reasoning: The paragraph describes the company's internal cybersecurity strategy, policies, and risk assessment processes, including employee training and third-party audits.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the internal processes and activities overseen by the management team to manage cybersecurity risks, including the use of threat intelligence and security tools.

provider: google

stage: benchmark


reasoning: The paragraph describes the company's internal incident response and management plans, including testing, playbooks, and notification procedures, which falls under Risk Management Process.


reasoning: The paragraph details the company's internal cybersecurity processes, including independent assessments, defense mechanisms, and vendor risk assessments.


content_category: Incident Disclosure

reasoning: The paragraph explicitly describes a past cybersecurity incident involving a third-party vendor, detailing the nature of the exploit, the data affected, and the company's response actions.


content_category: None/Other

reasoning: The paragraph describes the company's general business operations and contains no cybersecurity-related information.


content_category: Management Role

reasoning: The paragraph focuses on the qualifications, experience, and support structure of the IT Lead, which aligns with the Management Role category.


reasoning: The paragraph discusses the company's recognition of the importance of developing and maintaining cybersecurity measures to safeguard information systems, which falls under the Risk Management Process category.


content_category: Strategy Integration

reasoning: The paragraph discusses the general lack of material impact from past threats and provides a boilerplate materiality disclaimer regarding potential future incidents.


reasoning: The paragraph describes the company's internal cybersecurity training and policy communication processes.


content_category: Board Governance

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


reasoning: The paragraph describes the company's internal cybersecurity risk management protocols, including its cross-departmental approach, software tools, and policy review processes.


reasoning: The paragraph focuses on the composition and functions of the IT Steering Committee and the reporting line of the IT manager, making it primarily about management roles and their oversight responsibilities.


reasoning: The paragraph primarily focuses on the CISO's qualifications, tenure, reporting structure, and responsibilities, making Management Role the most applicable category.


reasoning: The paragraph describes the company's internal incident response plan, threat level assessment, and the specific escalation process for critical incidents.


reasoning: The paragraph primarily details the qualifications, experience, and collaborative structure of the management team responsible for cybersecurity, specifically focusing on the Chief Technology Officer and other named security managers.


reasoning: The paragraph describes the company's internal cyber risk management processes and resource investments, passing the person-vs-function test for Risk Management Process despite naming the management roles involved.


reasoning: The paragraph primarily details the qualifications, reporting structure, and experience of the Director of IT, who leads the CIRT, making Management Role the most applicable category.


reasoning: The paragraph explicitly describes a past cybersecurity incident, detailing when it occurred, the type of data extracted, and the containment and investigation actions taken.


reasoning: The paragraph focuses entirely on the Board and Audit Committee's oversight of cybersecurity risks, including reporting cadences, incident updates, and committee member expertise.


reasoning: Although the paragraph begins by mentioning the board's Risk Committee, the primary focus and most detailed portion of the text describes the CISO's responsibilities, reporting structure, years of experience, and specific professional certifications.


reasoning: The paragraph details the internal processes, threat intelligence, and incident response operations of the Information Security Division, focusing on risk management activities rather than just the CISO's qualifications.


reasoning: The paragraph primarily discusses the Audit Committee's oversight responsibilities regarding cybersecurity and the reporting cadence from management (CIO/CISO) to the committee, which falls under Board Governance.


reasoning: The paragraph primarily details the Audit Committee's oversight responsibilities, its reporting to the Board of Directors, and the frequency of briefings it receives from the CISO.


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


reasoning: The paragraph details the company's internal incident response planning, cross-functional coordination, and escalation procedures, which are core components of its risk management process.


reasoning: The paragraph describes the integration of cybersecurity into the company's broader enterprise risk management (ERM) strategies, which falls under internal risk management processes.


reasoning: The paragraph explicitly details a past cybersecurity incident, including the dates of occurrence and recovery, the financial amount involved, and the response actions taken.


reasoning: The paragraph explicitly discusses the board of directors' oversight of cybersecurity risks and the formalization of governance structures, making Board Governance the most applicable category.


reasoning: The paragraph focuses entirely on the management roles responsible for cybersecurity, specifically detailing the titles, reporting structure, years of experience, and professional certifications of the CIO and Senior Director of Information Security.


reasoning: The paragraph details the management-level governance structure, specifically identifying the CISO's role as chair of the Engineering Risk Steering Group and outlining the reporting lines to the Firmwide Technology Risk Committee.


reasoning: The paragraph describes the company's internal processes for enterprise information security risk management assessment, including safeguards for email spoofing, making it a Risk Management Process.


reasoning: The paragraph details the company's internal cybersecurity program, listing specific security measures and processes such as encryption, vulnerability scanning, and phishing simulations.


reasoning: The paragraph focuses on the leadership of the cybersecurity program, specifically identifying the Director of IT, detailing their 40 years of experience, and describing the CSIRT team's role.


reasoning: The paragraph describes the company's internal cybersecurity processes, including training, layered defenses, and penetration testing, which are core components of risk management.


reasoning: The paragraph discusses regulatory requirements and concludes with a standalone statement regarding the absence of any material cybersecurity incidents, which falls under Strategy Integration.


reasoning: The paragraph describes a specific cybersecurity incident (email spoofing effort) that occurred in May 2014, detailing what happened and the outcome.


reasoning: The paragraph explicitly describes the Audit Committee's role in reviewing and evaluating the company's information security program, making it a clear example of Board Governance.


reasoning: The paragraph outlines the key areas of the company's cybersecurity program, focusing on its integration into enterprise risk management, governance structure, and cross-functional incident escalation processes.


reasoning: The paragraph focuses entirely on the Board's oversight of cybersecurity risk, its delegation to the Audit Committee, and the reporting cadence from the CFO.


reasoning: The paragraph describes the responsibilities of the security team regarding internal risk assessment processes, security controls, and incident response planning.


reasoning: The paragraph primarily describes a specific, historical cybersecurity incident involving a third-party vendor (PBI) and the MOVEit file transfer system, detailing the scope of the data exposure and the company's response and materiality assessment.


content_category: Third-Party Risk

reasoning: The paragraph focuses entirely on the company's oversight of third-party vendors, including risk ratings and ensuring adherence to cybersecurity standards.


reasoning: The paragraph explicitly describes a past cybersecurity incident (the MOVEit breach), detailing the scope of affected individuals, the third party involved, and the resulting materiality assessment.


reasoning: The paragraph describes the company's internal cybersecurity policies, decentralized business unit programs, and general risk management procedures.


reasoning: The paragraph outlines the potential business, operational, and financial impacts of various cybersecurity risks, which falls under strategy integration.


reasoning: The paragraph focuses on the Chief Technology Officer, detailing their qualifications (25 years of experience), reporting structure, and responsibilities for overseeing the cybersecurity program.


reasoning: The paragraph primarily details the reporting lines and responsibilities of the CISO in informing executive management and escalating matters to the board and its committees.


reasoning: The paragraph explicitly states the company is a SPAC with no business operations and has not adopted any cybersecurity risk management program, which falls under the None/Other category per the guidelines.


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


reasoning: The paragraph explicitly states the company has not adopted any cybersecurity risk management program or formal processes, which triggers the rule to classify as None/Other regardless of incidental mentions of board oversight or materiality.


reasoning: The paragraph describes the scope and response actions of an actual cybersecurity incident, including notifying affected customers and regulators, providing credit monitoring, and facing lawsuits.


reasoning: The paragraph describes the company's internal information security processes, including vulnerability assessments, incident detection, disaster recovery, and employee training.


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


reasoning: The paragraph describes the organizational structure and delegation of the company's cybersecurity risk management processes to its General Partner, Investment Manager, and ultimately its parent company, Blackstone.


reasoning: The paragraph describes the integration of cybersecurity into the company's Enterprise Risk program and details the risk assessment activities conducted by the Enterprise Risk team, focusing on the function rather than the individual qualifications of the managers.


reasoning: The paragraph primarily describes the internal processes and methods used to identify and assess cybersecurity risks, such as vulnerability assessments and tabletop exercises, despite briefly mentioning the management roles involved.


reasoning: The paragraph explicitly states the company is a special purpose acquisition company (SPAC) with no business operations and no adopted cybersecurity risk management program, which falls under the None/Other category per the guidelines.


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


reasoning: The paragraph explicitly states the company is a SPAC with no operations and has not adopted any cybersecurity risk management program, which falls under the None/Other category per the guidelines.


reasoning: The paragraph primarily focuses on the roles of the CISO and CRO, detailing their responsibilities in supporting board oversight, reporting to the risk committee, and executing escalation processes.


reasoning: The paragraph focuses on the leadership of the technology team, specifically identifying the Director of Information Technology and detailing their years of experience.


reasoning: The paragraph primarily discusses the company's internal processes for assessing, identifying, and managing cybersecurity risks, including the establishment of policies and the Security Steering Group.


reasoning: The paragraph explicitly states the company lacks significant investments and resources for data security protection, which is a standard disclaimer for early-stage or shell companies indicating the absence of a formal cybersecurity program.


reasoning: The paragraph details the company's internal incident response and escalation processes, including the role of the CMT and policy timelines for materiality determinations.


reasoning: The paragraph describes the company's internal incident response processes, including the composition of its cross-functional Incident Response Team and the annual testing of its Incident Response Plan.


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


reasoning: The paragraph focuses entirely on the specific individuals (management) responsible for cybersecurity oversight, detailing their titles, educational backgrounds, and prior career experience.


reasoning: The paragraph discusses cyber risk insurance and the potential for losses to exceed coverage, which falls under Strategy Integration.


reasoning: The paragraph explicitly identifies the Chief Information Officer (CIO) as the leader of the cybersecurity program and details their reporting structure, supporting team, and extensive professional background.


reasoning: The paragraph describes the company's internal cybersecurity processes, including vulnerability management, incident response, and employee training, as well as how they manage third-party vendor risks as a component of their overall risk management strategy.


reasoning: The paragraph describes the company's internal incident response plan and the standard processes used to manage and remediate cybersecurity incidents.


reasoning: The paragraph discusses the materiality of cybersecurity threats in 2024, concluding that none have materially affected the business strategy, results of operations, or financial condition. This aligns with the Strategy Integration category.


reasoning: The paragraph explicitly discusses the Board's role in overseeing cybersecurity risk and its delegation of that oversight to executive management, making Board Governance the most applicable category.


reasoning: The paragraph describes the company's use of third-party service providers to execute various components of its internal cybersecurity risk management processes, such as vulnerability scanning and incident response.


reasoning: The paragraph discusses the materiality of cybersecurity risks and incidents on the company's business strategy, results of operations, and financial condition, which aligns with Strategy Integration.


reasoning: The paragraph focuses entirely on the qualifications, credentials, and experience of specific management roles (CISO, CTO, Head of IT Infrastructure).


reasoning: The paragraph primarily details the management structure for cybersecurity, identifying specific roles (Information Security Manager, CIO), their reporting lines, and their combined years of experience.


reasoning: The paragraph focuses on the reporting lines and responsibilities of the COO and management in providing cybersecurity updates to the board of directors and the Audit Committee.


reasoning: The paragraph describes a specific past cybersecurity incident, detailing the nature of the attack (email spoofing), the exact financial impact (26 BTC / $560,000), and the response actions taken.


reasoning: The paragraph consists entirely of forward-looking disclaimers regarding potential future cybersecurity threats and their possible material adverse effects, containing no substantive disclosure about actual processes, governance, or incidents.


reasoning: The paragraph provides a standalone materiality conclusion regarding past incidents and a boilerplate disclaimer about the potential material impact of future threats on the business strategy and financial condition.


reasoning: The paragraph heavily focuses on the roles, qualifications, and committee compositions of management, specifically detailing the CISO's years of experience and certifications, as well as the specific executive titles that make up the Enterprise Risk Committee.


reasoning: The paragraph describes the company's internal security governance structure and processes for evaluating cyber risk, making it a Risk Management Process disclosure.


reasoning: The paragraph describes a specific cybersecurity incident involving a threat actor impersonating a CFO, resulting in the theft of 26 BTC, and details the subsequent response actions.


reasoning: The paragraph provides a boilerplate statement regarding the absence of past material cybersecurity incidents and a forward-looking disclaimer about future risks, which falls under materiality assessments.


reasoning: The paragraph primarily describes the internal security controls, tools, and processes employed by the company's cybersecurity organization, including its approach to managing third-party risks.


reasoning: The paragraph focuses on the qualifications, experience, and reporting structure of the Chief Information Officer (CIO) and the internal management-level ISMS Committee, making Management Role the most appropriate category.


reasoning: The paragraph focuses on the preparation and qualifications of management (specifically the CFO) and third-party service providers to assess and manage cybersecurity risks.


reasoning: The paragraph primarily details the company's internal cybersecurity processes, including threat intelligence gathering, specific tools used, regulatory compliance frameworks, and participation in industry information-sharing programs.


reasoning: The paragraph focuses on the InfoSec Director's role, qualifications (thought leader, speaker), and responsibilities in monitoring and responding to cybersecurity incidents.


reasoning: The paragraph describes the company's internal processes and tools for monitoring, preventing, detecting, and mitigating cybersecurity incidents, which falls under Risk Management Process.


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


reasoning: The paragraph describes the company's internal cybersecurity program and how it interfaces with various departments to identify and understand threats, which falls under Risk Management Process.


reasoning: The paragraph details the response and financial impact of a specific cybersecurity incident involving stolen BTC, including forensic analysis results and a specific reimbursement payment.


reasoning: The paragraph details the company's internal cybersecurity program, including technical safeguards, incident response planning, third-party risk management, and education/awareness, making it a clear description of the Risk Management Process.


reasoning: The paragraph explicitly discusses the company's reliance on third-party vendors and the implementation of a vendor risk management program, including due diligence and contractual requirements for security controls.


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


reasoning: The paragraph focuses on the COO's role, experience, and reporting responsibilities regarding information security, making 'Management Role' the most appropriate category.


reasoning: The paragraph explicitly describes a past ransomware attack that occurred in May 2020, detailing the nature of the incident (data removal from a self-hosted environment) and its ongoing legal impacts.


reasoning: While the paragraph begins with board oversight, the majority of the text focuses extensively on the specific qualifications, educational backgrounds, certifications, and professional memberships of the CIO and CISO.


reasoning: The paragraph details the internal processes of the Information Security team, specifically focusing on the annual review of governance documents and the maintenance of a three-year cybersecurity strategic plan.


reasoning: The paragraph focuses on the oversight responsibilities and information flow to the Chief Information Security Officer and the Cybersecurity Committee, making Management Role the most appropriate category.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including its integration with the Enterprise Risk Management program, defense-in-depth strategy, and various security testing activities.


reasoning: The paragraph primarily discusses the potential business impact of cybersecurity threats and includes a boilerplate materiality conclusion stating that prior incidents have not materially affected the company's financial condition.


reasoning: The paragraph describes the company's internal risk management processes, specifically detailing the functions, responsibilities, and composition of its internal Cyber Security Watch Team.


reasoning: The paragraph details the response, forensic investigation findings, and financial remediation (including a specific payment amount) related to a specific cybersecurity incident involving stolen BTC.


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


reasoning: The paragraph primarily describes the company's Enterprise Risk Management (ERM) program and how cybersecurity risk is integrated and monitored within it, detailing the specific management committees and roles responsible for day-to-day oversight.


reasoning: The paragraph primarily focuses on the role, responsibilities, and functions managed by the Vice President of Information Security Systems (VP, ISS), making Management Role the most appropriate category.


reasoning: The paragraph describes specific incident response and remediation actions taken following an event, along with a conclusion on the incident's materiality.


reasoning: The paragraph primarily discusses the Audit Committee's oversight of cybersecurity risk and the reporting structure to the Board, making Board Governance the most applicable category.


reasoning: The paragraph explicitly details the timeline, scope, and findings of a specific cybersecurity incident, including exact dates of unauthorized activity and the completion of the forensic investigation.


reasoning: The paragraph explicitly discusses the oversight responsibilities of a specific board committee (the RCOC) regarding the cybersecurity program and its reporting to the full Board.


reasoning: The paragraph explicitly details the IT Director's responsibilities and specific years of experience, as well as the formation of an IT Steering Committee, making it focused on management's role in cybersecurity.


reasoning: The paragraph focuses entirely on the responsibilities, reporting lines, and collaboration of specific management roles (the CISO and CTO), making 'Management Role' the most appropriate category.


reasoning: The paragraph describes the company's internal process for identifying and assessing cybersecurity risks, specifically detailing how they utilize a third-party IT firm in conjunction with an internal IT lead to monitor the threat environment.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including its integration into the broader risk framework, a specific security points of contact program, and an internal security council.


reasoning: The paragraph describes the company's internal processes for threat identification, mitigation, and incident response.


reasoning: The paragraph explicitly describes a past cybersecurity incident, detailing the date of discovery, the operational impact on shipping, the recovery timeline, and the specific financial costs incurred.


reasoning: The paragraph focuses on the qualifications, training, and specific professional certifications held by the company's cybersecurity personnel, which falls under Management Role.


reasoning: The paragraph details the company's internal cybersecurity processes, including technical safeguards, incident response planning, third-party risk management as a component of the broader program, and employee training.


reasoning: The paragraph describes the integration of the cybersecurity program into the broader enterprise risk management program and the adoption of the NIST CSF framework.


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


reasoning: The paragraph primarily describes the company's internal communication and disclosure framework for cybersecurity incidents, including escalation processes to specific committees and stakeholders.


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


reasoning: The paragraph describes the company's internal processes for monitoring and detecting risks and vulnerabilities using a specific tool, which falls under Risk Management Process.


reasoning: The paragraph describes the design and procedures of the company's Incident Response Plan (IRP) and its alignment with the NIST Cybersecurity Framework, which are core components of internal risk management processes.


reasoning: The paragraph introduces the company's cybersecurity risk management processes and mentions shared oversight by the Board and senior management, making it primarily about the internal risk management process.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity risks and threats, stating they have not had a material impact on operations, business strategy, or financial results.


reasoning: The paragraph describes a component of the company's internal cybersecurity processes, specifically access control.


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


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


reasoning: The paragraph describes the company's internal risk management processes, specifically its use of external firms to assist with security operations, evaluations, and audits.


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


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


reasoning: The paragraph focuses on the Board of Directors' oversight of cybersecurity policies and their receipt of updates from senior management, which aligns with the Board Governance category.


reasoning: The paragraph details the company's internal technical controls and processes for managing cybersecurity risks, including specific firewall types, a custom internal cloud system, and physical tape backup procedures.


reasoning: The paragraph consists of boilerplate materiality disclaimers regarding past incidents and future threats, which falls under Strategy Integration according to the guidelines.


reasoning: The paragraph focuses on the security standards (SSAE audits) required of the company's third-party SaaS providers.


reasoning: The paragraph primarily describes the company's enterprise-wide information security program and processes for identifying and managing cybersecurity risks, with a brief mention of the CISO managing the program.


reasoning: The paragraph describes the company's internal processes for identifying and mitigating vulnerabilities, including internal/external testing and bug bounty programs.


reasoning: The paragraph focuses entirely on the company's oversight of third-party service providers, including risk assessments during onboarding and contractual security requirements.


reasoning: The paragraph details the composition of a management-level committee and explicitly identifies key cybersecurity and technology roles (CIO, CISO) that make up its membership.


reasoning: The paragraph discusses the potential business and financial impacts of cybersecurity risks, mentions insurance, and provides a standalone materiality conclusion stating that no material incidents have occurred to date.


reasoning: The paragraph consists entirely of a boilerplate materiality disclaimer regarding the impact of cybersecurity threats on the company's business strategy and financial condition.


reasoning: The paragraph is a standalone materiality conclusion stating that there are no known weaknesses or malware that would materially affect operations, which falls under Strategy Integration.


reasoning: The paragraph describes the company's adoption of specific cybersecurity frameworks (CIS, NIST, ISO) to manage and mitigate cyber risk, which is a core component of the risk management process.


reasoning: The paragraph focuses on the management structure for cybersecurity, specifically identifying the vice president of information technology services, their reporting line to the Chief Strategy Officer, and the responsibilities of the IT Department's security team.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risks, including the involvement of senior executives and an unnamed IT Managed Service Provider in developing policies and coordinating incident response.


reasoning: The paragraph focuses on the qualifications, experience, certifications, and responsibilities of the Vice President, IT Security, making it a clear fit for Management Role.


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


reasoning: The paragraph focuses on management's responsibility for cybersecurity, specifically identifying the Senior Vice President and Chief Technology Officer and detailing their years of experience.


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


reasoning: The paragraph is entirely a cross-reference to the Risk Factors section in Item 1A and contains no substantive cybersecurity disclosure or standalone materiality conclusion.


reasoning: The paragraph details the specific management committees (IT Steering Committee and IT Subcommittee) and executive roles (CISO, CTO, CRO) responsible for overseeing and managing cybersecurity risks.


reasoning: The paragraph primarily describes the company's internal cybersecurity management program, its review processes, and benchmarking to industry frameworks.


reasoning: The paragraph details the company's internal processes for monitoring networks, detecting intrusions, and escalating cyber events to management and the Board.


reasoning: The paragraph describes the company's internal Cybersecurity Incident Response Plan and its integration into the overall risk management system.


reasoning: The paragraph exclusively details the professional backgrounds, qualifications, and years of experience of various management roles, including the CISO and CDIO.


reasoning: The paragraph focuses on the board's audit committee and its dedicated cybersecurity sub-committee, detailing their composition and oversight responsibilities regarding cyber risks and incidents.


reasoning: The paragraph explicitly focuses on the oversight and management of third-party service providers, including security assessments and ongoing monitoring to mitigate risks originating from third parties.


reasoning: The paragraph primarily discusses the potential business and financial impacts of cybersecurity risks and includes a standalone materiality conclusion stating no material incidents occurred in the specified year.


reasoning: The paragraph focuses on the materiality of cybersecurity risks and past incidents, concluding that they have not materially affected the company since 2017, which aligns with Strategy Integration.


reasoning: The paragraph explicitly describes a past cybersecurity incident, noting a 2021 ransomware attack where data was accessed, and discusses the resulting class action lawsuit.


reasoning: The paragraph contains a standalone materiality conclusion stating that cybersecurity risks have not had a material impact on operations, business strategy, or financial results, which falls under Strategy Integration.


reasoning: The paragraph describes the company's internal processes for integrating cybersecurity into its broader risk management framework, detecting vulnerabilities, and handling incident notifications.


reasoning: The paragraph explicitly identifies the management role (Director of IT) responsible for assessing and managing cybersecurity risks and discusses their experience, fitting the Management Role category.


reasoning: The paragraph focuses exclusively on the assessment and ongoing monitoring of third-party providers to ensure compliance with the company's cybersecurity standards.


reasoning: The paragraph explicitly describes an actual cybersecurity incident, detailing the date of detection, the response actions taken, and the date the threat actor was ejected from the systems.


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


reasoning: The paragraph details the scope and response actions of a specific cybersecurity incident, including notifying affected consumers, providing credit monitoring services, and addressing related lawsuits.


reasoning: The paragraph provides a detailed narrative of an actual email spoofing incident, including the timeline of events, the financial impact, and the specific response actions taken by the company.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including monitoring, training, and third-party assessments, making it a clear fit for Risk Management Process.


reasoning: The paragraph details the specific management roles responsible for assessing and managing cybersecurity risks, including their experience and supervisory duties, while also mentioning board reporting.


reasoning: The paragraph primarily details the Board of Directors and Audit Committee's oversight responsibilities regarding cybersecurity, including their interactions with management.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight of cybersecurity, including briefings received from management and the CISO.


reasoning: The paragraph primarily describes the company's Information Security Program, its objectives, and its methods for monitoring and mitigating cyber threats, which falls under Risk Management Process.


reasoning: The paragraph focuses on how management is informed about and monitors cybersecurity incidents, detailing their reliance on communications with specific personnel from the Investment Manager.


reasoning: The paragraph focuses on the audit committee's oversight of cybersecurity risks, including the cadence and content of updates received from management.


reasoning: The paragraph focuses on a management-level committee and specific management roles (CIO, Director of Information Security) responsible for overseeing and implementing the cybersecurity program.


reasoning: The paragraph describes the company's internal information security and cybersecurity programs, including the establishment of safeguards and threat identification processes, which are core components of risk management.


reasoning: The paragraph details the specific responsibilities and reporting lines of a management-level committee (the Information Security Management Committee), making Management Role the most appropriate category.


reasoning: The paragraph focuses on the responsibilities of management in overseeing cybersecurity threats and their reporting line to the board of directors during an incident.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including assessments, penetration testing, and employee training programs.


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


reasoning: The paragraph provides a boilerplate materiality disclaimer stating that no cybersecurity incidents have materially affected the company's strategy or financial condition.


reasoning: The paragraph primarily details the oversight responsibilities and reporting lines of management roles, specifically the CFO and VP of Internal Audit, regarding cybersecurity risk management and incident reporting.


reasoning: The paragraph describes the company's internal IT risk identification process and risk register, which are core components of its risk management framework.


reasoning: The paragraph describes the company's internal cybersecurity processes, including its incident response plan, regulatory compliance efforts, framework adoption, and integration into overall business strategy.


reasoning: The paragraph primarily details the company's internal cybersecurity risk assessments, vulnerability testing, and integration with enterprise risk management, while also noting the CISO's oversight role.


specificity_confidence: medium

reasoning: The paragraph focuses on a specific management role (Director of Compliance) and describes their reporting responsibilities to the Board regarding cybersecurity risks.


reasoning: The paragraph primarily details the roles, reporting lines, and committee memberships of the Director of Information Security and Chief Information Officer, making Management Role the most applicable category.


reasoning: The paragraph focuses on management's leadership of cybersecurity processes, the specific experience level of their third-party partner, and the reporting structure to senior management.


reasoning: The paragraph focuses on management-level committees (OROC and IT Steering Committee) and specific management roles (CRO, CIO) responsible for overseeing cybersecurity risks.


reasoning: The paragraph focuses entirely on the management roles responsible for cybersecurity (VP Technology and CISO) and details the CISO's specific qualifications and years of experience.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and managing cybersecurity risks, including integration into overall risk management, penetration testing, and employee training.


reasoning: The paragraph is entirely focused on the company's third-party service provider management program, detailing how vendor contracts are reviewed and due diligence is conducted to mitigate third-party cybersecurity risks.


reasoning: The paragraph details the company's internal incident response and escalation processes, including how significant incidents are triaged and reported to specific technology and security executives.


reasoning: The paragraph primarily details the Audit Committee's oversight of cybersecurity risks, including its meeting cadence, responsibilities, and the reporting structure of management roles like the CISO and CCO/CAO to the committee.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and monitoring cybersecurity risks through its Enterprise Risk Management Program and incident response plan.


reasoning: The paragraph primarily details the board of directors' and Audit Committee's oversight of cybersecurity risks, including reporting cadences and escalation protocols for material incidents.


reasoning: The paragraph focuses on the CFO's responsibilities for day-to-day oversight of cybersecurity risks and reporting to the Board, making Management Role the primary subject.


reasoning: The paragraph describes the company's internal cybersecurity processes, including its integration into the broader risk management program and the adoption of an incident response plan.


reasoning: The paragraph primarily discusses the Board of Directors' oversight of cybersecurity risk, including the types of information they receive and their discussions on the topic.


reasoning: The paragraph describes the operational impact and response actions related to a specific cybersecurity incident, including disruptions, taking systems offline, containment, and restoration.


reasoning: The paragraph describes an actual cybersecurity incident, specifically mentioning that information was exfiltrated and an ongoing investigation into the extent of the compromise.


reasoning: The paragraph is centrally focused on the company's oversight of third-party service providers, detailing how they are used and the processes (like questionnaires and attestation reviews) employed to assess their cybersecurity risks.


reasoning: The paragraph primarily outlines the oversight and reporting structure for cybersecurity, detailing the Board and Audit Committee's oversight responsibilities, the Principal Accounting Officer's management role, and the reporting cadence to the committee.


reasoning: The paragraph explicitly discusses the Board of Directors' commitment to staying updated on cybersecurity regulations and best practices, while also noting the absence of incidents in a specific year.


reasoning: The paragraph introduces the company's recognition of the need to assess, identify, and manage cybersecurity risks, listing generic examples of potential threats.


reasoning: The paragraph explicitly details the Board of Directors' and its committees' oversight responsibilities regarding cybersecurity risks and enterprise risk management.


reasoning: The paragraph details the briefing cadence and the specific contents of the cybersecurity reports provided to the Risk Committee, which falls under board/committee oversight.


reasoning: The paragraph focuses entirely on the company's approach to managing cybersecurity risks associated with third-party service providers, including vendor due diligence and contractual requirements.


reasoning: The paragraph describes the company's internal approach to cybersecurity, specifically its adoption of a risk-based approach and implementation of cybersecurity policies, which falls under Risk Management Process.


reasoning: The paragraph focuses entirely on the Audit Committee's oversight of cybersecurity risks, the information they review, and their reporting cadence to the Board of Directors.


reasoning: The paragraph describes the company's internal processes for reviewing and auditing its Information Security Program, including risk assessments using a specific tool.


reasoning: The paragraph focuses on management-level oversight of cybersecurity, detailing the roles, composition, and reporting lines of the ERM committee, cybersecurity committee, and the CTO.


reasoning: The paragraph focuses on the Audit Committee's oversight of cybersecurity risks, detailing their reporting cadence and the topics covered in briefings from the CSO.


reasoning: The paragraph provides a standalone materiality conclusion regarding the absence of material cybersecurity incidents during the year, which falls under Strategy Integration.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity threats and incidents, along with forward-looking disclaimers and a cross-reference to Risk Factors.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity incidents and their impact on business strategy and financial condition, which aligns with Strategy Integration.


reasoning: The paragraph consists entirely of forward-looking risk disclaimers regarding potential consequences of a hypothetical system compromise, containing no substantive cybersecurity disclosure.


reasoning: The paragraph primarily details the oversight structure for cybersecurity, focusing on the Board's overall responsibility and the reporting cadence to the Audit Committee, while also identifying the management role responsible for the program.


reasoning: The paragraph explicitly identifies the specific management role (Executive Director of Information Technology) responsible for chairing the company's risk management committee.


reasoning: The paragraph focuses on the qualifications, experience, and reporting structure of management roles, specifically the CISO and their supporting team of ISOs and consultants.


reasoning: The paragraph focuses on the Board of Directors' oversight responsibilities, including their review of specific internal plans, and details the cybersecurity expertise of a named board member.


reasoning: The paragraph primarily discusses the Trust's reliance on its Sponsor's (BlackRock) Enterprise Risk Management (ERM) framework to manage cybersecurity risks, introducing the core process used.


reasoning: The paragraph details the specific management roles (CIO and CISO) and internal management committees responsible for cybersecurity crisis management and incident disclosure.


reasoning: The paragraph primarily details the management structure, specifically focusing on the CISO and Chief Technology and Digital Officer, their reporting lines, and the CISO's professional experience and qualifications.


category_confidence: medium

reasoning: The paragraph details the Board's responsibility for cybersecurity oversight and the specific reporting cadence and content provided to the Board by the Director of Information Technology.


reasoning: The paragraph focuses on the IT Team Director and the reporting structure to other C-suite executives (CFO, CEO, General Counsel) regarding cybersecurity risks and incidents, which falls under Management Role.


reasoning: The paragraph describes the internal processes for incident identification, assessment, and response, focusing on the activities performed rather than the qualifications or background of the personnel.


reasoning: The paragraph describes the company's internal access management processes, including least privilege methodology, user provisioning, and single sign-on controls.


reasoning: The paragraph fragment describes the implementation of security controls and mitigation measures, which are core components of a company's internal risk management process.


reasoning: The paragraph indicates that the company has not yet commenced operations and lacks formal cybersecurity expertise or processes, which falls under the None/Other category for shell companies.


reasoning: The primary clause of the paragraph describes the Board of Directors' oversight of cybersecurity risks and their inquiries to management, making Board Governance the most appropriate category.


reasoning: The paragraph describes the company's internal Information Security Program (ISP) and lists the various security domains and controls it encompasses, which falls squarely under Risk Management Process.


reasoning: The paragraph is entirely dedicated to describing the company's vendor management program, including how it assesses and imposes contractual obligations on third-party service providers regarding cybersecurity.


reasoning: The paragraph describes the company's internal cybersecurity processes, including patch management, employee training, and reviewing third-party security procedures.


reasoning: The paragraph focuses on the specific management roles, committees, and divisions responsible for cybersecurity risk management, detailing their reporting lines, team size, and qualifications.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, its integration into the broader enterprise risk management approach, and the adoption of recognized frameworks.


reasoning: The paragraph focuses on the CISO's responsibilities, career background, tenure, and reporting structure, which directly aligns with the Management Role category.


reasoning: The paragraph explicitly discusses the Board's role in overseeing cybersecurity risk and management's implementation of the risk management program, making 'Board Governance' the most appropriate category.


reasoning: The paragraph explicitly identifies the management role responsible for cybersecurity (Senior Director, Head of IT and Informatics) and details their reporting line to the CFO.


reasoning: The paragraph describes the operational impact and restoration timeline of a specific cybersecurity incident.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents for the year 2024, along with a cross-reference to the Risk Factors section.


reasoning: The paragraph explicitly describes a past cybersecurity incident, including specific dates of occurrence and disclosure, the scope of the impact (internal servers, IT telephony, data extraction), and the response actions taken.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks, including the adoption of the NIST framework and an incident response plan.


reasoning: The paragraph describes the company's use of external consultants and service providers as a component of its internal risk management processes.


reasoning: The paragraph focuses on the board of directors receiving presentations on cybersecurity risks from senior management, which falls squarely under Board Governance.


reasoning: The paragraph describes the integration of the cybersecurity risk management program into the broader enterprise risk management framework.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including continuous monitoring, employee training, penetration testing, and incident response planning.


reasoning: The paragraph focuses on the experience of executive management (CEO, CFO, controller) and their responsibilities in briefing the audit committee on cybersecurity risks.


reasoning: The paragraph explicitly describes a past cybersecurity incident involving a fraudulent email, details the financial loss incurred, and outlines the response actions taken to strengthen wire transfer procedures.


reasoning: The paragraph explicitly details the responsibilities, reporting structure, and departmental duties of the Chief Information Security Officer (CISO), making it a clear description of management's role.


reasoning: The paragraph describes the general goals and review cadence of the company's internal cybersecurity measures, which falls under risk management processes.


reasoning: The paragraph focuses on the oversight responsibilities of the Board of Directors and specifically names the Risk and Information Security Committee as having primary responsibility for cybersecurity risk oversight.


reasoning: The paragraph explicitly describes a past cybersecurity incident, detailing when it occurred, the scope of the breach (two employee email accounts), the notification timeline, and the specific financial cost incurred.


reasoning: The paragraph explicitly details the role, responsibilities, and professional background/qualifications of the Chief Information Security Officer (CISO), making it a clear fit for Management Role.


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


reasoning: The paragraph focuses on the management team's involvement in cybersecurity risk management and explicitly lists the specific roles responsible for these processes.


reasoning: The paragraph outlines the internal cybersecurity processes and responsibilities managed by the information technology department, focusing on risk assessment, controls, and incident response.


reasoning: The paragraph describes the activities and processes used by management to supervise cybersecurity efforts, such as utilizing threat intelligence and security tools, fitting the Risk Management Process category.


reasoning: The paragraph primarily describes the company's internal incident response and vulnerability management policies, specifically detailing the escalation process to management and the board.


reasoning: The paragraph describes the company's internal cybersecurity processes, including threat hunting, monitoring, threat intelligence sharing, and third-party evaluations.


reasoning: The paragraph primarily discusses the Board of Directors' oversight responsibilities regarding enterprise risk management and highlights the cybersecurity expertise of its members.


reasoning: The paragraph focuses on the role and qualifications of the informational technology consultant who leads the company's cybersecurity strategy.


reasoning: The paragraph details the responsibilities and qualifications of the management team, including a named executive and the quantified combined experience of the IT staff, making Management Role the most appropriate category despite the initial mention of board reporting.


reasoning: The paragraph details the composition and function of a management-level cybersecurity committee, including the CISO as chair and various departmental representatives, making it a Management Role disclosure.


reasoning: The paragraph concludes with a standalone materiality assessment regarding cybersecurity threats for fiscal year 2023, which falls under Strategy Integration. While it also mentions the lack of a formal program and generic management/board oversight, the materiality disclaimer is the most substantive disclosure element.


reasoning: The paragraph describes the company's internal cybersecurity program and the specific frameworks and regulations it aligns with, which falls under Risk Management Process.


reasoning: The paragraph focuses on the specific management roles (CISO, CIO, CRO) responsible for handling escalated cybersecurity threats and highlights their professional experience.


reasoning: The paragraph describes the company's internal cybersecurity processes, specifically vulnerability scanning, threat intelligence, and the use of third-party assessors.


reasoning: The paragraph consists entirely of boilerplate materiality conclusions regarding the absence of material cybersecurity incidents and their impact on business strategy and financial condition.


reasoning: The paragraph explicitly details the management roles, including the Controller and Director - Finance, responsible for overseeing IT communications and reporting cybersecurity threats.


reasoning: The paragraph outlines the key elements of the company's cybersecurity risk management program, including risk assessments, training, and incident response planning.


reasoning: The paragraph briefly mentions past cyber-attacks without detailing a specific incident and discusses the potential future business impact of IT disruptions, aligning with strategy and risk impact integration.


reasoning: The paragraph focuses entirely on the oversight, due diligence, and contractual security requirements imposed on third-party service providers.


reasoning: The paragraph focuses on the role of management, specifically the executive committee and an executive security council, in reviewing cybersecurity strategy, policy, and program effectiveness.


reasoning: The paragraph consists of boilerplate materiality disclaimers regarding the potential impact of future incidents on the company's business strategy and financial condition, along with a cross-reference to the Risk Factors section.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cyber-attacks and cross-references the risk factors section for further discussion on business and financial impacts.


reasoning: The paragraph describes the company's internal incident response process, specifically focusing on severity classification and escalation protocols to leadership and the board.


reasoning: The paragraph focuses entirely on the qualifications, credentials, and experience of specific management roles (Head of Cybersecurity and VP Information Security), fitting the Management Role category.


reasoning: The paragraph describes a specific past incident involving fraudulent wire transfers, detailing the timeline, response actions, and the exact financial loss incurred.


reasoning: The paragraph details management-level committees and roles, specifically the Compliance Committee and Information Governance and Privacy Committee, and their responsibilities for overseeing cybersecurity risks.


reasoning: The paragraph focuses on the composition of the ISSC and the qualifications, reporting lines, and responsibilities of the vCISO, making it a clear fit for Management Role.


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


reasoning: The paragraph primarily details the management team's (including the CIO) role in receiving cybersecurity briefings and making strategic decisions, with a secondary mention of board oversight.


reasoning: The paragraph explicitly describes a past cybersecurity incident, including the date of detection, the nature of the event (unauthorized access), and the response actions taken.


reasoning: The paragraph primarily describes the company's internal processes for identifying, assessing, and managing cybersecurity risks, including integration into the overall enterprise risk management program and the cross-functional team involved in risk assessment.


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


reasoning: The paragraph describes a specific series of attempted attacks (look-alike phishing sites) targeting the company's online banking platform, including the timing and the lack of financial losses.


reasoning: The paragraph primarily discusses the materiality of cybersecurity threats, including a conclusion for 2023 and the material financial impact of a past incident in June 2022.


reasoning: The paragraph focuses on the specific management role responsible for cybersecurity, detailing the VP of IT's title, years of experience, and educational degrees.


reasoning: The paragraph outlines the components of the company's internal cybersecurity program, including risk assessments, incident response planning, and employee training.


reasoning: The paragraph focuses on the creation of the Chief Risk Officer position and their collaboration with the CISO to oversee the cybersecurity risk management program, making Management Role the most appropriate category.


reasoning: The paragraph primarily details the composition of the management-level cybersecurity committee, identifying specific IT leadership roles and their reporting line to the CFO.


reasoning: The paragraph primarily focuses on a materiality assessment of past cybersecurity threats and includes forward-looking materiality disclaimers, which aligns with the Strategy Integration category.


reasoning: The paragraph is entirely focused on the company's processes for managing risks associated with third-party vendors, detailing its Vendor Risk Management Program and Policy.


reasoning: The paragraph describes the internal risk management processes of the management-level Enterprise Risk Management Committee, detailing how it integrates cybersecurity risk assessments and action plans from the CISO and CDO into broader ERM processes.


reasoning: The paragraph provides a generic definition of a Denial of Service attack and contains no substantive disclosure about the company's cybersecurity program or risks.


reasoning: The paragraph primarily describes the company's internal security awareness training and testing programs, which are core components of its risk management processes, alongside a brief mention of cyber insurance.


reasoning: The paragraph is entirely dedicated to the company's third-party risk management program, detailing vendor due diligence and contractual security requirements imposed on service providers.


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


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


reasoning: The paragraph primarily provides a materiality conclusion for the reporting year and briefly mentions a past incident from June 2022 along with its financial and operational impact, fitting the Strategy Integration category.


reasoning: The paragraph explicitly identifies the management roles responsible for cybersecurity (Senior ISO, Director of IT, Director of Information Services) and details their reporting lines and responsibilities.


reasoning: The paragraph describes the company's internal cybersecurity program design and risk assessment processes, specifically noting the adoption of industry frameworks as guides.


reasoning: The paragraph exclusively discusses the company's maintenance of cybersecurity insurance to cover potential incident costs, which falls under strategy integration.


reasoning: The paragraph explicitly details the role of management by describing the establishment, composition, and responsibilities of the Information Security Steering Committee (ISSC).


reasoning: The paragraph primarily details the roles, qualifications (including specific years of experience and education), and reporting structure of management personnel responsible for cybersecurity, such as the CIO and the Cybersecurity Infrastructure Committee.


reasoning: The paragraph primarily describes the company's internal processes for risk assessment, safeguard implementation, and monitoring, while also identifying the specific IT roles responsible for managing these processes.


reasoning: The paragraph focuses extensively on the qualifications, career history, and specific responsibilities of management roles including the CTO, DPI Head, and SSA.


reasoning: The paragraph discusses the potential impact of cybersecurity threats on the company's business strategy, operations, and financial condition, serving as a general strategic overview.


reasoning: The paragraph provides a boilerplate materiality disclaimer regarding past incidents and lists generic cybersecurity risks, which falls under Strategy Integration.


reasoning: The paragraph explicitly identifies the 'Manager of Information Technology' as the leader of the cybersecurity function and describes their reporting line to the Audit Committee.


reasoning: The paragraph describes the company's internal processes for identifying and managing cybersecurity risks, including vulnerability assessments, penetration testing, and tabletop exercises.


reasoning: The paragraph describes the internal management committees (Enterprise Risk and Return Council, Information Security Council) and their specific activities in monitoring, escalating, and mitigating cybersecurity risks, which falls under the risk management process.


reasoning: The paragraph describes the company's internal processes for detecting and responding to cybersecurity incidents, including its incident response plan and tabletop exercises.


reasoning: The paragraph details the company's internal incident response and escalation processes, including the activation of the CIRT and the specific steps for determining materiality and notifying leadership.


reasoning: The paragraph describes the company's internal risk management processes, specifically detailing its use of third-party consultants for penetration testing and red-team exercises to evaluate its own systems.


reasoning: The paragraph is entirely focused on the company's third-party risk management program, detailing how it oversees, assesses, and imposes contractual obligations on third-party service providers.


reasoning: The paragraph describes the functions and responsibilities of the Information Security Department in managing cybersecurity risk and developing control standards, fitting the Risk Management Process category.


reasoning: The paragraph describes the company's internal processes for monitoring threat intelligence and mitigating risks.


reasoning: The paragraph focuses entirely on insurance reimbursements and a boilerplate materiality conclusion regarding a past incident, without describing the incident itself.


reasoning: The paragraph explicitly focuses on the company's reliance on third-party software providers and their process of reviewing SOC reports to assess vendor controls.


reasoning: The paragraph is a standalone statement assessing the potential material impact of cybersecurity threats on the company's business strategy and financial condition.


reasoning: The paragraph primarily details the management structure and personnel responsible for cybersecurity, specifically identifying the Director of IT and the certification qualifications of the IT team.


reasoning: The paragraph focuses on the Board's oversight of the cybersecurity risk management program and its receipt of reports from management, making Board Governance the most applicable category.


reasoning: The paragraph primarily details the management roles responsible for cybersecurity, specifically identifying the CIO and Director of IT, their reporting lines, and their professional experience.


reasoning: The paragraph describes the company's internal cybersecurity processes, such as network monitoring, vulnerability scanning, and email alerts, which are executed by its IT Service Provider.


reasoning: The paragraph details the company's cybersecurity risk management processes, policies, and procedures, which are executed on its behalf by its sponsor, CIM Group.


reasoning: The paragraph explicitly details the management role responsible for cybersecurity (Director of IT), including their reporting structure and specific years of professional experience.


reasoning: The paragraph focuses on the Chief Information Officer, detailing their reporting responsibilities to the Audit Committee and their specific professional background and years of experience.


reasoning: The paragraph describes the company's internal cybersecurity processes, including safeguards, training, incident response exercises, audits, and supply chain resilience efforts.


reasoning: The paragraph describes a standard step in the company's internal incident response procedure, detailing how the incident response team conducts an immediate assessment.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management program, including its processes, audits, vendor due diligence, and employee training.


reasoning: The paragraph explicitly details the responsibilities of management, specifically the COO and Senior Vice President for Operations, in overseeing and implementing the cybersecurity risk management processes.


reasoning: The paragraph discusses the potential business and financial impact of cybersecurity threats, including forward-looking statements about how a material IT event could affect the company's financial condition and operations.


reasoning: The paragraph focuses on executive management being kept informed about the company's cybersecurity posture and potential risks.


reasoning: The paragraph provides a boilerplate materiality disclaimer regarding past incidents and discusses the potential business and financial impact of future breaches, which falls under Strategy Integration.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and managing cybersecurity threats and vulnerabilities.


reasoning: The paragraph focuses on the reporting lines of management (the COO and CFO) regarding cybersecurity risks and their responsibility to update the Board.


reasoning: The paragraph details the specific management roles (CTO and VPCS) responsible for overseeing and managing the cybersecurity risk management program, including their reporting structure, making Management Role the most applicable category despite the initial mention of board oversight.


reasoning: The paragraph explicitly describes a past cybersecurity incident, detailing the date of announcement, the nature of the attack, the specific data compromised, and the response actions taken.


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


reasoning: The paragraph describes the company's internal cybersecurity processes, specifically focusing on employee training, phishing tests, and the IT team's role in implementing the security program.


reasoning: The paragraph explicitly details the responsibilities and functions of specific management roles (Executive Director of IT and CFO) in overseeing and executing the cybersecurity program.


reasoning: The paragraph discusses the potential material adverse impacts of cybersecurity incidents, includes a boilerplate materiality disclaimer stating no past incidents have had such an impact, and cross-references the Risk Factors section.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks and its integration with the enterprise risk management program.


reasoning: The paragraph focuses on the responsibilities of the CISO, who is the grammatical subject, in supervising and assisting the ERMC with cybersecurity risk monitoring.


reasoning: The paragraph explicitly identifies the management role (Senior Director of Cybersecurity), details their experience, and describes the composition of the security steering committee.


reasoning: The paragraph explicitly details the Board of Directors' and Audit Committee's oversight responsibilities regarding cybersecurity risk, including the reporting cadence from management.


reasoning: The paragraph focuses on the composition and responsibilities of the management-level Cybersecurity Team, specifically identifying the CTO and other executives who lead the program.


reasoning: The paragraph focuses entirely on the qualifications, career history, and educational background of the CISO, as well as the composition and experience levels of the Information Security team.


reasoning: The paragraph consists of a boilerplate materiality disclaimer regarding the absence of material cybersecurity incidents and their impact on the business, followed by a cross-reference to the Risk Factors section.


reasoning: The paragraph details the internal processes and committees (ERM, ARB, PMO, internal audit) used to manage and integrate cybersecurity risk, fitting the Risk Management Process category despite mentioning the CITO's reporting lines.


reasoning: The paragraph primarily details the Chief Information Officer's responsibilities, reporting lines to the Audit Committee, and specific professional qualifications, including the experience levels of the CIO and the supporting cybersecurity team.


reasoning: The paragraph focuses exclusively on the Chief Digital Information Officer, detailing their responsibilities, years of experience, and educational background.


reasoning: The paragraph provides a standalone materiality conclusion stating the company has not experienced any material cyber breaches, which falls under Strategy Integration.


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 cross-references to risk factors.


reasoning: The paragraph provides a materiality conclusion regarding the absence of material cybersecurity incidents over the past three years, which falls under Strategy Integration.


reasoning: The paragraph provides a detailed narrative of a specific past cybersecurity incident, including the date of announcement, the attack vector, the data compromised, and the immediate response actions taken.


reasoning: The paragraph introduces the company's reliance on information systems, acknowledges general cyber threats, and mentions the implementation of an Information Security Program for security operations and governance.


reasoning: The paragraph primarily discusses the potential business and financial impacts of cybersecurity risks, including mentions of insurance coverage, costly remediation, and potential material adverse effects on operating results.


reasoning: The paragraph focuses entirely on the Board of Directors and the Audit Committee's oversight responsibilities regarding cybersecurity risk management and incident escalation.


reasoning: The paragraph discusses the potential business and financial impacts of cybersecurity risks, including effects on reputation, operations, and financial condition, which aligns with the Strategy Integration category.


reasoning: The paragraph details the company's internal cybersecurity technologies, tools, and assessment processes, including vulnerability management and third-party audits.


reasoning: The paragraph primarily details the evaluation and security requirements imposed on third-party service providers, alongside a brief boilerplate mention of board oversight.


reasoning: The paragraph details the company's internal cybersecurity processes, including training, vulnerability management, and threat intelligence.


reasoning: The paragraph focuses exclusively on the risks posed by third-party service providers and the company's monitoring of those risks.


reasoning: Although the CISO and CIO are the grammatical subjects of the first two sentences, the paragraph primarily describes the activities and processes they oversee (monitoring, audits, incident response), fitting the Risk Management Process category per the person-vs-function test.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including its adoption of the NIST framework and control testing procedures.


reasoning: The paragraph describes the integration of cybersecurity risk assessment and the incident response plan into the company's overall enterprise risk management framework.


reasoning: The paragraph details the various components of the company's internal cybersecurity risk management program, including policies, risk assessments, security team responsibilities, and training.


reasoning: While the paragraph begins by mentioning Board and Audit Committee oversight, the central and most detailed portion focuses on the specific management roles (CIO and CISO), detailing their extensive professional backgrounds, certifications, and reporting responsibilities.


reasoning: The paragraph is entirely dedicated to the company's oversight of cybersecurity threats presented by third-party vendors, service providers, and external systems.


reasoning: The paragraph describes the company's overall ERM approach and how management oversees cybersecurity risk mitigation, which falls under internal risk management processes.


reasoning: The paragraph explicitly describes a past cybersecurity incident that occurred in 2022, noting its impact on the network and the company's response actions.


reasoning: The paragraph consists entirely of forward-looking, hypothetical risk disclaimers regarding potential cybersecurity threats and their impacts, containing no substantive disclosure about the company's actual cybersecurity program, governance, or incidents.


reasoning: The paragraph primarily focuses on the Director of Information Technology, detailing their interactions with other executives and their responsibility for reporting cybersecurity matters to the audit committee.


reasoning: The paragraph focuses entirely on the company's reliance on third-party service providers, its vendor monitoring processes, and the risks associated with supplier cybersecurity failures.


reasoning: The paragraph describes the integration of cybersecurity risk management into the company's broader enterprise risk management program.


reasoning: The paragraph details the company's internal technical security measures, including authentication methods, encryption protocols, and DDoS protection tools.


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


reasoning: The paragraph focuses on the management-level committee and the InfoSec team responsible for executing the cybersecurity strategy, identifying specific executive roles such as the CISO and CTO.


reasoning: The paragraph details the company's internal technical security controls and architecture, specifically its use of AWS RDS and firewalls to protect data.


reasoning: The paragraph details the company's internal processes, technical controls, and threat intelligence enrollments used to identify, assess, and manage cybersecurity risks.


reasoning: The paragraph details the company's internal cybersecurity program, including its integration into enterprise risk management, testing procedures, and vulnerability scanning.


reasoning: The paragraph primarily discusses the materiality of cybersecurity incidents, noting the absence of a material incident in 2023 while referencing two past breaches, and outlines potential financial and business impacts.


reasoning: The paragraph describes the company's internal cybersecurity program, controls, and procedures, noting its alignment with the NIST framework.


reasoning: The paragraph focuses on the reporting cadence and oversight mechanisms involving the Audit Committee and the full Board of Directors regarding cybersecurity risks.


reasoning: The paragraph discusses the company's ongoing response actions (cooperating with state regulators) related to a specific, real cybersecurity event ('the Data Incident').


reasoning: The paragraph describes the reporting cadence between management and a board committee regarding the company's cybersecurity posture and significant incidents, which is a core element of board governance.


reasoning: The paragraph outlines the key elements of the company's internal cybersecurity program, including risk assessments, training, incident response planning, and third-party risk management.


reasoning: The paragraph describes a specific past incident (an elaborate phishing scam in 2024 that resulted in a loss) and the response actions taken (enabled additional cybersecurity procedures, established new checking accounts).


reasoning: The paragraph is entirely dedicated to the company's processes for assessing and overseeing cybersecurity risks associated with third-party service providers, including vendor questionnaires, due diligence, and contractual security terms.


reasoning: The paragraph describes the company's internal cybersecurity processes, technical safeguards, and employee training programs.


reasoning: The paragraph explicitly details the board of directors' responsibility for overseeing cybersecurity risk management, including the frequency of reports and training they receive.


reasoning: The paragraph describes the company's internal security safeguards, such as firewalls and anti-malware, and the use of external providers for testing, which falls under risk management processes.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity incidents and includes forward-looking disclaimers about potential future impacts.


reasoning: The paragraph explicitly identifies the Vice President of Operations as the management role responsible for directing the cybersecurity programs and outlines their reporting line to the audit committee and board.


reasoning: The paragraph primarily discusses the expected oversight role of the Board of Directors regarding cybersecurity risks and the anticipated reporting cadence from management.


reasoning: The paragraph describes the company's internal incident response policy, specifically focusing on the escalation and reporting processes to management and the Audit Committee.


reasoning: The paragraph explicitly identifies the CISO, outlines their reporting structure, and details their educational background, certifications, and years of experience, making it a clear fit for Management Role.


reasoning: The paragraph is a biography of a corporate officer (Chief Corporate Officer) with no mention of cybersecurity responsibilities, processes, or oversight, making it non-cybersecurity content.


reasoning: The paragraph outlines the company's internal cybersecurity risk management practices and future goals, such as threat detection, tabletop exercises, and incident response readiness.


reasoning: The paragraph details the company's internal incident response and escalation process, specifically how a cross-functional committee assesses events before escalating to the board.


reasoning: The paragraph describes the company's internal risk assessment and control selection processes, explicitly mentioning the adoption of a specific cybersecurity framework.


reasoning: The paragraph describes the company's internal cybersecurity processes, including monitoring systems, incident response practices, and employee training.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management program, its integration with the broader ERM program, and the internal committees and processes used to assess and monitor cyber risks.


reasoning: The paragraph provides a boilerplate statement regarding the absence of material cybersecurity incidents to date, which aligns with materiality assessments and strategy integration.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including its incident response functions, incident classification levels, and escalation procedures.


reasoning: The paragraph primarily details the Audit Committee's oversight of cybersecurity risks and the briefing cadence it receives from the CTO.


reasoning: The paragraph explicitly describes a past cybersecurity incident involving a fraudulent email, details the financial impact, and outlines the remediation actions taken.


reasoning: The paragraph describes the internal cybersecurity controls, prevention methods, and incident response processes utilized by the company's sponsor, Deutsche Bank Group.


reasoning: The paragraph explicitly discusses the materiality of cybersecurity threats on the company's business strategy, results of operations, and financial condition, which falls under Strategy Integration.


reasoning: The paragraph focuses on the CIO's responsibilities, years of experience, and specific certifications, clearly identifying management's role and qualifications in overseeing cybersecurity.


reasoning: The paragraph describes a specific, real-world cybersecurity incident involving a third-party vendor (Change Healthcare), detailing the operational impact on the company's billing processes, response actions taken, and the timeline of the event.


reasoning: The paragraph focuses on the Board and its committees receiving reports and educational presentations on cybersecurity, making Board Governance the most applicable category.


reasoning: The paragraph details the management-level governance structure, specifically the composition of the Cybersecurity Council and the advisory roles of the CIO and VP of Information Security.


reasoning: The paragraph describes the company's internal cybersecurity program and its process for assessing maturity and mitigating risk using third-party evaluations against the NIST framework.


reasoning: The paragraph consists entirely of forward-looking disclaimers regarding the potential impacts of a hypothetical cyber-attack, containing no substantive disclosure about the company's actual cybersecurity program or incidents.


reasoning: The paragraph details the company's cybersecurity risk management processes, including threat detection, technical controls, and framework alignment, which are implemented and managed by its property manager, IHM.


reasoning: The paragraph describes the company's internal processes for incident response planning, testing, and data backups, which falls under Risk Management Process.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including its adoption of the CIS Controls framework to guide its program.


reasoning: The paragraph describes the company's internal cybersecurity awareness training, phishing simulation exercises, and role-based training processes.


reasoning: The paragraph describes the company's internal processes for identifying and assessing cybersecurity risks, detailing the methods used by their consultant and vendor to monitor the threat environment.


reasoning: The paragraph details management's role in cybersecurity by identifying the CIO and CISO as leaders of the cybersecurity crisis management team and describing the specific management-level committees responsible for incident response and disclosure.


reasoning: The paragraph introduces the company's overall risk management process and how cybersecurity is integrated into it, outlining the goals of identifying, prioritizing, and monitoring risks.


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


reasoning: The paragraph details the reporting cadence between management (the COO) and the Audit Committee, focusing on the committee's oversight, strategic involvement, and annual review of the cybersecurity program.


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


reasoning: The paragraph describes the company's internal cybersecurity risk management program, policies, and processes, which are central to the Risk Management Process category.


reasoning: The paragraph primarily describes the company's internal incident response processes, specifically detailing the function and management of its Data Security Event Plan (DSEP).


reasoning: The paragraph explicitly details the board of directors' and audit committee's roles in overseeing cybersecurity risks.


reasoning: The paragraph describes the internal processes and responsibilities of the MAT, CIO, and CISO in assessing and reporting cybersecurity threats, focusing on the function rather than individual qualifications.


reasoning: The paragraph primarily describes the company's internal incident reporting, escalation, and response processes, including a specific four-tier risk identification system.


reasoning: The paragraph explicitly describes a past cybersecurity incident from June 2018 involving unauthorized email access and $10 million in fraudulent disbursements, making it an Incident Disclosure despite the inclusion of materiality conclusions.


reasoning: The paragraph describes the company's internal processes for incident response planning and testing, which falls under Risk Management Process.


reasoning: The paragraph discusses the ongoing investigation, scope, and potential data compromise (PII) of a specific cybersecurity incident.


reasoning: The paragraph describes the company's internal cybersecurity program and its use of external service providers to evaluate and enhance its security policies, which falls under risk management processes.


reasoning: The paragraph primarily describes the company's internal cybersecurity programs, frameworks adopted (NIST, ISA/IEC 62443), testing procedures, and integration with the Enterprise Risk Management program. Although the CISO is mentioned, the focus is on the function and processes of the risk management program rather than the individual's qualifications.


reasoning: The paragraph focuses entirely on the oversight of third-party service providers, including compliance assessments, SOC 2 report reviews, and contractual notification requirements.


reasoning: The paragraph explicitly describes a past ransomware incident, including the specific date it was detected, the systems impacted, and the resulting operational service delays.


reasoning: The paragraph explicitly describes a past cybersecurity incident, detailing the date of the attack, the specific systems affected, the response actions taken, and the investigation outcomes.


reasoning: The paragraph discusses the potential material impact of cybersecurity threats on the company's business strategy, results of operations, and financial condition.


reasoning: The paragraph describes the scope and response actions of a specific cybersecurity incident, detailing what data was and was not accessed and the subsequent notification process.


reasoning: The paragraph primarily discusses the Board of Directors and Audit Committee's oversight of cybersecurity risks, including the reporting cadence from management to the board.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, including the date of discovery, the nature of the attack (encryption and monitoring software), and the immediate response actions taken.


reasoning: The paragraph describes a specific past cybersecurity incident, including the date of discovery, the systems accessed (email systems), and the resulting operational impact (misdirected vendor payments).


reasoning: The paragraph describes the company's internal procedures for monitoring IT systems, detecting deviations, and identifying security incidents.


reasoning: The paragraph consists entirely of a forward-looking disclaimer about potential future impacts and a cross-reference to the Risk Factors section, containing no substantive cybersecurity disclosure.


reasoning: The paragraph details the composition and responsibilities of a management-level Cybersecurity Steering Committee, including the CISO, making it a Management Role disclosure.


reasoning: The paragraph details the company's internal processes for assessing cybersecurity risks, monitoring vulnerabilities, and lists generic categories of security tools used.


reasoning: While the paragraph begins by discussing the Board and Audit Committee's oversight, the latter half provides extensive, highly specific details about the Chief Technology Officer's responsibilities, tenure, and external board memberships, making Management Role the most substantive focus.


reasoning: The paragraph primarily focuses on the management roles responsible for cybersecurity, specifically detailing the composition of the DPIRC and the extensive qualifications and tenure of the Vista CIO.


reasoning: The paragraph explicitly discusses the board of trustees' oversight of cybersecurity risks and details the specific information security expertise of two named board members.


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 primarily discusses the Board and Audit Committee's oversight of cybersecurity risks, the selection of directors with cyber expertise, and the reporting cadence from management to the Board.


reasoning: The paragraph primarily details the Information Security Officer (ISO), focusing heavily on their specific years of experience and numerous industry certifications, which clearly falls under Management Role.


reasoning: The paragraph focuses on the reporting cadence and escalation protocols to the board and its specific committee (BRCC), detailing how the board maintains oversight of cybersecurity risks.


reasoning: The paragraph details the company's internal cybersecurity risk assessment processes and the specific safeguards and controls implemented, such as MFA, vulnerability scanning, and digital asset key controls.


reasoning: The paragraph describes the company's basic approach to managing cybersecurity risks, including the use of standard commercial software and general oversight by the CEO.


reasoning: The paragraph provides a standalone materiality conclusion stating that no material cybersecurity incidents have occurred to date, which falls under Strategy Integration according to the classification rules.


reasoning: The paragraph focuses on the management team's composition and their supervisory role over the cybersecurity program and personnel.


reasoning: The paragraph explicitly names management roles (SVPF and Director of IT) as the grammatical subjects and describes their responsibilities in identifying and managing cybersecurity risks.


reasoning: The paragraph primarily focuses on the CIO's qualifications, reporting structure, and leadership over the IT department's cybersecurity efforts.


reasoning: The paragraph focuses on the management-level cybersecurity sub-committee, detailing their combined years of experience and their operational responsibilities in managing cybersecurity risks.


reasoning: The paragraph details the company's internal cybersecurity risk assessment processes, vulnerability scanning, and ISO 27001 certification audits.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and their potential impact on the company's financial condition and business objectives.


reasoning: The paragraph describes the company's internal processes for assessing cybersecurity risk, specifically mentioning penetration testing and vulnerability assessments.


reasoning: The paragraph consists entirely of a forward-looking disclaimer regarding the effectiveness of the company's cybersecurity program and a cross-reference to the Risk Factors section, containing no substantive disclosure.


reasoning: The paragraph primarily discusses the integration of cybersecurity into the enterprise risk management framework and provides a standalone materiality conclusion regarding past and ongoing cybersecurity threats.


reasoning: The paragraph explicitly describes a past cybersecurity incident that occurred in November 2023, detailing its operational impact, data exfiltration, and subsequent remediation actions.


reasoning: The paragraph primarily focuses on the CISO's role, responsibilities, and specific professional qualifications, making Management Role the most appropriate category despite a brief mention of board oversight.


reasoning: The paragraph focuses exclusively on the company's oversight of third-party service providers, including onboarding risk assessments and contractual security requirements.


reasoning: The paragraph describes the company's internal cybersecurity processes, including continuous monitoring tools, incident response planning, and employee training.


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


reasoning: The paragraph explicitly describes two past cybersecurity incidents from September 2022, detailing the nature of the unauthorized access, the affected systems (Rockstar Games and 2K Games), and the response actions taken.


reasoning: The paragraph explicitly identifies specific management roles (President of P&T, CDO) and outlines their responsibilities in leading the company's cybersecurity assessment and management processes.


reasoning: The paragraph describes how the company's cybersecurity and IT functions are managed and provided through agreements with specific named affiliates, establishing their baseline risk management approach.


reasoning: The paragraph explicitly describes a past cybersecurity incident, detailing the date (February 2023), the nature of the attack (ransomware encrypting servers), and the company's response and recovery actions.


reasoning: The paragraph describes a specific past cybersecurity incident involving employee interactions with suspicious websites and details the subsequent containment and investigation.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including change management, patching, MFA, backups, and continuous monitoring.


reasoning: The paragraph primarily discusses the Board of Directors and the Audit Committee's oversight of cybersecurity risks, including the cadence of briefings from the CISO.


reasoning: The paragraph focuses on the composition, responsibilities, and qualifications of a management-level Cybersecurity Committee, making Management Role the most appropriate category.


reasoning: The paragraph primarily describes the company's internal cybersecurity program, its integration into the enterprise risk management framework, and the specific processes and activities (risk assessments, tabletop exercises, training) used to manage cyber risk.


reasoning: The paragraph provides a statement regarding the absence of material cybersecurity incidents affecting business operations, which falls under Strategy Integration.


reasoning: The paragraph outlines the company's internal processes and procedures for assessing, identifying, and managing cybersecurity risks, including risk assessments, incident response procedures, and employee training.


reasoning: The paragraph focuses on the management team's responsibilities, specifically identifying the CISO, the establishment of an information technology risk committee, and the reporting lines to the management risk committee and the Board.