected the company's business strategy or financial condition, which falls under Strategy Integration.


reasoning: The paragraph explicitly states the company lacks the resources and expertise to manage cybersecurity risks, effectively disclosing the absence of a program rather than describing substantive cybersecurity processes.


reasoning: The paragraph details the company's internal controls, security awareness training, and disaster recovery testing used to assess and manage cybersecurity risks.


reasoning: The paragraph explicitly identifies a specific management role (Senior Principal Security and Infrastructure Architect) and details their professional experience and qualifications, fitting the Management Role category.


reasoning: The paragraph primarily describes the company's internal incident response planning and third-party risk assessment processes, including the CIRT's strategies and the CIO's vendor assessments.


reasoning: The paragraph explicitly describes a past cybersecurity incident, detailing the dates of occurrence and disclosure, the scope of the breach involving customer data, and the specific containment and response actions taken.


reasoning: The paragraph primarily describes the company's internal cybersecurity training programs, simulations, and tabletop exercises, which are core components of its risk management processes.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including safeguards, third-party assessments, and the adoption of the NIST framework, despite briefly mentioning the CIO.


reasoning: The paragraph focuses on the audit committee's oversight role and the reporting cadence regarding cybersecurity threats.


reasoning: The paragraph outlines the key features of the company's internal cybersecurity program, including its incident response plan, testing procedures, policies, and cross-functional risk management approach.


reasoning: The paragraph discusses the potential financial impact of cybersecurity risks, provides a boilerplate materiality conclusion regarding past incidents, and mentions cyber liability insurance.


reasoning: The paragraph outlines the components of the company's cybersecurity risk management program, including vulnerability management, training, and third-party oversight.


reasoning: The paragraph focuses on the Audit Committee and the Board of Directors' oversight of information security, including their meeting attendance and reporting cadence.


reasoning: The paragraph provides a boilerplate materiality conclusion regarding past cybersecurity risks and incidents, along with a cross-reference to the Risk Factors section.


reasoning: The paragraph primarily describes the company's internal incident response procedures and testing exercises, which are core components of its risk management process.


reasoning: The paragraph serves as an introductory statement acknowledging the importance of identifying, assessing, and managing cybersecurity risks, which falls under the risk management process category.


reasoning: The paragraph primarily focuses on the company's due diligence process for third-party providers, including evaluating their security posture and enforcing contractual security requirements.


reasoning: The paragraph describes the company's internal cybersecurity policies, incident response plan, and technical review processes, which are core components of its risk management program.


reasoning: The paragraph is a pure cross-reference to the Risk Factors section with no substantive cybersecurity disclosure or standalone materiality conclusion.


reasoning: The paragraph focuses entirely on how the Fund identifies and oversees cybersecurity risks associated with its use of third-party service providers.


reasoning: The paragraph primarily discusses the Board of Directors and its specific committees' oversight of cybersecurity risks, including the cadence of reports received from management.


reasoning: The paragraph discusses general state-level regulatory trends regarding privacy and cybersecurity standards, which is non-substantive background information rather than a description of the company's specific cybersecurity program or incidents.


reasoning: The paragraph focuses on the qualifications, experience, certifications, and responsibilities of specific management roles (CIO and CISO), making it a clear fit for Management Role.


reasoning: The paragraph explicitly describes two past cybersecurity incidents, detailing the dates, operational impacts, and response actions taken.


reasoning: The paragraph primarily focuses on the specific management roles (EVP of Global IT and eDiscovery Operations, VP CISO) responsible for cybersecurity risk management and details their reporting lines and responsibilities.


reasoning: The paragraph focuses exclusively on the company's processes for assessing and overseeing the cybersecurity of its vendors and service providers.


reasoning: The paragraph describes the company's internal processes and tools for identifying and assessing cybersecurity risks, including vulnerability assessments, penetration testing, and integration into overall risk assessment.


reasoning: The paragraph explicitly discusses the board of directors' active involvement and oversight regarding cybersecurity risk management, making Board Governance the most applicable category.


reasoning: The paragraph describes the internal process of conducting risk assessments and internal audits, focusing on the activities rather than the specific qualifications of the personnel.


reasoning: The paragraph focuses on the oversight activities of the CyTOC (a board committee) and the full Board, detailing the cadence and content of cybersecurity briefings they receive from management.


reasoning: The paragraph describes the composition of the Information Security Team (which is outsourced) and details its reporting line to the Principal Financial Officer, aligning with the Management Role category.


reasoning: The paragraph primarily details the reporting cadence and the specific content of cybersecurity briefings provided to the board of directors by the CTO.


reasoning: The paragraph primarily describes the company's internal incident management and reporting processes, detailing the specific management roles involved in the escalation chain before concluding with a standard materiality disclaimer.


reasoning: The paragraph discusses the potential material impact of cybersecurity risks on the company's business strategy and financial condition, along with a statement that no material incidents have occurred.


reasoning: The paragraph discusses the absence of past material incidents, the maintenance of cybersecurity insurance, and potential material adverse effects, which aligns with the Strategy Integration category.


reasoning: The paragraph consists entirely of boilerplate forward-looking disclaimers regarding potential cybersecurity risks and their possible impacts, containing no substantive disclosure about the company's actual cybersecurity program.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats and their potential impact on the company's business strategy and financial condition, which falls under Strategy Integration.


reasoning: The paragraph provides a standalone materiality conclusion regarding the impact of cyber threats on the business strategy and financial condition, which falls under Strategy Integration.


reasoning: The paragraph focuses entirely on management's role in cybersecurity, specifically detailing the title, qualifications, experience, reporting structure, and committee leadership of the Vice President, Global Cybersecurity.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including its incident response plans, business continuity management system, and disaster recovery exercises.


reasoning: The paragraph describes the company's internal processes for assessing, monitoring, and mitigating cybersecurity risks, including their integration into the overall enterprise risk management program.


reasoning: The paragraph is centrally focused on the company's oversight of third-party service providers, including assessing their cybersecurity practices and enforcing contractual requirements.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight of cybersecurity risks and the reporting they receive from management.


reasoning: The paragraph identifies the specific management role (Senior Director - Information Security) responsible for directing cybersecurity initiatives, alongside brief mentions of board oversight and incident response.


reasoning: The paragraph primarily describes the governance structure, focusing on board-approved committees (ITAC, ERM) chaired by board members, and the reporting cadence of cybersecurity officers to these oversight committees.


reasoning: The paragraph provides a boilerplate materiality conclusion regarding past cybersecurity risks and incidents, followed by a cross-reference to the Risk Factors section.


reasoning: The paragraph focuses entirely on the qualifications, experience, and certifications of the VP of IT, which clearly falls under the Management Role category.


reasoning: The paragraph primarily details the management-level committees and roles, specifically the CISO and CEO, responsible for overseeing the cybersecurity program and their reporting lines.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including controls, monitoring, testing, and framework adoption, executed by the Information Technology Department.


reasoning: The paragraph describes the company's internal risk management activities, specifically the CIO's process for reviewing risks with IT teams and the existence of a global incident response plan.


reasoning: The paragraph consists of a standalone materiality conclusion regarding cybersecurity threats and a cross-reference to the Risk Factors section, which falls under Strategy Integration.


reasoning: The paragraph explicitly describes a past cybersecurity intrusion that occurred on February 16, 2022, detailing the network disruption it caused and the response actions taken.


reasoning: The paragraph focuses on the qualifications, experience, and reporting structure of specific management roles (VP of IT and CFO) responsible for cybersecurity.


reasoning: The paragraph's grammatical subject is a management role (the CFO), and it describes the reporting lines and responsibilities of management (CFO, DIT, DIS) in briefing the board on cybersecurity developments.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and past threats, along with a cross-reference to the Risk Factors section.


reasoning: The paragraph describes the company's approach to identifying and managing cybersecurity risks, primarily through reliance on third-party service providers and consultants, followed by a boilerplate materiality disclaimer.


reasoning: The paragraph describes the company's internal Cybersecurity Plan, its objectives, and how it integrates with overall risk management to protect specific infrastructure and data.


reasoning: The paragraph focuses exclusively on the company's approach to identifying and managing cybersecurity risks presented by third parties, vendors, and service providers.


reasoning: The paragraph primarily focuses on the responsibilities, collaborative efforts, and reporting lines of the CISO, making Management Role the most appropriate category.


reasoning: The paragraph primarily discusses the audit committee's oversight of cybersecurity risks and the reporting cadence it maintains with management and specific security officers.


reasoning: The paragraph explicitly describes the scope, impact, and response actions of a specific cybersecurity incident, including data exfiltration and regulatory notifications.


reasoning: The paragraph describes the company's internal processes for identifying and assessing cybersecurity risks, specifically detailing how the GRC team integrates these threats into the overall risk assessment process.


reasoning: The paragraph focuses entirely on the Board of Directors' oversight of cybersecurity risks, its delegation to the Audit Committee, and the briefing cadence it maintains with management.


reasoning: The paragraph provides a generic introductory statement about the company's reliance on information technology and data processing, containing no substantive cybersecurity disclosures.


reasoning: The paragraph primarily details the composition, responsibilities, and reporting structure of management-level committees (IT/Cybersecurity Committee, Enterprise Risk Committee) and the specific roles of the CIO and CISO in overseeing cybersecurity.


reasoning: The paragraph describes the internal escalation and reporting process for cybersecurity incidents, detailing how incidents are routed to the Incident Response Team and the specific reporting chain (BCC to CLO to the Board).


reasoning: The paragraph consists of a section header and a generic description of the cybersecurity threat landscape, providing no substantive disclosure about the company's actual processes, strategy, or incidents.


reasoning: The paragraph outlines general steps in the company's incident response process, such as containment, remediation, and recovery.


reasoning: The paragraph focuses on the CTO's role, reporting structure, and specific educational and professional qualifications.


reasoning: The paragraph details the company's internal processes for identifying, assessing, and mitigating cybersecurity risks, including the use of various tools, threat assessments, and security controls.


reasoning: The paragraph explicitly details the management roles (CTO and CISO), their qualifications (25 years of experience), and the specific cross-functional teams responsible for overseeing and implementing the cybersecurity program.


reasoning: The paragraph details the components of the company's cybersecurity risk management program, including vulnerability management, incident response drills, and assessments against the NIST framework.


reasoning: The paragraph describes the company's internal processes for handling cybersecurity incidents, including its incident response program and escalation protocols.


reasoning: The paragraph explicitly discusses the Board of Directors and Audit Committee's oversight responsibilities regarding cybersecurity risks and the reporting cadence to the committee.


reasoning: The paragraph details the company's internal processes for managing cybersecurity incidents, including its incident response plan, team composition, and escalation procedures.


reasoning: The paragraph describes the company's internal information security processes designed to identify, assess, and manage cybersecurity risks to its systems and data.


reasoning: The paragraph focuses extensively on management roles, specifically detailing the titles, reporting lines, years of experience, and educational backgrounds of the VP/CIO and Director of Information Security, as well as the management committees they lead.


reasoning: The paragraph describes the company's internal safeguards, physical security controls, and disaster recovery plans, which are core components of its risk management process.


reasoning: The paragraph details the composition and responsibilities of specific management-level committees (TRCC and ERC) and roles (CISO, head of ERM) tasked with overseeing cybersecurity risks.


reasoning: The paragraph details the composition and reporting structure of a management-led Risk Committee, focusing on the specific management roles involved in cybersecurity oversight.


reasoning: The paragraph primarily details the reporting and escalation responsibilities of the CIO and specific management teams (Executive Leadership Team, Executive Response Team) regarding cybersecurity matters.


reasoning: The paragraph focuses on the management teams responsible for overseeing cybersecurity processes and details their professional qualifications and experience.


reasoning: The paragraph describes the company's internal processes for evaluating cybersecurity risks, detecting vulnerabilities, and notifying stakeholders, which falls under Risk Management Process.


reasoning: The paragraph focuses on the qualifications, title, and responsibilities of the management role (Vice President of Informatics) leading the cybersecurity program.


reasoning: The paragraph consists of a boilerplate materiality disclaimer regarding past cybersecurity threats and their potential impact on business strategy, operations, and financial condition.


reasoning: The paragraph explicitly details the CISO's responsibilities, tenure, and professional background, making it a clear description of management's role and qualifications.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity incidents, which falls under Strategy Integration according to the guidelines, despite the appended cross-references to Risk Factors.


reasoning: The paragraph primarily consists of a boilerplate materiality disclaimer stating that the company has not experienced any material cybersecurity incidents to date.


reasoning: The paragraph describes the company's internal cybersecurity processes, including third-party assessments, penetration testing, vulnerability remediation, and vendor risk assessments.


reasoning: The paragraph explicitly discusses the board of directors' and audit committee's oversight of cybersecurity risk, making Board Governance the most applicable category.


reasoning: The paragraph focuses on the management structure and personnel responsible for cybersecurity, specifically detailing the roles of the Chief Insurance Officer, the cybersecurity operations risk steering group, and the CISO's specific qualifications and tenure.


reasoning: The paragraph primarily focuses on the CISO's qualifications, role as IS Program Coordinator, and the management teams responsible for executing the information security program, making Management Role the most appropriate category.


reasoning: The paragraph is a purely forward-looking disclaimer about the potential hypothetical impacts of a data breach, containing no substantive disclosure about the company's actual cybersecurity program, governance, or incidents.


reasoning: The paragraph primarily focuses on the IT Director's role, qualifications, and reporting structure to the CFO, making Management Role the most applicable category despite brief mentions of Board oversight.


reasoning: The paragraph is a generic, forward-looking disclaimer about the potential operational impacts of hypothetical cybersecurity incidents, containing no substantive disclosure about the company's actual cybersecurity program.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity incidents and includes cross-references to the Risk Factors section, which falls under Strategy Integration.


reasoning: The paragraph describes the company's internal cybersecurity incident response policies and the specific escalation procedures to internal teams and committees.


reasoning: The paragraph is a pure cross-reference to the Risk Factors section and contains no substantive cybersecurity disclosure.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents and threats, which falls under Strategy Integration.


reasoning: The paragraph focuses on the qualifications, experience, and reporting structure of the management team responsible for cybersecurity, specifically detailing the backgrounds of the SVP of finance and accounting and the senior IT consultant.


reasoning: The paragraph discusses the potential material impact of cybersecurity risks on the company's financial condition and operations, concluding with a cross-reference to the Risk Factors section.


reasoning: The paragraph focuses on the Senior Vice President of Information Technology, detailing their experience, the team they lead, and their responsibilities in managing cybersecurity risks.


reasoning: The paragraph describes the company's internal continuous monitoring strategy, security metrics, and control assessments, which are core components of its risk management process.


reasoning: The paragraph details the Chief Information Officer's reporting cadence to the Audit Committee and provides specific information about the CIO's qualifications and years of experience, fitting the Management Role category.


reasoning: The paragraph focuses on the audit committee's oversight role and the cadence of cybersecurity briefings it receives.


reasoning: The paragraph focuses entirely on the qualifications, educational background, and career history of the CSO and CISO, fitting the Management Role category.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats and incidents, which falls under Strategy Integration.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and managing cybersecurity risks to its networks, systems, and data.


reasoning: The paragraph explicitly discusses the company's cybersecurity insurance coverage, which falls under Strategy Integration.


reasoning: The paragraph describes the internal process by which senior management identifies, assesses, and evaluates cybersecurity risks.


reasoning: The paragraph describes the integration of cybersecurity into the company's enterprise risk management program and the processes used to assess and manage these risks.


reasoning: The paragraph explicitly states the company is a blank check company with no operations and no cybersecurity personnel or processes of its own. Per the guidelines, SPACs and shell companies stating they have no formal processes are classified as None/Other.


reasoning: The paragraph details the components of the company's cybersecurity risk management program, including risk assessments, monitoring, training, and incident response planning.


reasoning: The paragraph describes the activities and processes used to identify and assess cybersecurity risks, such as monitoring, scanning, and analyzing threat intelligence. Although a specific management role is named, the focus is on what the program does rather than the individual's qualifications, making it a Risk Management Process.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, specifically mentioning penetration testing and external assessments aligned with industry frameworks.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats and includes a cross-reference to the Risk Factors section, which falls under Strategy Integration.


reasoning: The paragraph describes the integration of cybersecurity risks into the company's enterprise risk management program, which is a core component of internal risk management processes.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and their impact on business strategy and financial condition, along with a cross-reference to the Risk Factors section.


reasoning: The paragraph explicitly details the roles, reporting structure, and specific years of experience of the CISO and the IT Security team, which falls squarely under Management Role.


reasoning: The paragraph describes the company's internal protocols and communication plans for reporting cybersecurity incidents to management and the board, which is a component of its overall risk management and incident response process.


reasoning: The paragraph explicitly states that the company is a blank check company with no operations and no personnel or processes of its own for cybersecurity. Per the guidelines, SPACs stating they have no formal processes are classified as None/Other.


reasoning: The paragraph describes the high-level governance structure for cybersecurity, specifically noting the oversight roles of the Board and the CFO.


reasoning: The paragraph focuses on the reporting responsibilities of a specific management role (SVP of IT) regarding cybersecurity matters.


reasoning: The paragraph details the composition of a management-level committee (the ISO Committee) and lists the specific executive roles, including the CISO and CTO, that participate in it.


reasoning: The paragraph primarily details a management-level committee (Information Technology Steering Committee), its composition including specific roles like the CIO, CTO, and ISO, and their reporting lines to the board.


reasoning: The paragraph describes the company's internal processes for identifying and evaluating cybersecurity risks, including the formation of a specific committee, vulnerability testing, and the use of third-party vendors.


reasoning: The paragraph discusses the materiality of past incidents and potential future impacts, concluding with a cross-reference to Risk Factors, which aligns with Strategy Integration.


reasoning: The paragraph describes the company's internal incident response plan, the team that manages it, and the escalation processes, which are core components of risk management.


reasoning: The paragraph describes a specific past event (the July 2024 CrowdStrike outage), detailing the operational impact and the timeline for system restoration.


reasoning: The paragraph explicitly discusses the Board and Audit Committee's oversight of cybersecurity risks and the cadence of reports they receive from management.


reasoning: The paragraph provides a narrative of a specific past cyberattack, detailing its operational impact, data exfiltration scope, and subsequent remediation efforts.


reasoning: The paragraph focuses on the management roles responsible for cybersecurity, specifically identifying a third-party consultant and a Security Operations Center Manager, along with their qualifications.


reasoning: The paragraph primarily focuses on the CISO's qualifications, reporting structure, and the management-level Cybersecurity Governance Council (CGC) that supports the CISO, making 'Management Role' the most appropriate category.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and mitigating cybersecurity threats through the implementation of a specific plan.


reasoning: The paragraph primarily describes the briefing cadence and oversight mechanisms of the Committee and the Board, including reports received from the Chief Technology Officer and continuing education presentations.


reasoning: The paragraph focuses entirely on the CISO, detailing their responsibilities, reporting lines to the CIO and Audit Committee, and specific professional qualifications and certifications.


reasoning: The paragraph focuses on the board of directors' cybersecurity expertise, the role of the Technology & Cybersecurity Committee, and director training, making it a clear fit for Board Governance.


reasoning: The paragraph explicitly discusses the Board and Audit Committee's oversight responsibilities regarding cybersecurity risk management.


reasoning: The paragraph describes the company's internal cybersecurity team and its processes, including policy publication, risk assessments, and network segmentation, focusing on the function rather than the individual qualifications of the CIO.


reasoning: The paragraph explicitly describes a real cybersecurity incident, detailing the timeline, containment actions taken (taking systems offline), and the resulting operational and financial impacts.


reasoning: The paragraph describes the company's internal processes for post-incident review, including reassessing the cybersecurity program and incident response plan.


reasoning: The paragraph consists of a standalone materiality conclusion regarding past cybersecurity incidents and threats, which falls under Strategy Integration according to the classification rules.


reasoning: The paragraph is a pure cross-reference to the Risk Factors section regarding materiality, containing no substantive cybersecurity disclosure or actual materiality conclusion.


reasoning: The paragraph focuses entirely on the reporting structure of the CISO and the specific qualifications, tenure, and career history of the Vice President of Platform and Technology Services.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, their integration into the overall risk management program, and the adoption of recognized frameworks.


reasoning: The paragraph details the company's internal cybersecurity processes, including its Information Security Program, vulnerability management, incident response planning, and employee training.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents for the specified fiscal year, along with a cross-reference to the Risk Factors section.


reasoning: The paragraph primarily details the roles, responsibilities, and qualifications of management personnel, specifically the CIO and the Director of Information Security and Compliance, as well as the internal Security Council.


reasoning: The paragraph describes the integration of cybersecurity risk into the company's overall enterprise risk management program and how internal processes are prioritized to mitigate threats.


reasoning: The paragraph details the company's internal processes and methods for identifying and managing cybersecurity risks, such as using automated tools, conducting vulnerability assessments, and performing tabletop exercises.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including the responsibilities of its security team and its employee training practices.


reasoning: The paragraph consists entirely of boilerplate materiality conclusions regarding past incidents and future risks, which falls under Strategy Integration.


reasoning: The paragraph focuses entirely on the company's processes for identifying and managing cybersecurity risks associated with third-party service providers.


reasoning: The paragraph primarily details the briefing cadence to the Board of Directors and the Audit Committee's general oversight responsibilities regarding data security practices.


reasoning: The paragraph describes the company's internal cybersecurity processes, including its layered defensive approach and use of preventative and detective tools to monitor and manage cyber risks.


reasoning: The paragraph explicitly details the qualifications, experience, and responsibilities of the CIO/CISO, making Management Role the most appropriate category.


reasoning: The paragraph consists entirely of a standalone materiality conclusion and forward-looking disclaimer regarding the potential financial and operational impact of cybersecurity threats.


reasoning: The paragraph provides an overview of the company's cybersecurity program, focusing on its alignment with regulatory requirements and adoption of recognized frameworks like NIST and ISO 27001.


reasoning: The paragraph primarily focuses on the systems and processes used to oversee and mitigate security risks associated with third-party vendors and service providers, while also briefly mentioning cybersecurity insurance.


reasoning: The paragraph is entirely dedicated to the company's processes for assessing and overseeing third-party vendors and the security requirements imposed on them.


reasoning: The paragraph focuses on the management team's role in supervising cybersecurity efforts and how they stay informed through briefings, threat intelligence, and security alerts.


reasoning: The paragraph describes the company's internal processes for assessing and supporting the cybersecurity programs of its autonomous Affiliates, including pre-investment diligence and incident response assistance.


reasoning: The paragraph describes the company's internal cybersecurity processes, including threat identification, protective measures, monitoring, incident response planning, and employee training.


reasoning: The paragraph focuses on the VP of Information Technology, detailing their reporting lines, responsibilities, and specific career experience.


reasoning: The paragraph primarily describes the operational activities of the cybersecurity team and the CICSO, focusing on continuous monitoring processes and the execution of an incident response runbook.


reasoning: The paragraph describes the internal processes and activities related to cybersecurity risk management, such as integrating risk considerations, preparing for incidents, and reviewing assessments, rather than detailing the qualifications or reporting lines of a specific management role.


reasoning: The paragraph provides a high-level overview of the company's security capabilities, dividing them into internal cybersecurity and external product security, which falls under risk management processes.


reasoning: The paragraph focuses on the qualifications, credentials, and responsibilities of the Vice President, Head of Technology, making it a clear description of a management role.


reasoning: The paragraph primarily details the qualifications, experience, responsibilities, and reporting structure of the CISO and CDO, which aligns perfectly with the Management Role category.


reasoning: The paragraph describes the daily activities, monitoring processes, and escalation protocols of the information security team, focusing on the company's internal risk management operations.


reasoning: The paragraph consists of a standalone materiality conclusion regarding past cybersecurity threats and incidents, followed by a cross-reference to the Risk Factors section, which aligns with the Strategy Integration category.


reasoning: The paragraph provides a standalone materiality conclusion stating the company has not experienced prior material incidents, followed by forward-looking disclaimers about potential future impacts.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, controls, and risk assessments. While it mentions specific management titles, it focuses on their functional responsibilities within the program rather than their personal qualifications, aligning it with Risk Management Process.


reasoning: The paragraph focuses entirely on the Board of Directors' oversight of cybersecurity, including their briefing cadence, participation in exercises, and review of assessments.


reasoning: The paragraph describes the company's internal processes, controls, and mechanisms for assessing and managing cybersecurity risks, including a brief mention of third-party risk management as a component of the broader program.


reasoning: The paragraph focuses on the identification, reporting lines, and specific qualifications (experience, certifications, degrees) of management roles overseeing cybersecurity.


reasoning: The paragraph describes internal cybersecurity training and awareness programs, including phishing simulations and new hire training, which are core components of the company's risk management processes.


reasoning: The paragraph explicitly identifies the management roles (Senior Director, Human Resources & Infrastructure) and the specific internal team (Rapid Response Team) responsible for assessing and managing cybersecurity risks.


reasoning: The paragraph explicitly describes a past cybersecurity incident, detailing the timeline, operational impact, data exfiltration, and subsequent remediation efforts.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including policies, technical controls, and training programs.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including risk assessments, security enhancements, and third-party risk identification.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including its ISO 27001 certification, incident response procedures, and internal reporting workflows.


reasoning: While the paragraph briefly mentions Board oversight, the primary focus is on the CIO's reporting lines, qualifications (25 years of experience), and supporting team structure (Director of IT Security and vCISO), making Management Role the most applicable category.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including technical controls, monitoring systems, and the adoption of specific security frameworks.


reasoning: The paragraph primarily details the board's oversight structure, specifically the delegation of authority to the Audit and Operations and Safety Committees, and the reporting cadence of the CISO to the board.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity threats and risks, stating they have not materially affected the company's business strategy or financial condition, which falls under Strategy Integration.


reasoning: The paragraph focuses on the oversight activities of the CyTOC (a board committee) and the full Board, detailing their briefing cadences and interactions with management regarding cybersecurity risks.


reasoning: The paragraph primarily details the qualifications, responsibilities, and specific certifications of the Chief Security Officer and the Information Security team, making Management Role the most applicable category despite a brief initial mention of the board committee.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity risks and includes a cross-reference to the Risk Factors section.


reasoning: The paragraph focuses on the specific management roles responsible for leading cybersecurity processes, detailing their collective experience and how they monitor and manage cyber risks.


reasoning: The paragraph explicitly describes a past cybersecurity incident involving a third-party provider (CDK), detailing the timeline, affected systems, and operational impact.


reasoning: The paragraph outlines the company's internal cybersecurity risk management program, detailing its various components such as risk assessments, security controls, incident response planning, and employee training.


reasoning: The paragraph merely quotes the SEC's rationale for the new cybersecurity disclosure rules and introduces the requirements, providing no substantive disclosure about the company's own practices.


reasoning: The paragraph describes the company's internal procedures for conducting cybersecurity risk assessments and updating its risk register.


reasoning: The paragraph explicitly describes a past cyber-attack from February 2022, detailing the operational impact, system shutdowns, and subsequent remediation efforts.


reasoning: The paragraph explicitly identifies the management roles responsible for the risk assessment process and details their specific years of IT experience, fitting the Management Role category.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity incidents and their impact on the business strategy and financial position, along with a cross-reference to risk factors.


reasoning: While the paragraph begins by mentioning board oversight, the primary focus is on management roles, specifically detailing the CIO's reporting lines, committee leadership, and extensive educational and professional background, as well as the presence of a CISO.


reasoning: The paragraph focuses entirely on the qualifications, certifications, and credentials of the Vice President of Risk Management and external personnel, fitting the Management Role category.


reasoning: The paragraph primarily details the governance structure for cybersecurity, focusing on the Information Security Governance Committee's reporting cadence to the Board of Directors and the Board's ongoing cybersecurity education.


reasoning: The paragraph details management's responsibilities in monitoring cybersecurity incidents and their reporting structure to the Information Technology Steering Committee and the Board.


reasoning: The paragraph explicitly discusses the Board of Directors' responsibility for monitoring and assessing cybersecurity risk, and how it administers this oversight directly and through the Audit Committee.


reasoning: The paragraph focuses on the CISO's reporting responsibilities, detailing the committees they report to and the specific topics covered in their updates.


reasoning: The paragraph discusses the board of directors' oversight of the cybersecurity program, specifically delegating it to a subsidiary's Information Security Committee, which provides updates to the board.


reasoning: The paragraph primarily consists of a standalone materiality conclusion regarding past cybersecurity threats and incidents, along with forward-looking disclaimers, which falls under Strategy Integration.


reasoning: The paragraph is entirely focused on the Chief Technology Officer, detailing their reporting structure, professional experience, and specific responsibilities in managing the company's cybersecurity program.


reasoning: The paragraph describes the integration of the cybersecurity risk management program into the broader enterprise risk management program and mentions risk assessments, which are core components of internal risk management processes.


reasoning: The paragraph consists of a standalone materiality conclusion stating the company has not experienced any material cybersecurity incidents, followed by a cross-reference to the Risk Factors section. Per the guidelines, materiality disclaimers fall under Strategy Integration.


reasoning: The paragraph focuses on the reporting cadence to the audit committee and the board regarding cybersecurity risks, making it a Board Governance disclosure.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, specifically its use of ISO and NIST frameworks to guide its program.


reasoning: The paragraph explicitly details the board of directors' and Audit Committee's oversight of cybersecurity risks, including the reporting cadence and topics discussed.


reasoning: The paragraph describes the company's internal process for administering information and data security training programs.


reasoning: The paragraph focuses on the role and responsibilities of the Vice President of Information Technology in monitoring and reporting cybersecurity threats to management.


reasoning: The paragraph primarily discusses the Audit Committee's oversight of cybersecurity risks and the reporting it receives from the CISO, making Board Governance the most applicable category.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management program, its objectives, and its integration into overall risk management governance.


reasoning: The paragraph focuses on the management structure for cybersecurity, specifically identifying the roles leading the incident response team (Director and VP of IT), the existence of an information security advisory board, its cross-functional composition, and its specific responsibilities.


reasoning: The paragraph explicitly identifies the Chief Information Officer (CIO) as the leader of the cybersecurity program, detailing their 20 years of experience and specific responsibilities regarding the incident response plan.


reasoning: The paragraph details the company's internal cybersecurity training, testing, and exercise programs, which are core components of its risk management process.


reasoning: The paragraph describes the company's internal incident response, business continuity, and disaster recovery programs, which are core components of its risk management process.


reasoning: The paragraph primarily describes the company's internal processes for identifying, assessing, and managing cybersecurity risks, including risk assessments, monitoring, and escalation procedures.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment process, including its alignment with the NIST framework, and mentions its approach to evaluating third-party service provider risks.


reasoning: The paragraph focuses on the qualifications, experience levels, and committee memberships of specific management roles (chief risk officer and interim chief information officer) overseeing cybersecurity.


reasoning: The paragraph focuses on the composition and responsibilities of a management-level Information Security committee, including specific roles like the CDIO and CISO.


reasoning: The paragraph lists standard internal cybersecurity processes and controls, such as vulnerability management, access controls, and incident response planning, which are core components of a risk management program.


reasoning: The paragraph lists components of the company's cybersecurity program, including personnel capabilities, strategy, and resource allocation, which are core elements of internal risk management processes.


reasoning: The paragraph describes the company's internal security awareness training for personnel and educational efforts for customers, which are components of its risk management process.


reasoning: The paragraph describes the company's internal cybersecurity tools (SIEM, PAM, endpoint security) and its use of a third-party SOC for threat monitoring and remediation, which falls under risk management processes.


reasoning: The paragraph primarily discusses the oversight structure for cybersecurity, detailing the reporting lines to the Board of Directors and the Audit Committee's role in receiving updates.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity threats and cross-references the Risk Factors section, which aligns with the Strategy Integration category.


reasoning: The paragraph focuses on the materiality of past incidents, mentions cybersecurity insurance, and includes boilerplate disclaimers regarding potential future financial impacts, which aligns with the Strategy Integration category.


reasoning: The paragraph focuses on the Chief Security Officer (CSO), detailing their responsibilities for managing cyber risk and the evaluation of their expertise by the Executive Committee.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including risk mitigation tools, third-party assessments, incident response planning, and employee training.


reasoning: The paragraph discusses the absence of material cybersecurity events and the potential material adverse impact of future threats, which falls under Strategy Integration (materiality assessments).


reasoning: The paragraph primarily focuses on the management team's responsibilities, prior experience, and role in administering the cyber risk management program, with only a brief mention of the Audit Committee's oversight.


reasoning: The paragraph focuses entirely on the consideration of cybersecurity risks associated with third-party vendors and service providers.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including risk assessments and security controls.


reasoning: The paragraph primarily details the composition and responsibilities of a management-level committee (Information Technology Steering Committee) and specific management roles (CIO, CTO, ISO), making Management Role the most appropriate category.


reasoning: The paragraph primarily discusses the company's internal risk assessment and mitigation processes, making 'Risk Management Process' the most appropriate category.


reasoning: The paragraph contains a boilerplate materiality disclaimer stating that the company has not experienced any material financial losses or significant compromises to date, which falls under Strategy Integration according to the classification rules.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including threat assessment, employee training, vulnerability scanning, and integration with enterprise risk management.


reasoning: The paragraph focuses on the audit committee's oversight of cybersecurity risks and the reporting cadence from the CSO/CISO to the committee.


reasoning: The paragraph primarily focuses on the specific management roles (CISO and SVP of IT) responsible for cybersecurity, detailing their tenure and professional background.


reasoning: The paragraph primarily discusses the board committee's responsibility for overseeing the cybersecurity risk management program and the reporting cadence it receives from management.


reasoning: The paragraph describes the internal escalation protocols and incident response plan for reporting material cybersecurity incidents, focusing on the company's internal processes.


reasoning: The paragraph explicitly describes a past cybersecurity incident, noting when it was detected and the subsequent response actions taken, which aligns with the Incident Disclosure category.


reasoning: The paragraph describes the company's internal risk management processes, specifically its use of external consultants to conduct audits, penetration testing, and threat assessments on its own systems.


reasoning: The paragraph primarily provides a standalone materiality conclusion regarding cybersecurity risks and confirms the absence of material incidents during specific fiscal years.


reasoning: The paragraph's grammatical subject is management (Executive Officer and Vice President of Technology), describing their responsibility to brief the board on cybersecurity risks and activities.


reasoning: The paragraph describes the internal auditing and monitoring of the company's Information Security program, which falls under risk management processes.


reasoning: The paragraph discusses the importance of IT systems, the types of data collected (PHI, PII), and compliance with privacy laws (HIPAA, CCPA), but does not describe cybersecurity risk management processes, governance, or incidents. It serves as background context.


reasoning: The paragraph introduces the company's recognition of cybersecurity risks, mentioning the assessment and identification of threats alongside their potential business and financial impacts.


reasoning: The paragraph focuses on the specific management roles (CFO, General Counsel, Head of Information Technology) responsible for cybersecurity and details their respective years of experience and qualifications.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risk, specifically mentioning conducting risk assessments to identify threats to systems and infrastructure.


reasoning: The paragraph focuses on the responsibilities of the executive team and management, including the CEO and CFO, in implementing and overseeing cybersecurity risk management processes.


reasoning: The paragraph focuses on the individuals serving as chief security officer and chief privacy officer, detailing their responsibilities and combined years of experience.


reasoning: The paragraph describes a specific past event involving erroneous invoice payments, the recovery status, and the resulting investigation and materiality conclusion.


reasoning: The paragraph describes the company's internal risk assessment processes, specifically the use of third-party experts for penetration testing and posture assessments to validate existing controls.


reasoning: The paragraph contains a standalone materiality conclusion stating the company has not experienced a material cybersecurity incident to date, followed by a cross-reference to the Risk Factors section regarding potential material impacts.


reasoning: The paragraph describes the company's internal cybersecurity program, risk management approach, and adoption of the NIST framework.


reasoning: The paragraph focuses on management's responsibilities for implementing cybersecurity policies and their reporting cadence to the Board.


reasoning: The paragraph's central focus is on the oversight of third-party service providers, including obtaining SOC-1 reports and limiting vendor access to company data.


reasoning: The paragraph explicitly identifies the CISO and CIO as the grammatical subjects and describes their responsibilities in reporting cybersecurity risks to the Board and Audit Committee.


reasoning: The paragraph focuses entirely on the management team's roles (CTO, VPCS) and their specific qualifications, educational backgrounds, years of experience, and certifications.


reasoning: The paragraph provides a standalone materiality conclusion regarding the absence of material cybersecurity incidents and discusses potential impacts on business strategy and financial condition, which falls under Strategy Integration.


reasoning: The paragraph primarily describes the company's internal cybersecurity policies, processes, and adoption of ISO and NIST frameworks, despite an initial mention of Board oversight.


reasoning: The paragraph primarily describes the company's internal cybersecurity policies, processes, and framework adoption (SCF, NIST, ISO) to manage and mitigate cyber risks.


reasoning: The paragraph focuses on the management level, specifically identifying the CIO, detailing their years of experience, and outlining their reporting structure.


reasoning: The paragraph explicitly describes a past cybersecurity incident, detailing the date of discovery, the nature of the attack (ransomware), operational impacts, and the lack of material financial impact.