content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: This paragraph contains a standalone materiality conclusion ('not experienced a material cybersecurity incident') without any description of an actual incident event, which per the tiebreaker rules makes it Strategy Integration. The language is entirely generic boilerplate that could apply to any company—no named entities, frameworks, dates, or firm-specific details.

provider: moonshotai

stage: benchmark


content_category: None/Other

reasoning: This paragraph describes IT systems and data handling in general operational terms without any substantive cybersecurity disclosure. It contains no board oversight, management roles, risk processes, third-party risk, incident description, or strategy integration. It is purely contextual/introductory language that could appear in any company's filing.


reasoning: This is a standalone materiality conclusion with no incident narrative—explicitly stating no material cybersecurity incidents have affected the company. The cross-reference to Risk Factors does not change the classification per the tiebreaker rules. No named entities, dates, frameworks, or specific details appear; this is standard boilerplate language that could apply to any company.


content_category: Incident Disclosure

reasoning: This paragraph describes an actual cybersecurity incident with specific dates (June 21, 2023; June 22, 2023; August 2023), named product (MOVEit), named subsidiary (Umpqua Bank), and specific headcount (429,252 customers), making it clearly Incident Disclosure with Quantified-Verifiable specificity.


content_category: Risk Management Process

specificity_confidence: medium

reasoning: The paragraph describes the company's internal risk assessment and threat monitoring processes (what the program DOES), not the CISO's personal qualifications, so it's Risk Management Process. The CISO title is cybersecurity-specific, and the specific technologies listed (intrusion detection systems, SIEM tools, threat intelligence programs) are firm-specific details about the actual security stack deployed.


content_category: Management Role

reasoning: The paragraph is fundamentally about the PERSON leading cybersecurity (the Senior Director of Cybersecurity with 15+ years experience) and their supporting governance structure (security steering committee with specific member composition). While some process elements appear, the grammatical subjects are the cybersecurity team leader and the steering committee members, making this Management Role. The cybersecurity-specific title 'Senior Director of Cybersecurity' and named committee with specific departmental composition are firm-specific facts, but only one hard verifiable fact (the 15 years experience) exists—no second hard fact like a date, dollar amount, percentage, or named third-party firm to reach Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and its use of multiple frameworks/standards as guides for identifying, assessing and managing risks. The grammatical subject is the program itself, not the board or a specific management role. While the paragraph names several specific standards (NIST, ISO/IEC 27001, ISO/IEC 27017, SOC 2, CSA, EU frameworks), these are all external, recognized standards that any company could reference. The only firm-specific element is the claim of maintaining certifications, but the explicit disclaimer that this 'does not imply that we specifically or comprehensively comply' weakens this to essentially naming standards rather than asserting verifiable firm-specific facts. No dates, dollar amounts, headcounts, named third-party firms, or named tools appear.


reasoning: The paragraph focuses on the Information Security Director and CIO as persons—their reporting structure, responsibilities, and career credentials (years of experience, tenure at the company). The person-vs-function test confirms this is about the people, not processes: removing their titles and experience would break the paragraph. While it mentions CIRT and CIC selection, this is framed as a responsibility of the Information Security Director, not a description of how those teams function. Specific facts include cybersecurity-specific titles, named internal programs (CIRT, CIC), and specific numbers (55 and 31 combined years), but only one hard verifiable fact type (the combined years counts as one fact type, not two separate hard facts) prevents Quantified-Verifiable.


reasoning: The paragraph describes the company's internal risk management activities (identifying, prioritizing, assessing, monitoring, mitigating risks) and an annual assessment process. While it mentions ADP's name, this is a standard company self-reference, and the activities described (ERM integration, annual assessments) are generic practices applicable to any company. No cybersecurity-specific titles, named frameworks, specific dates, or quantified details appear.


reasoning: The paragraph describes the company's internal security processes (testing, scanning, threat intelligence review, consulting) without naming any specific frameworks, dates, tools, or third-party firms. 'Cybersecurity consultants' and 'security vendor' are unnamed, and practices like penetration testing and vulnerability assessments are common across all companies. No cybersecurity-specific roles, named committees, or quantified details appear.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, organizational structure, and program components. While it mentions the CTO and CISO, the focus is on what the program DOES (technical controls, monitoring, training, third-party tools) rather than personal qualifications of the CTO. The CTO's tenure is mentioned as supporting context, not as the central topic. The specific cybersecurity titles (CTO overseeing CISO, dedicated security team) make this Firm-Specific.


reasoning: The paragraph describes internal risk management activities (designing safeguards, addressing gaps, monitoring effectiveness) without referencing specific frameworks, named roles, dates, tools, or organizational structures unique to the company. This is generic language applicable to any entity conducting risk assessments.


reasoning: The paragraph describes the company's internal cybersecurity awareness and training processes, including phishing exercises and tabletop exercises. It focuses on what the program does rather than identifying specific management personnel or board oversight.


reasoning: This paragraph contains a standalone materiality disclaimer stating that cybersecurity threats have not materially affected the company, which falls under Strategy Integration per the guidelines. It contains no specific facts, dates, named roles, or frameworks—only generic boilerplate language that could appear in any filing.


reasoning: The paragraph describes the company's internal incident response workflow, including escalation procedures from the IRT to the CIEC, materiality assessment protocols, and engagement of external advisors. This focuses on the company's own processes for handling cybersecurity threats rather than describing a specific incident or governance structure.


reasoning: The paragraph describes internal cybersecurity processes (monitoring, analysis, remediation, vulnerability testing) without referencing a specific incident, board oversight, or management roles. It mentions engaging outside vendors only as a component of internal testing processes rather than as a central vendor oversight topic. The language is entirely generic—no named frameworks, tools, dates, roles, or third-party firms—and could apply to any company.


reasoning: The paragraph describes internal employee training programs and technology-based mitigation measures, which are core components of the company's risk management processes. However, it contains only generic references to 'key employees,' 'various cybersecurity trainings,' and 'technology-based tools' without naming specific frameworks, tools, dates, or quantifiable details, making it indistinguishable from boilerplate language applicable to any company.


reasoning: The paragraph focuses on the CISO as a person—qualifications, experience, and career history—making this Management Role per the person-vs-function test. The CISO title and 'more than 20 years of experience' are firm-specific facts, but only one hard verifiable fact (the 20 years) exists, so this does not reach Quantified-Verifiable.


content_category: Third-Party Risk

reasoning: The paragraph exclusively addresses vendor and third-party security oversight, including assessments and monitoring for compliance with company standards. It contains no specific dates, named frameworks, roles, or quantifiable details that would distinguish it from generic disclosure language applicable to any company.


reasoning: The paragraph describes a specific past cybersecurity incident with date (April 2022), scope (disrupted hospital operations, exfiltration of patient information), and response actions (remediation costs, system enhancements). Despite mentioning financial impacts, the primary content is the incident narrative itself, which per tiebreaker rules makes this Incident Disclosure rather than Strategy Integration. The specificity is Firm-Specific due to the specific date, but does not reach Quantified-Verifiable as no dollar amounts, headcounts, percentages, or named third-party firms/products are disclosed.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and their integration with Enterprise Risk Management, overseen by specific cybersecurity leadership roles (CIO and CISO). The focus is on the function and processes rather than the individuals' qualifications, making it Risk Management Process rather than Management Role.


content_category: Board Governance

reasoning: The paragraph focuses on board committee oversight with the Risk Committee as the grammatical subject receiving reports, making this Board Governance. The Risk Committee is a named non-generic committee, and specific reporting cadences (annual and quarterly) with named internal program (Information Security Program) provide firm-specific details, though not enough hard verifiable facts for Quantified-Verifiable.


reasoning: This paragraph describes the company's internal cybersecurity risk management processes (identification, assessments, training, vendor engagement) with the company as the grammatical subject. While it contains specific details about their program structure (global assessments, specific technical IT risk assessments, consortium participation, several-times-yearly testing), these are organizational/programmatic specifics rather than hard verifiable facts like dates, dollar amounts, or named third-party firms. The 'leading security and technology vendors' and 'various consortiums' remain unnamed.


reasoning: Paragraph contains biographical details of a Senior Vice President overseeing a business segment (AFP) with no reference to cybersecurity responsibilities, governance, or risk management processes. It is non-cybersecurity content.


reasoning: This paragraph describes the company's internal risk management processes and governance structure for cybersecurity, with internal committees (ORMC, ERMC) and specific roles (Chief Operational Risk Officer, Chief Risk Officer) as the grammatical subjects. While it mentions the Risk Committee and Board, the central focus is on management committees and their escalation procedures, not board oversight itself.


reasoning: The paragraph contains a forward-looking materiality assessment regarding potential cybersecurity impacts on business strategy and financial condition, along with a cross-reference to Risk Factors. It does not describe specific governance structures, management roles, internal processes, or actual incidents.


reasoning: This is a pure cross-reference paragraph with no substantive cybersecurity disclosure—no board oversight, management roles, processes, incidents, or strategy content. It merely directs readers to other sections of the filing.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and managing cybersecurity risks based on the NIST framework, which falls under Risk Management Process. It names the NIST CSF standard but contains no firm-specific details such as implementation dates, specific roles, tools, or organizational structures unique to Norfolk Southern.


reasoning: The paragraph contains a standard materiality disclaimer stating that cybersecurity threats have not materially affected the company, which falls under Strategy Integration per the instructions. It lacks any specific dates, incidents, roles, frameworks, or quantifiable details, making it generic boilerplate language that could appear in any filing.


reasoning: The paragraph describes the company's internal Cyber Security Watch Team (CSWAT) and its risk management functions, including reviewing security programs and business continuity processes. It contains firm-specific details including the named team 'CSWAT' and the specific cross-functional composition of IT, operations, risk, legal and compliance leaders.


reasoning: The paragraph describes the company's internal cybersecurity program, risk assessment methodology, and controls against industry standards. It explicitly names the NIST Cybersecurity Framework and Cyber Risk Institute Cyber Profile as assessment benchmarks but contains no firm-specific details such as named roles, dates, headcounts, or unique organizational structures.


reasoning: The paragraph describes internal disclosure procedures, controls, and compliance programs related to cybersecurity incidents, which falls under risk management processes. The content is generic boilerplate referencing standard disclosure controls and insider trading restrictions applicable to any public company, with no specific frameworks, roles, dates, or quantifiable details unique to Northern Trust.


reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity risk, with these entities as grammatical subjects. It contains no specific facts, dates, named roles, or frameworks—only generic governance structure language that could apply to any company.


reasoning: The paragraph describes Tredegar's internal Cybersecurity Program and its risk-based functions (preventing, identifying, investigating, resolving, and mitigating vulnerabilities), which constitutes a risk management process. While third-party service providers are mentioned, they are a component of the program's scope rather than the central topic. The disclosure identifies a specific internal program by name ('Cybersecurity Program' or 'the Program'), making it firm-specific rather than generic boilerplate.


reasoning: The paragraph provides a detailed narrative of the MOVEit Transfer cybersecurity incident, describing the third-party vendor involvement, the scope of affected customer data, response actions (patching, investigation, notification), and operational impact. It meets the Quantified-Verifiable threshold with two hard verifiable facts: the named third-party firm Progress Software Corporation and the named software product MOVEit Transfer.


reasoning: The paragraph provides a standalone materiality conclusion stating that cybersecurity incidents have not materially affected the business to date, accompanied by forward-looking disclaimers about potential future impacts. It contains no description of actual incidents, governance structures, or management roles. The language is standard boilerplate that could appear in any company's filing without modification.


reasoning: The paragraph describes the company's internal enterprise risk management processes for identifying and mitigating cybersecurity risks, but contains no specific frameworks, named roles, dates, or quantifiable details that would distinguish it from any other company's disclosure.


reasoning: The paragraph identifies the Information Security Officer (ISO) as the responsible party for implementing the cybersecurity program, details the specific cross-functional composition of the supporting team (including risk/compliance and IT members), and specifies the ISO's reporting line to the Senior Risk Officer, focusing on organizational structure and roles rather than processes.


reasoning: The paragraph provides a materiality assessment stating that no cybersecurity incidents have materially affected the company, which falls under Strategy Integration per the tiebreaker rules for materiality disclaimers. It contains no specific dates, dollar amounts, named entities, or other verifiable facts, making it generic boilerplate language that could apply to any company.


reasoning: The paragraph describes ongoing internal activities to improve cybersecurity capabilities and organizational structure, which falls under risk management processes. However, it contains no specific details—no named frameworks, dates, dollar amounts, headcounts, or unique program identifiers—that would distinguish this disclosure as specific to CONMED rather than any other company.


reasoning: The paragraph describes an actual cybersecurity incident, providing specific details including the date (July 2018), the attack type (ransomware), affected systems (Dx IT systems), and investigation findings regarding data exfiltration. While it concludes with a materiality assessment, the primary content is the incident narrative. The specificity is Firm-Specific due to the specific date and the reference to 'Dx' (diagnostics) systems, which is unique to LabCorp's business operations.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks, including annual risk assessments and control implementation, which falls under Risk Management Process. It contains no specific dates, named roles, frameworks, or quantifiable details, making it generic boilerplate language that could apply to any company.


reasoning: Paragraph describes the company's internal cybersecurity processes, including incident response planning, system patching, and benchmarking against unnamed frameworks, fitting Risk Management Process. Contains no named standards (e.g., NIST, ISO), specific dates, dollar amounts, headcounts, or named tools, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including threat detection, monitoring, vulnerability management, and incident response protocols. It references specific cybersecurity roles (CISO) and organizational structures (CSIRT, SOC) that are unique to this company's disclosure, as well as annual NIST assessments, making it firm-specific rather than generic boilerplate.


reasoning: The paragraph describes the company's internal information security program processes, including engaging external assessors for security improvements and forensic reviews. While it mentions third-party engagement, this is a component of internal risk management rather than vendor oversight as the central topic. The language contains no named frameworks, specific dates, identified firms, or unique operational details, making it generic boilerplate applicable to any company.


reasoning: Paragraph contains a standalone materiality conclusion stating that cybersecurity challenges have not materially impaired operations or financial standing, without describing any specific incident. The cross-reference to Risk Factors does not alter the classification. No specific entities, dates, frameworks, or quantified details are present.


reasoning: The paragraph describes the company's internal cybersecurity awareness and training procedures (mandatory education, phishing tests, remedial training), which falls under Risk Management Process. However, it lacks any specific details—no dates, headcounts, named tools, or unique program identifiers—and describes generic practices applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including framework adoption, policy development, and employee training. It names specific recognized industry standards (NIST, CIS, COBIT, ISO) but contains no firm-specific details such as dates, headcounts, named roles, or unique organizational structures that would identify AAON specifically.


reasoning: The paragraph describes the company's internal process of engaging external threat intelligence sources and forensic services as part of its cybersecurity program, which falls under Risk Management Process. It names two specific, verifiable external organizations (H-ISAC and FBI's InfraGard), meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes an actual ransomware incident that occurred on May 4, 2022, including detection, containment measures, and system restoration, which fits the Incident Disclosure category. The specific date provides a firm-specific detail, though only one hard verifiable fact is present, making it Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph describes a specific cybersecurity incident that occurred on February 3, 2025, including details of the attack (unlawful network access, encryption of applications, data exfiltration) and immediate response actions (activating incident response plan, engaging experts), which meets the definition of Incident Disclosure. The specific date makes this Firm-Specific, but there is only one hard verifiable fact (the date), so it does not reach Quantified-Verifiable.


reasoning: The paragraph provides a standard materiality disclaimer stating that cybersecurity threats and prior incidents have not materially affected the company, which falls under Strategy Integration. The cross-reference to Risk Factors does not change this classification. The language is entirely boilerplate with no specific dates, incidents, roles, or frameworks identified.


reasoning: Paragraph contains standalone materiality conclusions regarding cybersecurity risks and previous incidents (stating they have not materially affected business strategy, results of operations, or financial condition) without describing any specific incident narrative, which aligns with Strategy Integration per the tiebreaker rules. The materiality disclaimer language is standard boilerplate that could apply to any company, with no named entities, dates, frameworks, or specific details.


reasoning: The paragraph focuses on the qualifications, credentials, and tenure of specific cybersecurity management personnel (CISO and CIO), making it Management Role. It contains multiple independently verifiable quantitative facts including specific years of experience (10+ and 15+) and educational credentials (computer science degree), meeting the Quantified-Verifiable threshold per calibration examples.


reasoning: Paragraph describes the company's internal cybersecurity policies and control standards across generic domains (identity management, network security, incident response, etc.) without naming specific frameworks, tools, dates, or unique organizational structures that would identify this as specific to Lakeland Bancorp.


reasoning: The paragraph describes internal processes for evaluating cybersecurity program effectiveness and reviewing strategy/policy, which falls under Risk Management Process. It contains no specific facts—references to 'executive committee' are standard governance structures, 'an executive security council' uses indefinite article suggesting a descriptive mechanism rather than a formal named committee, and phrases like 'cross-functional, enterprise-wide' are generic descriptors without dates, numbers, frameworks, or specific tools.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment processes, including annual assessments and engagement of external assessors, which falls under Risk Management Process. However, it contains no named frameworks (NIST, ISO, etc.), specific dates, named roles (CISO, CIO), named third-party firms, or other unique identifiers—only generic activities (risk identification, prevention, mitigation) and vague cadences ('at least annually', 'periodically') that could appear in any company's filing.


reasoning: The paragraph describes internal processes including employee training cadence, vendor contract review procedures, and insurance coverage, but contains no specific frameworks, named third-party providers, dates, or quantified metrics. Terms like 'third party service provider' and 'annual basis' are generic, and 'General Partner' is a standard governance reference for partnership structures rather than a cybersecurity-specific disclosure.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and prioritizing cybersecurity risk using various tools (third-party assessments, internal audits, tabletop exercises, penetration testing). While it mentions reporting to the Audit Committee, the primary focus is the risk management function itself rather than board oversight. No specific frameworks, dates, dollar amounts, named vendors, or unique program identifiers are disclosed.


reasoning: The paragraph constitutes a standalone materiality assessment, stating that prior cybersecurity incidents have not materially affected the company while acknowledging ongoing risks could. Per tiebreaker rules, brief mentions of past incidents coupled with materiality conclusions as the main point map to Strategy Integration. The text contains no specific dates, dollar amounts, named third parties, or other verifiable facts—only generic boilerplate language applicable to any registrant.


reasoning: The paragraph describes the company's internal risk assessment processes involving coordination between internal audit and external experts. It contains no named third-party firms, specific dates, quantified metrics, or unique program identifiers—only generic references to 'the Program,' 'the Plan,' and 'internal audit team' that could apply to any company.


reasoning: The paragraph provides a materiality assessment stating that no cybersecurity incidents have materially affected operations or financial standing, and cross-references Risk Factors for additional discussion. This aligns with Strategy Integration, which includes standalone materiality conclusions and materiality disclaimers. The language is entirely boilerplate and could apply to any company, containing no specific details about the company's cybersecurity program, governance structure, or actual incidents.


reasoning: The paragraph provides a standalone materiality disclaimer regarding past cybersecurity incidents and potential future business impact, which maps to Strategy Integration per the tiebreaker rules ('Materiality disclaimers... → Strategy Integration, even if boilerplate'). It contains no specific dates, dollar amounts, named frameworks, or cybersecurity-specific roles, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on the CISO as a person, detailing career history, promotion timeline (2013), prior experience (14 years), and reporting structure, which fits the Management Role category per the Person-vs-Function test. It meets the Quantified-Verifiable threshold with two hard verifiable facts: the specific year 2013 and the 14-year tenure duration.


reasoning: The paragraph focuses on the Audit Committee's central oversight role and specific composition, with management roles (CIO, CSIRT, SVP Technology and Innovation) mentioned only to establish reporting lines to the committee. It contains firm-specific details including cybersecurity-specific titles and the specific expertise areas of board members.


reasoning: The paragraph describes the company's internal incident response capabilities, mentioning third-party providers as a supplementary component of their process rather than focusing on vendor oversight or risk assessment. It contains no named entities, dates, frameworks, or quantifiable details—only generic references to 'third party providers' and standard technology categories (IT/OT) that could apply to any company.


reasoning: The paragraph focuses on Board and Committee oversight activities (reporting, annual briefings, continuing education) with the Board as the grammatical subject. The mention of the CISO—a cybersecurity-specific title—provides the single firm-specific fact required for this classification, though it lacks additional hard verifiable facts (dates, amounts, named vendors) needed for Quantified-Verifiable.


reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities, briefing cadence, and interactions with management regarding cybersecurity risk. As the Audit Committee (a board committee) is the grammatical subject throughout, this is Board Governance. The disclosure identifies the CISO—a cybersecurity-specific role—which qualifies as a firm-specific fact, but lacks two or more hard verifiable facts (dates, dollar amounts, headcounts, percentages, or named third-party firms/tools) required for Quantified-Verifiable.


reasoning: The paragraph's grammatical subject is the Audit Committee, describing its oversight of cybersecurity risks and annual briefing cadence from management. This is standard board governance disclosure. No specific facts (dates, named firms, cybersecurity-specific titles, certifications, or unique program identifiers) are present; all elements (Audit Committee, annual reports, incident response plan, third-party assessments) are generic and applicable to any company.


reasoning: The paragraph primarily describes the oversight responsibilities of the Board of Directors and Audit Committee regarding cybersecurity risks, including the briefing cadence and types of updates received from management. While management roles are mentioned, the board and committee are the grammatical subjects of the majority of sentences, and the focus is on governance structure rather than the specific qualifications or processes of management. The identification of the 'Chief Information Officer' as a specific cybersecurity role elevates the specificity from generic boilerplate.


reasoning: The paragraph discusses the company's commitment to establishing and sustaining cybersecurity measures to protect information systems, which falls under internal risk management processes. However, it contains no specific details, named frameworks, roles, dates, or quantifiable facts—only generic statements about the importance of cybersecurity that could apply to any company.


reasoning: The paragraph consists primarily of forward-looking disclaimers about cybersecurity limitations ('may not be sufficient,' 'No system is entirely secure') and concludes with a cross-reference to Item 1A Risk Factors. It contains no substantive disclosure regarding board governance, management roles, risk management processes, or incidents.


reasoning: The paragraph focuses exclusively on oversight of third-party cybersecurity risks, making Third-Party Risk the appropriate category. It contains no named entities, dates, frameworks, or specific details, rendering it generic boilerplate applicable to any company.


reasoning: Paragraph describes the integration of cybersecurity into the company's enterprise risk management program and internal assessment processes (IT infrastructure evaluations, compliance audits), but contains no named frameworks, specific roles, dates, dollar amounts, or other firm-unique details that would distinguish it from any other company's disclosure.


reasoning: The paragraph identifies specific cybersecurity management positions (CISO and Director of IT Security, Risk and Compliance) and describes their qualifications and experience, fitting the Management Role category. It contains firm-specific details including cybersecurity-specific titles, a named internal committee (ISC), and a specific quantification of experience (20 years).


reasoning: The paragraph describes management's activities in steering cybersecurity processes and frameworks (specifically the 'three lines of defense' model), but does not identify specific management roles (CISO/CTO/CIO), their qualifications, or reporting lines. It contains no firm-specific details such as dates, named standards (NIST, ISO), specific tools, or hard metrics, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity incident response workflow, escalation procedures, and cross-functional coordination. While it references the Sr Director of Tech, it focuses on the process and organizational structure (what the role does) rather than the individual's qualifications or background, making it a process description rather than a management role profile.


reasoning: The paragraph describes management's responsibilities for integrating cybersecurity into business processes, risk strategy, incident preparation, and security assessments, which falls under Risk Management Process. It contains no specific details, dates, dollar amounts, named frameworks, or cybersecurity-specific titles that would identify it as unique to Akili—it could apply to any company.


reasoning: The paragraph focuses exclusively on oversight of vendors and service providers, contractual indemnification terms, and third-party cybersecurity requirements, making 'Third-Party Risk' the appropriate category. The language contains no named entities, specific dates, frameworks, or quantifiable details, and could apply to any company unchanged.


reasoning: The paragraph describes the company's internal cybersecurity processes for risk identification, assessment, and mitigation (monitoring, threat assessments, technical controls). While it mentions the CFO and third-party providers as part of the function's composition, the focus is on what the program does rather than the person's qualifications or vendor oversight. No specific frameworks, named vendors, dates, dollar amounts, or unique organizational details are provided—only generic descriptions of security activities and controls that could apply to any company.


reasoning: The paragraph describes generic incident response procedures (containment, analysis, recovery) without referencing specific events, dates, systems, or tools, indicating it is part of the company's internal risk management process rather than a disclosure of an actual incident.


category_confidence: medium

specificity_confidence: low

reasoning: Paragraph describes the company's membership in an external Data Privacy Board for benchmarking purposes, which constitutes part of its risk assessment and management process. Contains one named third-party organization (Data Privacy Board), but lacks additional hard verifiable facts (dates, numbers, specific tools) needed for Quantified-Verifiable.


reasoning: Describes the company's internal risk management activities (assessments, tabletop exercises, audits) where third-party engagement is a component of the process rather than the central topic of vendor oversight. The specific year '2024' constitutes one firm-specific date, but unnamed firms and vague quantifiers ('several') prevent reaching the Quantified-Verifiable threshold.


reasoning: The paragraph identifies specific management structures and roles, including an Executive Cybersecurity Steering Committee comprised of senior leadership and local Information Security Officers designated by business units, along with their reporting cadences and certification requirements. It contains firm-specific details by naming a non-generic management committee and cybersecurity-specific role titles, but lacks quantifiable data such as headcounts, dates, or dollar amounts necessary for Quantified-Verifiable classification.


reasoning: Paragraph contains a standalone materiality conclusion stating no previous cybersecurity threats have materially affected the company, which falls under Strategy Integration. The language is generic boilerplate with no specific dates, amounts, named entities, or firm-specific details.


reasoning: The paragraph describes a specific past cybersecurity incident with a precise date (April 2022), operational impact (disruption to hospital operations), and data scope (exfiltration of confidential company and patient information), satisfying the Incident Disclosure definition. It contains one specific date, which qualifies as a firm-specific fact, but lacks a second hard verifiable fact (such as dollar amounts, headcounts, or named third-party firms) needed for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and its integration with enterprise risk management, which falls under Risk Management Process. It explicitly names the NIST Cybersecurity Framework (800-171) but contains no firm-specific details such as dates, specific roles, team compositions, or tools, resulting in Sector-Adapted specificity.


reasoning: The paragraph contains a standalone materiality disclaimer stating that cybersecurity risks 'have not materially affected us, including our business strategy, results of operations or financial condition,' which per the guidelines maps to Strategy Integration even when boilerplate. It provides no specific dates, dollar amounts, named roles, or other verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph describes an actual cybersecurity incident with specific dates (February 16, 2022), detailing the intrusion, network disruption, impacted systems, and response actions including engagement of third-party experts, which qualifies as Incident Disclosure. The specificity is Firm-Specific due to the inclusion of the specific incident date, though it lacks a second hard verifiable fact (such as named third-party firms, dollar amounts, or headcounts) needed for Quantified-Verifiable.


reasoning: The paragraph focuses on specific cybersecurity management roles (CIO, CISO, VP of Product Security) and their reporting lines to board committees. While it mentions processes, the grammatical subjects are the management positions, making this a description of management structure rather than internal processes or board governance.


reasoning: Paragraph describes the company's internal incident response framework, testing protocols, and escalation procedures. While it references specific leadership titles (CITO, CIRO), the focus is on the processes and governance of the IR Plan itself rather than the individuals' qualifications or backgrounds.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including ERM integration, the NIST framework structure (identify, protect, detect, respond, recover), and specific policy domains. While it mentions the Board and Audit Committee, the grammatical focus is on the cross-departmental program, policies, and layered strategy—not board oversight mechanisms or specific management personnel. It cites the NIST framework (a recognized standard) but contains no firm-specific details like named cybersecurity roles, specific dates, tool names, or unique program identifiers.


reasoning: The paragraph describes the company's internal risk management processes, including controls monitoring, vulnerability management, and security awareness training. It identifies the cybersecurity-specific role 'VP of Information Security' and a named internal program 'Security Awareness Program' (presented in quotes), which qualifies as firm-specific content.


reasoning: Paragraph describes the company's internal privacy risk management processes, including privacy impact assessments, data flow mapping, and governance structure (GPO supported by data protection officers and specialists), which falls under Risk Management Process. It contains no named frameworks, specific dates, dollar amounts, named tools, or unique identifiers that would distinguish it from any other company's disclosure, making it Generic Boilerplate.


reasoning: The paragraph describes internal risk management processes (incident monitoring, risk management processes, incident response plan operation, and disclosure controls) rather than individual qualifications or an actual incident. While the InfoSec Leadership Team is the grammatical subject, the content focuses on the functions and processes they manage, not their personal credentials or reporting structure.


reasoning: The paragraph identifies specific executive titles (CDIO and VP of Platforms, Infrastructure and Cybersecurity) responsible for cybersecurity and describes their professional qualifications and tenure, making it about management roles rather than processes.


reasoning: The paragraph describes internal risk management processes (directing, coordinating, planning, and organizing security activities) rather than the CDO's personal qualifications or reporting lines. The specific title 'CDO' is not generic C-suite (like CEO/CFO) and identifies the firm's unique organizational structure.


reasoning: The paragraph focuses on Board oversight activities, describing the annual briefing cadence on cybersecurity posture and the Board's participation in strategy discussions. While CIO and CISO are mentioned, they appear as participants in the briefing process rather than the subject of the disclosure, and the paragraph passes the person-vs-function test (it would still make sense without the titles).


reasoning: The paragraph describes the company's internal cybersecurity incident response workflow, including threat identification, escalation protocols, cross-functional assessment, and reporting cadence to leadership and the Board. It identifies specific cybersecurity roles (VP of Tech) and detailed team compositions (IT specialists, accountants, lawyers) that distinguish it from generic disclosures.


reasoning: The paragraph focuses primarily on the Audit and Finance Committee's oversight responsibilities and briefing cadence (receiving updates from management), making the board committee the grammatical and topical subject. While management roles are identified, they are discussed in the context of reporting to the committee rather than as the primary topic. The disclosure names specific cybersecurity leadership titles (CDTO, CISO) and the specific board committee name, distinguishing it from generic boilerplate.


reasoning: The paragraph describes the company's internal product cybersecurity risk assessment and management processes within its specific E-Systems business unit, including alignment with the ISO 21434 framework and the company's certification to this standard in 2023. This focuses on internal risk management activities and framework adoption rather than board oversight, management roles, or incidents.


reasoning: The paragraph focuses on the Board of Directors and its specific committees (RAC and TEC) providing oversight of cybersecurity risk management, with the CISO mentioned only briefly as reporting to these committees. The disclosure includes specific committee abbreviations and the cybersecurity-specific CISO role, which distinguishes it from generic boilerplate.


reasoning: The Audit Committee is the grammatical subject performing oversight activities (receiving quarterly reports, engaging with leadership on risk topics), which is the defining characteristic of Board Governance. The disclosure identifies specific cybersecurity leadership roles (CIO and CISO), making it Firm-Specific rather than generic boilerplate.


reasoning: The paragraph describes the Audit Committee's oversight of cybersecurity risk, with the committee as the grammatical subject reviewing management's activities. However, it references only the standard 'Audit Committee' (explicitly excluded as generic), unspecified 'management,' and a 'quarterly' cadence without specific dates, frameworks, or firm-unique details that would distinguish this disclosure from any other company.


reasoning: The paragraph focuses entirely on the qualifications, career histories, and educational backgrounds of specific cybersecurity-related management personnel (CISO, CIO, and CRO), making it a clear Management Role disclosure. It contains multiple hard verifiable facts including specific durations (17 years, 35 years, 30 years), a specific year (2005), and named professional certifications (CISM, CERT Certificate in Cybersecurity Oversight), meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal governance structure for managing cybersecurity risk, focusing on the Information Security Council's functions (monitoring, decision-making, escalation, policy oversight) rather than individual qualifications. It contains firm-specific details including the CISO role, named councils (ISC and Enterprise Risk and Return Council), and specific departmental representation (Privacy, Legal and Technology), but lacks quantifiable data like dates, headcounts, or dollar amounts needed for Quantified-Verifiable.


reasoning: The paragraph contains forward-looking materiality disclaimers regarding the potential impact of future cybersecurity incidents on 'business strategy, results of operations, or financial condition,' which per the categorization rules falls under Strategy Integration (materiality assessments). However, it provides no substantive details about the company's actual cybersecurity program, governance structure, or risk management processes, and consists entirely of generic disclaimer language that could apply to any company, plus a cross-reference to Risk Factors.


reasoning: The paragraph describes the company's internal procedures for incident detection, analysis, mitigation, and escalation frameworks, which are core risk management processes. It contains no specific details such as dates, named cybersecurity roles (e.g., CISO), recognized standards (e.g., NIST), or quantifiable metrics—only generic references to 'senior management,' 'Board,' and an 'established incident prioritization framework' that could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity processes, controls, and framework adoption (NIST 800), which constitutes risk management processes. While third-party risks are mentioned, they are discussed as components of the company's own risk oversight processes rather than as the central topic of vendor requirements.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment methodology (asset identification, criticality evaluation, and threat impact assessment) without referencing specific frameworks by name, organizational roles, dates, or quantifiable details unique to GUESS INC.


reasoning: The paragraph describes the company's internal risk-based process for identifying and overseeing cybersecurity risks presented by third parties, making it a Risk Management Process disclosure rather than purely Third-Party Risk (which focuses on contractual requirements imposed on vendors). It contains only generic descriptions of third-party relationships (e.g., 'application providers,' 'penetration testing firms') and oversight approaches without naming specific vendors, frameworks, dates, or quantifiable metrics, rendering it Generic Boilerplate.


reasoning: The paragraph focuses on the CAO's qualifications, tenure, and career history (including prior CIO role), making it about the management role rather than the process itself. It contains firm-specific details including cybersecurity-specific titles and a specific tenure duration.


reasoning: The paragraph describes the board of directors' oversight responsibility for cybersecurity risk and delegates this function to the audit committee, fitting the Board Governance category. However, it contains only generic references to standard governance bodies ('board of directors', 'audit committee', 'executive officers') without naming specific cybersecurity frameworks, specialized roles (e.g., CISO), dates, or quantifiable details, making it Generic Boilerplate.


reasoning: The paragraph describes internal processes for threat identification, detection, and risk evaluation, fitting Risk Management Process. It lacks specific details—no named frameworks, tools, dates, headcounts, or organizational structures—and uses only generic language ('various processes,' 'periodically,' 'multiple forums') applicable to any company.


reasoning: The paragraph focuses on the qualifications, tenure, and credentials of the Information Technology Director and Director of Information Security (management roles), satisfying the Person-vs-Function Test for Management Role. It meets the Quantified-Verifiable threshold with multiple hard facts: a specific duration ('over ten years') and numerous named professional certifications (CISSP, CCSP, GIAC, GCFA, GCIH).


reasoning: The paragraph centers on identifying the VP of IT/Information Security Officer, their qualifications (24 years experience, 2 years tenure), reporting relationships (to CFO and audit committee), and the specific composition of the IT Executive Steering Committee. This describes management roles and structure rather than internal processes or board oversight. It contains specific titles, committee names, and exact durations that are unique to this disclosure, but lacks two hard verifiable facts (dates, dollar amounts, specific headcounts, or named third-party firms/tools) required for Quantified-Verifiable.


reasoning: The paragraph describes internal reporting cadences, review processes, and assessment procedures for cybersecurity events, focusing on what the program DOES rather than the CTO's personal qualifications. It identifies firm-specific elements including the CTO role and the uniquely named 'Digital QBR' program, but lacks quantifiable data such as dates, dollar amounts, or headcounts required for Quantified-Verifiable.


reasoning: The paragraph concludes with a standalone materiality assessment stating that no incident has materially affected the company, which falls under Strategy Integration per the tiebreaker rules. The text contains no specific dates, roles, frameworks, or verifiable facts—only generic statements about cyber threats and standard materiality language that could apply to any financial institution.


reasoning: The paragraph focuses on the qualifications, credentials, and educational backgrounds of specific executives (Mr. Madigan and Mr. James) comprising the InfoSec Leadership Team, fitting the Management Role category under the person-vs-function test. It contains firm-specific details including named individuals, specific degrees, and the cybersecurity team name, but only one hard quantifiable fact (60 years), making it Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph describes an actual cybersecurity incident that occurred on December 30, 2022, including operational impact (production delays, delayed shipments) and response actions, fitting the Incident Disclosure definition. It contains three specific dates (December 30, 2022; January 6, 2023; February 10, 2023), exceeding the two-fact threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's internal Information Security Program and controls designed to comply with regulatory requirements, placing it in Risk Management Process. While it mentions the Board and senior management, it does so only to describe regulatory guidelines imposed upon them rather than detailing specific governance practices. The disclosure names specific financial sector frameworks (GLBA, SOX, FFIEC) but contains no firm-unique details such as specific dates, headcounts, named roles, or tools, making it Sector-Adapted.


reasoning: The paragraph describes the company's internal risk management process of leveraging its client-facing cybersecurity consultants to advise internal IT teams and provide supplemental incident response capabilities. However, it contains no named frameworks, specific dates, quantified metrics, named roles (e.g., CISO), or named third-party firms that would distinguish it from any other professional services firm. References to 'directors,' 'executives,' and 'segment or regional leaders' are generic governance and organizational descriptors.


reasoning: The paragraph centers on the IT/Cybersecurity Committee (a board committee), its oversight responsibilities, meeting frequency, and composition, making Board Governance the primary category. It contains firm-specific details including named committees, cyber-specific titles (CIO, CISO), and specific departmental compositions, but lacks two hard verifiable facts (dates, dollar amounts, headcounts, or named third-party firms/tools) required for Quantified-Verifiable.


reasoning: The paragraph introduces the company's cybersecurity risk management approach and its integration with overall enterprise risk management, but contains only generic descriptive language ('multifaceted approach', 'assessing, identifying, and managing') without naming specific frameworks, roles, organizational structures, or dates that would identify it as unique to Trimble.


reasoning: The paragraph describes the company's internal processes for cybersecurity risk identification, assessment, and monitoring (program maintenance, vulnerability assessments, penetration testing, tabletop exercises), which falls under Risk Management Process. It contains no named frameworks (NIST, ISO, etc.), specific dates, cybersecurity-specific roles (CISO), named tools/products, or quantifiable details—only generic descriptions of common security practices that could apply to any company.


reasoning: The paragraph describes the company's internal processes for monitoring cybersecurity risks through briefings, threat intelligence, external consultants, and security tools. While it mentions the CISO and Sr. Director of Information Security, the focus is on the monitoring function and activities rather than the individuals' qualifications or reporting structure (per the person-vs-function test). The disclosure includes cybersecurity-specific titles (CISO, Sr. Director of Information Security), which satisfy the firm-specific threshold, but lacks quantifiable details like specific dates, dollar amounts, headcounts, or named third-party firms/products required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal data protection controls (encryption methods for laptops and data), which falls under Risk Management Process. It contains no named standards, specific technologies, dates, or quantifiable details, making it generic language applicable to any company.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks, including monitoring, incident response readiness, employee training, and disaster recovery. While it references reviewing third-party SOC reports, this is presented as one component of the broader internal control system rather than the central topic. The disclosure names the specific SOC 1, Type 2 standard but contains no other firm-specific details such as named roles, dates, or unique program identifiers.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks ('have not materially affected...') without describing a specific incident, which falls under Strategy Integration per the category tiebreakers. The inclusion of the specific date 'December 31, 2023' constitutes one hard verifiable fact, making the disclosure Firm-Specific rather than generic boilerplate.


reasoning: The paragraph focuses on the qualifications, reporting lines, and responsibilities of the Vice President of Information Technology and Security and CIO, making it a Management Role disclosure. It includes firm-specific details such as the specific cybersecurity title and the exact tenure (25 years), but contains only one hard verifiable fact, making it Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph describes the Board of Directors' oversight structure for cybersecurity risk, specifically noting the absence of a dedicated committee and the full Board's retention of responsibility. While the Chief Risk Officer is mentioned, this is a generic enterprise risk title (not a CISO/CTO/CIO per the taxonomy), and the reporting relationships use generic entities ('Board of Directors', 'internal audit department') and vague cadences ('regularly') without specific dates, frameworks, or quantifiable details.


reasoning: The paragraph describes a specific historical cybersecurity incident (the AMCA Incident) involving unauthorized access to patient data at a third-party vendor, including the specific notification date (May 14, 2019), the named external agency (AMCA), and subsequent litigation and regulatory response actions.


reasoning: The paragraph provides a detailed narrative of the February 2022 cyber-attack, including specific dates, system scope (connectivity, operating and accounting systems globally), operational impact (limited operations for approximately three weeks), and response actions. While it mentions subsequent investments and the addition of a CISO, the primary substance is the incident description. Specific dates, durations, and cybersecurity-specific roles make this firm-specific, though it lacks the second hard verifiable fact (dollar amount, exact headcount, or named third-party firm) needed for Quantified-Verifiable.


reasoning: This paragraph provides a standalone materiality assessment regarding cybersecurity threats and their impact on business strategy, results of operations, and financial condition, without describing any specific incident details. It contains standard boilerplate language that could apply to any company, with no named entities, specific dates, dollar amounts, or unique identifiers.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident including the exact date of occurrence (October 31, 2023), specific subsequent filing dates (November 2, 9, and December 15, 2023), the nature of the unauthorized access, and specific response actions taken (system shutdowns, law enforcement notification). This clearly describes what happened in an actual incident rather than discussing governance, risk processes, or materiality assessments.


reasoning: The paragraph focuses on the CISO as an individual, detailing specific biographical qualifications including tenure (13 years) and career experience (20 years), which falls under Management Role. It meets the Quantified-Verifiable threshold with two specific numeric facts (13 and 20 years) that are independently verifiable, plus the cybersecurity-specific title.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, including the disclosure date (June 13, 2023), operational impact (paused operations, nine-day recovery), response actions, and quantified financial damages ($80-85M revenue loss, $35-40M earnings impact). This meets the criteria for Incident Disclosure with Quantified-Verifiable specificity due to multiple independently verifiable hard facts (specific date and precise dollar amounts).


reasoning: The paragraph describes the company's internal cybersecurity processes (implementing safeguards, continuous monitoring, maturity assessments) and framework adoption (NIST CSF), focusing on what the team does rather than the CIO's personal qualifications. It identifies the CIO (a cybersecurity-specific title per the IS list) and names the NIST framework, meeting the Firm-Specific threshold.


reasoning: The paragraph contains a standalone materiality conclusion stating that cybersecurity threats are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which falls under Strategy Integration per the tiebreaker rules. The language is generic boilerplate that could apply to any company, containing no specific dates, named roles, frameworks, or verifiable facts.


reasoning: Describes internal cybersecurity monitoring processes and control assessments without naming specific frameworks, tools, dates, or organizational structures unique to the company. The reference to 'executive team' is generic and the program components listed are standard security practices applicable to any organization.


reasoning: The paragraph describes the company's internal risk assessment and monitoring processes, including the organizational structure of cybersecurity supervisory divisions (64 members across specific named divisions) and their reporting lines to the Risk Management Officer and Committee. While management roles are mentioned, the focus is on the functional process and organizational composition rather than individual qualifications.


reasoning: The paragraph details the company's internal incident response workflow and escalation protocols, including activation criteria for the Cyber Incident Response Team (CIRT), notification chains to the CISO and General Counsel, and the specific composition of a committee convened to assess materiality. This describes organizational processes rather than individual qualifications or an actual incident.


reasoning: The paragraph consists primarily of a standard materiality disclaimer stating that cybersecurity threats have not materially affected the company, which falls under Strategy Integration. It contains no specific dates, incidents, roles, frameworks, or quantifiable details—only generic risk language and a cross-reference to Risk Factors that could appear in any filing.


reasoning: The paragraph focuses on the CISO's personal qualifications, professional certifications, and career history (30+ years experience, CISA certification), which falls under Management Role per the person-vs-function test. It meets Quantified-Verifiable specificity by containing two hard verifiable facts: a specific duration (30 years) and a named professional certification (Certified Information Systems Auditor), analogous to the calibration example citing CISSP/CISM certifications and years of experience.


reasoning: The paragraph provides a brief mention of a past ransomware incident but focuses primarily on the materiality conclusion ('did not have a material impact') and resulting business strategy shifts (accelerated IT initiatives), fitting the Strategy Integration tiebreaker rule. The reference to '2021' provides a specific date that distinguishes this disclosure from generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management procedures, including ERM integration, risk register maintenance, and monitoring cadences. It contains no specific dates, named frameworks, identifiable roles (e.g., CISO), quantified metrics, or firm-unique details—only generic process language applicable to any company.


reasoning: The paragraph contains a standalone materiality disclaimer regarding prior cybersecurity incidents without describing any specific incident details (dates, scope, or response actions), which per the tiebreaker rules maps to Strategy Integration. The language is boilerplate and could apply to any company, containing only generic references to 'prior cybersecurity incidents' and the company's 'Enterprise Risk Management program' without specific dates, dollar amounts, named roles, or unique program identifiers.


reasoning: The paragraph describes the company's internal risk assessment processes, including annual assessments and risk register updates, but contains no specific details, dates, named frameworks, or unique identifiers that would distinguish it from standard boilerplate disclosure applicable to any company.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and managing cybersecurity threats through monitoring, automated tools, vulnerability assessments, and tabletop exercises. While it mentions 'IT vendors' and 'officers,' the focus is on the functions and processes performed rather than on specific governance structures or vendor oversight as the central topic. The disclosure contains no named frameworks, specific tools, dates, headcounts, or dollar amounts—only generic security practices (threat detection, patch management, DDoS protection) that could apply to any company.


reasoning: The paragraph provides a standalone materiality conclusion stating that past cybersecurity breaches have not materially affected the company's business strategy, results of operations, or financial condition, without describing any specific incident or internal processes. It consists of boilerplate language and cross-references to Risk Factors that could apply to any company, containing no named frameworks, dates, dollar amounts, or specific organizational details.


reasoning: The paragraph culminates in a standalone materiality conclusion stating the company has not experienced material cybersecurity breaches or incurred material related expenses, which aligns with Strategy Integration's scope for materiality assessments. It contains no specific dates, dollar amounts, named roles, or certified frameworks—only generic references to an ERM program and standard risk types—rendering it generic boilerplate.


reasoning: The paragraph focuses on the CISO and CRO roles, their qualifications, reporting lines (to CRO and committees), and responsibilities, with board committees mentioned as context rather than primary focus. It contains multiple firm-specific details including named non-generic committees (Enterprise Risk Management Committee, Enterprise Risk Committee), cybersecurity-specific titles (CISO), specific headcounts (three independent directors), and specific team compositions.


reasoning: The paragraph describes the company's internal processes for identifying and managing cybersecurity risks, fitting the Risk Management Process category. However, it contains only generic language ('various information security processes') without naming specific frameworks, roles, dates, tools, or organizational details that would identify it as unique to this company.


reasoning: The paragraph describes the company's internal incident escalation and reporting workflow, including the process for reporting to management, escalating to the Incident Response Team, and following the business continuity plan. While it identifies the Business Continuity Coordinator (BCC) and CLO, the focus is on the functions and process rather than the individuals' qualifications or backgrounds. The identification of the 'Business Continuity Coordinator' as the leader of the Incident Response Team provides a firm-specific organizational detail analogous to an HSE Director overseeing cybersecurity.


reasoning: The paragraph identifies the Chief Information Officer (a cybersecurity-specific management title) and the ITSC as the entities providing reports to the Board, describing management's reporting structure and lines of communication. The Board is the recipient, not the grammatical subject, making this a management role disclosure rather than board governance.


reasoning: The paragraph describes the company's use of unnamed third-party consultants for standard cybersecurity functions (penetration testing, monitoring, incident response) as part of its internal risk management approach, but contains no named vendors, specific dates, dollar amounts, or other verifiable details that would identify this as unique to T2 Biosystems.


reasoning: The paragraph describes internal risk management processes and collaboration between the enterprise risk management team, CSO, and IT risk team to evaluate cybersecurity risks, focusing on the function rather than the individual's qualifications or reporting structure. It identifies the specific cybersecurity leadership role of Chief Security Officer, which distinguishes it from generic boilerplate.


reasoning: The paragraph describes the company's internal processes for assessing and maturing its cybersecurity program, including self-evaluations, vulnerability management, and third-party maturity assessments. It references specific external evaluators (DCMA) and defense-sector compliance frameworks (CMMC, DoD RMF) that are unique to this company's operating context.


reasoning: The paragraph describes the company's internal risk assessment methodology and ERM integration for identifying material cybersecurity threats. It references a specific internal organizational unit (the 'GRC' team) but contains no quantifiable metrics, dates, or external verification points that would elevate it to Quantified-Verifiable.


reasoning: The paragraph focuses on the organizational structure of the cybersecurity team, reporting lines to the CISO, and specific professional certifications held by team members, which aligns with the Management Role category. It contains multiple firm-specific details including the CISO title, 'Cyber Security Office' department name, and named industry certifications (CISSP, CISM, CRISC, CEH), but lacks quantifiable data (dates, dollar amounts, headcounts, named vendors) required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal process of using third-party service providers to test, audit, and validate its cybersecurity controls, which falls under risk management activities rather than vendor oversight. It contains no named frameworks, specific dates, named firms, or unique organizational details that would distinguish it from any other company's disclosure.


reasoning: The paragraph describes a board committee receiving reports from management on cybersecurity risks and incidents, fitting the Board Governance category definition. It contains no specific identifying details—referring only to 'The Committee' (likely the standard Audit Committee), 'management,' and vague cadences like 'regular' and 'as necessary'—making it generic boilerplate that could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity processes and controls (monitoring, defensive approach, tools for threat detection), which falls under Risk Management Process. It contains no specific frameworks, roles, dates, tools, or quantifiable details—only generic descriptions of security practices that could apply to any company.


reasoning: The paragraph describes the company's internal process for monitoring and reporting cybersecurity risks to the Board, with the 'cybersecurity team' as the grammatical subject. While the Audit Committee is mentioned as the recipient of reports, the board is not the grammatical subject, so this does not qualify as Board Governance under the strict grammatical subject rule. The text contains no specific dates, named frameworks, specific role titles (e.g., CISO), dollar amounts, or named third parties—only generic references to 'quarterly' reports, 'third-party assessments,' and the 'cybersecurity team.'


reasoning: Paragraph describes the company's internal incident response plan, team composition, and escalation processes. The detailed enumeration of specific departments constituting the incident response team (including marketing, facilities, and distribution) provides a firm-specific organizational detail.


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


reasoning: The paragraph describes the company's internal process for designing and assessing its cybersecurity program using recognized frameworks, which falls under Risk Management Process. It names specific standards (ISO 27001, CIS 18, NIST) but explicitly disclaims certification or compliance, providing no firm-specific implementation details, dates, or organizational facts unique to Commerce.com.


reasoning: The paragraph describes board oversight and reporting cadence regarding cybersecurity, with the board of directors as the grammatical subject. It contains only generic references to the 'board of directors' and 'regularly reported' without naming specific committees, dates, frameworks, or cybersecurity-specific roles, rendering it generic boilerplate applicable to any company.


reasoning: The paragraph describes internal risk management activities (defining policies, standards, and control systems) but contains no specific frameworks, dates, roles, or other identifying details that would distinguish this disclosure from any other company's filing.


reasoning: The paragraph describes internal cybersecurity awareness and training processes (phishing simulations, security policies, employee training) rather than specific board oversight, management roles, or incidents. While 'Executive management' is mentioned, the focus is on the function/culture rather than specific personnel qualifications. The language is entirely generic—using vague cadences ('regular,' 'periodic') and common practices without naming specific frameworks, dates, numbers, tools, or unique program identifiers that would distinguish this disclosure from any other company.


reasoning: The paragraph describes a specific cybersecurity incident from November 2022, including the attack vector, scope (PII access), operational impact (loan origination delays), and response actions. It contains two specific dates (November 2022, January 2024) and a specific headcount (five lawsuits), meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal third-party risk management program and enterprise issue management process, emphasizing internal lifecycle management (due diligence, oversight, exit planning) and ERM integration rather than specific vendor contractual requirements. It contains no named frameworks, specific dates, quantified metrics, unique program identifiers, or other firm-specific details, consisting entirely of generic process descriptions applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity processes, including employee training, technology deployment, and policies across areas like Incident Response and Third-Party Risk Management. While third-party consultants are mentioned, they are described as tools for conducting penetration tests and audits rather than being the central topic of vendor oversight. The disclosure contains no named frameworks, specific roles, dates, dollar amounts, or unique program identifiers—only generic descriptions of security activities that could apply to any company.


reasoning: The paragraph describes the company's internal processes for preventing, detecting, and mitigating cyber risks (briefings, threat intelligence, security tools), making it Risk Management Process. It contains no named frameworks, specific titles, dates, vendors, or quantifiable details—only generic references to 'management team,' 'external consultants,' and 'security tools' that could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, controls, and integration with overall risk governance. While the Audit Committee is mentioned as reviewing risks annually, the board is not the grammatical subject and the focus is on the program itself rather than board oversight. The disclosure contains no specific frameworks, roles, dates, or quantifiable details, consisting entirely of generic language applicable to any company.


reasoning: The paragraph contains generic introductory statements about recognizing the importance of cybersecurity and dependence on IT systems without describing specific governance structures, management roles, risk management processes, or incidents. It serves as contextual framing rather than substantive disclosure of the company's cybersecurity program.


reasoning: The paragraph describes the Technology and Cybersecurity Risk Committee (TRCC), a management governance committee, and its oversight responsibilities for BlackRock's cybersecurity risk management practices, including escalation and remediation procedures. It identifies specific internal committees (TRCC, ERC) and the CISO role, making it firm-specific rather than generic boilerplate.


reasoning: The paragraph centers on specific cybersecurity leadership roles (Acting CISO and Acting CIO), their qualifications (30 years combined experience), and reporting structure. While it mentions the ERMC, the grammatical focus is on management personnel rather than board oversight or process mechanics, satisfying the Person-vs-Function test for Management Role. It contains firm-specific details including cybersecurity-specific titles and a named ERM committee, but lacks two hard verifiable facts (dates, dollar amounts, headcounts, percentages, named third-party firms, or tools) required for Quantified-Verifiable.


reasoning: The paragraph describes internal programs for incident response, business continuity, and disaster recovery, which are risk management processes. However, it contains only generic references to 'programs,' 'periodic exercises,' and standard activities (identify threats, evaluate risk) without naming specific frameworks, roles, dates, tools, or organizational details that would identify this as unique to BV Financial.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, enterprise risk assessment integration, and alignment with recognized frameworks (NIST CSF and CMMI). It contains no firm-specific details such as dates, named roles, headcounts, or named third-party firms.


reasoning: The paragraph describes the company's internal incident response procedures, monitoring practices, and employee training, which falls under Risk Management Process. It is Firm-Specific because it identifies the cybersecurity-specific title 'Vice President of Infrastructure and Security' and details the specific cross-functional composition of the Incident Response team (legal, HR, finance), distinguishing it from generic disclosures.


reasoning: The paragraph describes an actual cybersecurity incident detected in early April 2023 and details the company's response actions including investigation, law enforcement engagement, and security enhancements. The specific date 'early April 2023' qualifies as a firm-specific fact, though insufficient alone to reach Quantified-Verifiable status.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents (stating they have not been material and are not reasonably likely to materially affect the business) without describing any specific incident narrative, which fits the Strategy Integration definition. It contains no specific dates, dollar amounts, named roles, or other unique identifiers—only generic materiality language that could apply to any company.


reasoning: The paragraph describes a specific ransomware incident that occurred in May 2022, including detection, response actions (engaging forensic experts, notifying law enforcement), system restoration, and the decision not to pay ransom, which falls under Incident Disclosure. It contains a specific date (May 2022) and a specific factual detail about the ransom payment decision, making it firm-specific rather than generic boilerplate, but lacks a second hard verifiable fact (such as a dollar amount or named third-party firm) needed for Quantified-Verifiable.


reasoning: The paragraph describes internal process improvements (hardening identity environments, security awareness training, MFA implementation) following a prior cybersecurity event, which falls under Risk Management Process. However, it contains no specific dates, named products/tools (only generic categories like 'Endpoint Detection and Response'), headcounts, or percentages. References to 'quarterly' cadence and 'three-pronged approach' are generic descriptors that could apply to any company.


reasoning: The paragraph describes internal processes for reporting and integrating cybersecurity risks into the company's ERM program and internal audit function, rather than focusing on the qualifications or background of the Chief Security and Trust Officer. While the CSTO is mentioned as the actor, the content centers on what the role does (providing reports) and how risk information flows through organizational processes, fitting the Risk Management Process category. The specificity is Firm-Specific due to the naming of the cybersecurity-specific executive role (Chief Security and Trust Officer), though no quantifiable metrics or dates are provided.


reasoning: Paragraph describes the company's internal cybersecurity processes including policy publication, compliance promotion, risk assessments, and technical mitigation measures. While it mentions the CIO and Security Officer, the focus is on the team's functions rather than individual qualifications, satisfying the Person-vs-Function test for Risk Management Process. Specificity is Firm-Specific due to the naming of cybersecurity-specific leadership titles (CIO, Security Officer), but lacks quantifiable data or named third parties required for Quantified-Verifiable.


reasoning: The paragraph identifies a specific cybersecurity management position (Senior Principal Security and Infrastructure Architect) and describes the incumbent's professional qualifications and tenure (over 20 years experience), which focuses on the person rather than the processes they manage.


reasoning: Paragraph describes the company's internal process for identifying, assessing, and managing cybersecurity risks through monitoring and evaluation activities, fitting Risk Management Process. The specific departmental composition 'finance and operations department' serves as the firm-specific detail distinguishing this disclosure from generic boilerplate.


reasoning: Paragraph contains a standalone materiality disclaimer stating that cybersecurity threats have not materially affected the company, which per instructions maps to Strategy Integration. Language is entirely boilerplate with no specific dates, roles, frameworks, or verifiable facts.


reasoning: The paragraph describes the company's internal cybersecurity processes and framework adoptions (NIST CSF, C2M2), which are specific risk management activities. While NIST and C2M2 are recognized standards, the explicit reference to 'BPU' (New Jersey Board of Public Utilities) identifies the specific state regulatory jurisdiction applicable to this New Jersey utility, making the disclosure firm-specific rather than generic sector boilerplate.


reasoning: The paragraph describes the CFO's management function in providing cybersecurity updates to the Board, with the grammatical focus on management reporting lines. The specific role abbreviations DIT and DIS (cybersecurity-specific titles) identify unique organizational roles within this company, distinguishing it from generic boilerplate.


reasoning: The paragraph identifies specific cybersecurity management positions (CTO, VP of IT, Senior Director of IT Security), describes their qualifications and experience, and outlines their reporting relationship to the Board. While Board oversight is mentioned, the grammatical focus and detail are on the management hierarchy and personnel rather than Board governance processes or risk management methodologies.


reasoning: The paragraph constitutes a standalone materiality assessment stating that previous cybersecurity incidents have not materially affected the company's business or financial condition, without describing any specific incident narrative, dates, or scope. It contains only standard SEC boilerplate language regarding materiality and a generic cross-reference to Risk Factors, with no named entities, specific dates, dollar amounts, or firm-unique operational details.


reasoning: The paragraph discusses potential business and financial impacts of cybersecurity incidents (material adverse effects on operations and financial condition) without describing specific governance structures, management roles, or internal processes. It represents forward-looking risk disclosure regarding materiality rather than a description of actual risk management activities or an incident narrative.


reasoning: The paragraph centers on the Enterprise Security Director's personal qualifications (26 years tenure, CISSP certification) and reporting structure, satisfying the Person-vs-Function test for Management Role. It contains two hard verifiable facts (specific duration of experience and named professional certification), meeting the Quantified-Verifiable threshold.


reasoning: The Audit Committee is the grammatical subject overseeing cybersecurity risk reporting, fitting Board Governance. The disclosure uses entirely generic language—standard committee names, unspecified 'periodic' cadence, and generic 'management' references without naming specific roles, frameworks, dates, or organizational structures unique to CalciMedica.


reasoning: Paragraph describes the company's internal risk assessment, audit, and training processes, fitting the Risk Management Process category. While the activities (audits, training, third-party support) are generic, the reference to 'CIST' appears to be a firm-specific designation for its cybersecurity team or leadership role (distinct from generic 'CISO' or standard titles), elevating the paragraph from generic boilerplate to firm-specific.


reasoning: The paragraph comprehensively describes the Company's internal cybersecurity risk management processes across governance, technical safeguards, incident response, third-party oversight, and education. While the Board and CIO are mentioned, the focus is on the program's activities and controls rather than personal qualifications or board structure. The disclosure includes two hard verifiable facts—the specific year 2023 and the named entity FBI (which conducted training)—as well as firm-specific organizational details (CIO title, IT/legal/operations department composition), warranting a Quantified-Verifiable classification.


reasoning: The paragraph describes the CISO's qualifications, prior positions, and educational background, as well as the cybersecurity team's combined experience and professional certifications, fitting the Management Role category under the person-vs-function test. It contains multiple quantifiable hard facts including specific durations of experience and numerous named professional certifications (CISSP, CCSP, GSEC, etc.), meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's internal risk assessment and ERM integration processes, including how management prioritizes and mitigates threats. While it mentions the COO and General Counsel, it focuses on their functions (what the roles do) rather than their personal qualifications, making it about the process. It contains no specific facts—only generic C-suite titles (COO, General Counsel), standard governance entities (audit committee), and boilerplate ERM references without named frameworks, dates, or quantifiable details.


reasoning: The paragraph consists of generic forward-looking risk language ('As are other businesses,' 'from time to time,' 'there can be no assurance') and a cross-reference to Risk Factors, without disclosing specific incidents, governance structures, or risk management processes. It lacks substantive cybersecurity program details.


reasoning: The paragraph describes the company's internal communication and escalation procedures for cybersecurity incidents, including processes for assessing materiality and engaging various internal stakeholders. While it mentions an 'internal disclosure committee' and concludes with a materiality disclaimer about past incidents, it contains no named frameworks, specific dates, dollar amounts, headcounts, or other verifiable facts unique to the firm—describing generic processes applicable to any public company.


reasoning: The paragraph describes the company's internal processes for assessing its cybersecurity program against a recognized framework and evaluating third-party risks as components of its risk management, rather than focusing centrally on vendor oversight requirements. It names the NIST standard but contains no firm-specific details, dates, dollar amounts, or named entities that would elevate it beyond sector-adapted.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes (threat assessment, monitoring, simulations, training) but contains no named frameworks, specific dates, dollar amounts, named tools, or firm-specific organizational details that would distinguish it from standard industry disclosure language.


reasoning: The paragraph describes a specific past cybersecurity incident with an exact date (February 16, 2022), details of what occurred (network disruption, impacted systems), and response actions taken (engaging internal resources and third-party experts). While it includes materiality assessments, the primary content is the incident narrative. The specific date makes it Firm-Specific, but it lacks a second hard verifiable fact (such as named firms, dollar amounts, or headcounts) required for Quantified-Verifiable.


reasoning: The paragraph consists of generic risk factor boilerplate discussing potential cybersecurity impacts without describing the company's specific governance structures, management roles, or internal risk management processes. It references unnamed 'measures' without detailing any actual programs, frameworks, or procedures.


reasoning: Paragraph focuses on identifying the CISO and Chief Technology and Digital Officer, their reporting lines, qualifications (20 years experience), and oversight committee (Cybersecurity, Technology and Innovation Committee), which are management role elements. Contains specific organizational titles and a named committee, but only one hard verifiable fact (20 years), making it Firm-Specific rather than Quantified-Verifiable.


reasoning: This paragraph constitutes a standalone materiality assessment regarding cybersecurity risks, stating that threats could materially affect the company but that no material adverse effects have been experienced to date. It is generic boilerplate as it contains only standard SEC disclosure language ('business strategy, results of operations, and financial condition') with no company-specific details, named roles, dates, frameworks, or quantifiable metrics.


reasoning: The paragraph focuses extensively on the specific individual holding the cybersecurity leadership role (Director of IT), detailing their qualifications, credentials (Microsoft certification), education, tenure (28 years), and reporting line (CFO), satisfying the Person-vs-Function Test for Management Role. It meets the Quantified-Verifiable threshold with two hard, independently verifiable facts: the specific duration of experience (28 years) and the named professional certification (Microsoft Certified Information Systems Professional).


reasoning: Paragraph describes an internal process (annual policy review) performed by the Information Security team with Legal Department support, making it Risk Management Process. It names specific organizational units (Information Security team, Legal Department) and a specific policy document (Cybersecurity Policy), distinguishing it from generic boilerplate, but lacks hard verifiable facts like dates, headcounts, or named frameworks needed for Quantified-Verifiable or Sector-Adapted.


reasoning: The paragraph describes an actual security breach occurring on February 13, 2023, involving a third-party vendor's file transfer platform and the exposure of patient personal information, which constitutes an incident narrative. The inclusion of the specific disclosure date makes the paragraph Firm-Specific, though it lacks a second hard verifiable fact (such as the vendor's name, patient count, or dollar impact) needed for Quantified-Verifiable.


reasoning: Paragraph assigns cybersecurity responsibilities to management roles (General Counsel, Assistant General Counsel, CEO, IT leaders) as grammatical subjects, describing their oversight and risk mitigation duties. Despite mentioning specific legal titles, the roles referenced are either generic C-suite positions (explicitly excluded from specific facts) or vague descriptors ('IT leaders'), with no dates, numbers, named frameworks, or cybersecurity-specific titles (e.g., CISO) to elevate specificity.


reasoning: The paragraph focuses on Board and Audit Committee oversight of cybersecurity risk, describing the establishment and composition of a specific Cybersecurity Steering Committee with named independent directors (Laura Black, Douglas Gilstrap, Joanne Solomon) and management representatives (CIO, CISO, legal, finance, internal audit).


reasoning: The paragraph describes the company's internal cybersecurity processes (vulnerability management, training, third-party due diligence) without referencing the board, specific management roles, or an actual incident. It contains no named frameworks, specific dates, dollar amounts, headcounts, or named third-party firms—only generic references to 'reputable cybersecurity consultants' and 'third-party experts.' The content could apply to any company and contains no firm-specific details.


reasoning: The paragraph describes the company's internal capabilities (or lack thereof) regarding cybersecurity risk identification, detection, prevention, and remediation processes. It contains no named frameworks, specific roles, dates, dollar amounts, or other verifiable facts that would identify this disclosure as unique to Peak Bio, making it generic boilerplate applicable to any resource-constrained entity.


reasoning: The paragraph describes internal incident response coordination and procedural activities (developing and following procedures to respond to incidents), which falls under Risk Management Process. The language is entirely generic, containing no named entities, dates, specific roles, or frameworks that would identify this as unique to the company.


reasoning: Paragraph describes internal cybersecurity processes (insurance procurement, backup/disaster recovery testing, incident response procedures, training metrics) that are reviewed with the Board. While the CIO and General Counsel are the grammatical subjects, the Person-vs-Function test applies: removing the titles leaves a coherent description of program activities, indicating the focus is on risk management functions rather than management role qualifications or reporting lines. Contains 'Chief Information Officer' as a cybersecurity-specific title, satisfying the Firm-Specific threshold.


reasoning: The paragraph primarily presents a standalone materiality conclusion stating that cybersecurity threats have not materially affected and are not reasonably likely to materially affect the company, which falls under Strategy Integration per the tiebreaker rules. It contains no specific facts, dates, named roles, or frameworks—only generic references to 'management,' 'the Board,' and standard materiality language that could appear in any filing.


reasoning: The paragraph provides a standard materiality disclaimer stating that no cybersecurity incidents have materially affected business strategy or financial condition, and mentions cyber liability insurance coverage without specifying amounts or carriers. This aligns with Strategy Integration. It contains no specific dates, dollar amounts, named roles, frameworks, or other identifying details, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal incident response framework and its integration into the broader risk management system, which falls under Risk Management Process. It qualifies as Firm-Specific because it identifies a uniquely named internal program—the 'Cybersecurity Incident Response Plan (IRP)'—which serves as a verifiable organizational detail distinct from generic disclosures.


reasoning: The paragraph focuses on the identification, qualifications, and credentials of a specific cybersecurity leadership role (Vice President, Head of Technology), including specific tenure (20+ years) and professional certification (CISM), making it about the person rather than abstract processes.


reasoning: The paragraph contains a standalone materiality assessment stating that no material cybersecurity incident has been experienced but that risks may materially affect business strategy and financial condition, which falls under Strategy Integration. Despite the cross-reference to Risk Factors, the materiality conclusion determines the category. The language is standard boilerplate that could apply to any entity, containing no specific dates, roles, frameworks, or quantifiable details unique to this ETF.


reasoning: The paragraph describes the company's internal cybersecurity processes, including framework adoption (CIS controls), audit cadence, vulnerability testing, and governance assignments. It names the specific CIS framework and provides an exact duration for audits ('every three years'), which qualifies as a specific numerical fact, making the disclosure Firm-Specific rather than generic Sector-Adapted boilerplate.


reasoning: Paragraph describes the company's internal cybersecurity risk management processes, including the Compliance Committee's responsibilities for risk assessment, monitoring metrics, and escalation protocols. While the Board is mentioned regarding oversight, the grammatical subject is the management-level Compliance Committee (comprised of executives, not directors), and the focus is on operational risk management functions rather than board governance or individual management roles. Contains firm-specific details including the cybersecurity-specific title of CIO and the specific composition of the committee.


reasoning: The paragraph describes the company's internal incident response governance structure and the specific functional composition of its information security advisory board, focusing on processes and responsibilities rather than individual qualifications or Board-level oversight. It contains firm-specific details including the 'VP of IT' title and the unique cross-functional makeup of the advisory board.


reasoning: The paragraph describes the company's internal processes for cybersecurity risk management, including supervision, briefings, and reporting cadences. It does not identify specific CISO/CIO/CTO individuals or their qualifications (which would trigger Management Role), nor does it name specific frameworks, dates, tools, or third-party firms that would elevate it beyond generic language.