reasoning: The paragraph's grammatical subject is 'Management,' describing their responsibilities for implementing cybersecurity controls and reporting cadence to the Board. It qualifies as Management Role rather than Board Governance because the focus is on management's duties and reporting lines rather than board oversight activities. The disclosure contains only generic terms ('Management,' 'the Board,' 'at least annually') without naming specific cybersecurity titles, committees, dates, or organizational structures, making it indistinguishable from standard boilerplate language applicable to any company.


content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes board-level oversight of cybersecurity risk, with the Board and a specific board committee serving as the grammatical subjects. The naming of the 'Risk and Information Security Committee' constitutes a firm-specific governance detail, distinguishing it from generic 'Audit Committee' disclosures.

provider: moonshotai

stage: benchmark


content_category: Strategy Integration

reasoning: The paragraph provides a negative materiality assurance stating no material cybersecurity incidents have occurred, functioning as a standalone materiality conclusion without describing specific governance structures, management roles, or risk processes. The language is entirely generic and could apply to any company without modification.


content_category: Risk Management Process

reasoning: The paragraph describes the company's internal risk management framework and processes (identification, analysis, response to risks), not the qualifications or background of a specific individual. While it mentions the Executive Director of Information Technology as chairing a committee, this is incidental to describing the risk administration structure and framework adoption.


reasoning: The paragraph describes management's oversight activities and reporting lines regarding cybersecurity risk as part of the company's ERM approach, which falls under risk management process rather than specific role identification or board governance. It contains no named entities, specific dates, frameworks, or unique organizational details—only generic references to 'Management,' 'board of directors,' and 'cybersecurity risk mitigation' that could apply to any company.


content_category: None/Other

reasoning: The paragraph describes erroneous vendor payments and a material weakness in internal controls over financial reporting related to cash disbursements, which is accounting/financial content rather than cybersecurity disclosure. As non-cybersecurity content, it falls under None/Other.


reasoning: The paragraph describes the Bank's internal cybersecurity risk management framework, including defense-in-depth strategies, ERM integration, vulnerability management, penetration testing, and incident response planning. It contains no named standards (e.g., NIST, ISO), specific dates, dollar amounts, headcounts, percentages, named third-party firms, or cybersecurity-specific roles (e.g., CISO). Program names such as 'Cybersecurity Incident Response Plan,' 'Information Security program,' and 'business continuity management program' are generic and could apply to any company.


content_category: Incident Disclosure

reasoning: The paragraph describes the operational status and restoration timeline of an actual cybersecurity incident, referencing specific affected services (DISH TV and SLING TV) and providing the exact date (March 31, 2023) when significant systems were restored.


reasoning: Paragraph describes the company's internal risk assessment processes, safeguard implementation, and monitoring activities. While it references an 'IT consultant' as having primary responsibility, this constitutes an unnamed external role (falling under 'external consultants' on the NOT list) rather than a named cybersecurity-specific title (e.g., CISO) or identified individual with qualifications. The disclosure contains no named frameworks, specific dates, dollar amounts, or other verifiable facts unique to the firm.


reasoning: The paragraph describes the company's internal cybersecurity processes, specifically vulnerability scanning/testing and utilizing external service providers to assist with system assessments. This constitutes a description of the company's own risk management activities rather than third-party oversight or incident disclosure. The content contains no named frameworks, specific dates, product names, or quantifiable details—only generic descriptions of security practices (vulnerability scans, threat intelligence feeds, external providers) that could apply to any company.


content_category: Management Role

reasoning: The paragraph describes the qualifications, career history, and educational backgrounds of specific management roles (CISO, CDIO, CEO, CFO, GC), focusing on the individuals rather than processes. It meets the Quantified-Verifiable threshold by containing multiple hard facts: specific durations (18 years, 25 years, 20 years) and specific counts (two master's degrees, two large public companies), which are verifiable biographical details.


reasoning: The paragraph describes the Board's oversight of cybersecurity risk, with the Board as the grammatical subject. The language is entirely generic, containing no named committees (e.g., Technology or Cybersecurity Committee), specific roles, dates, or organizational details unique to the company.


reasoning: The paragraph identifies specific cybersecurity leadership roles (CIO and Vice President, Information Security) and provides quantifiable biographical details about the VP's experience (25 years), making it about management personnel rather than processes. The presence of two hard verifiable facts—specific cybersecurity titles and a specific duration of experience—meets the Quantified-Verifiable threshold.


reasoning: The paragraph describes an actual cybersecurity incident involving a fraudulent email that caused a $0.7 million erroneous wire transfer during the year ended December 31, 2023, including the incident scope and response actions (engaging an outside consultant and strengthening procedures). It contains two hard verifiable facts: a specific date and a specific dollar amount.


reasoning: The paragraph describes the company's internal risk management processes, framework adoption, and specific program implementation details. It is Firm-Specific because it names the specific internal program (Cybersecurity Risk and Compliance Program), identifies the exact version of the framework implemented (CIS Controls v8.0), and specifies the architectural approach (Zero Trust), exceeding mere generic framework naming.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and data processing activities in general terms. It references 'recognized industry standards and frameworks' without naming specific ones (e.g., NIST, ISO 27001), and contains no company-specific details such as named roles, dates, team compositions, or tools that would distinguish it from any other company's disclosure.


reasoning: The paragraph contains forward-looking risk disclaimers describing hypothetical consequences of potential cyber incidents (data misappropriation, operational disruption, vendor breaches) without disclosing the company's actual cybersecurity governance structure, management roles, or specific risk management processes. It lacks any substantive disclosure about the company's specific cybersecurity program.


reasoning: The paragraph describes the company's internal process of using third-party service providers to assist with identifying, assessing, and managing cybersecurity risks. While it mentions vendors, it does so as a component of the company's risk management process rather than focusing on vendor oversight or security requirements imposed on suppliers (which would be Third-Party Risk). The disclosure lists only generic categories of providers (e.g., 'professional service firms,' 'cybersecurity consultants') without naming specific firms, tools, dates, or quantified details, making it generic boilerplate applicable to any company.


reasoning: The paragraph provides a generic, definitional description of Denial of Service attacks without referencing the company's specific cybersecurity governance, management roles, internal processes, or any substantive disclosure about its cyber risk management program. It constitutes background material rather than substantive disclosure.


reasoning: The paragraph describes the company's internal risk assessment processes and security safeguards (multi-factor authentication, vulnerability scanning, patch management, etc.), which falls under Risk Management Process. However, it contains only generic descriptions of standard security practices without naming specific frameworks, tools, dates, headcounts, or other verifiable facts unique to this company.


reasoning: The paragraph describes Deutsche Bank Group's internal cybersecurity controls, detection methods, and incident response processes, which constitute risk management activities. It contains no specific dates, dollar amounts, named frameworks (e.g., NIST, ISO), named third-party firms, or other hard verifiable facts—only generic descriptions of security controls and information sharing practices that could apply to any financial institution.


reasoning: The paragraph describes the company's internal security safeguards and processes (firewalls, intrusion detection/prevention, anti-malware) and mentions using unnamed external service providers as a component of these procedures, which falls under Risk Management Process rather than Third-Party Risk. It lacks named frameworks, specific dates, dollar amounts, headcounts, named vendors, or specific product names, consisting entirely of generic security controls applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and the organizational structure (cross-functional committee and multidisciplinary teams) that executes them, rather than focusing on board oversight or individual management qualifications. It contains firm-specific details including a named non-generic committee ('cybersecurity committee'), a cybersecurity-specific leadership title ('Vice President, IT'), and a specific departmental composition ('IT, legal, finance and internal audit departments'), but lacks quantifiable data points like dates, dollar amounts, or headcounts needed for Quantified-Verifiable.


reasoning: The paragraph describes an actual cybersecurity incident involving a fraudulent email that resulted in an erroneous wire transfer, including specific details about the timing (year ended December 31, 2023), the quantified financial impact ($0.7 million loss), and the company's subsequent response actions to strengthen wire transfer approval procedures.


reasoning: The paragraph describes a specific cybersecurity incident including the exact discovery date (October 15, 2025), the nature of the unauthorized access and encryption deployment, and specific response actions including notification to the FBI. This constitutes a concrete incident narrative rather than a general risk discussion or materiality assessment.


reasoning: The paragraph describes the company's internal cybersecurity processes (continuous monitoring, threat analysis, policy implementation, training, assessments) and passes the person-vs-function test—removing the CTO's name and credentials still leaves a coherent description of the risk management function. The identification of a CTO with specific tenure provides firm-specific detail.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, technical controls, and framework adoption. It names specific recognized standards (PCI DSS and CIS Controls) but contains no firm-specific details such as dates, named roles, headcounts, or specific tools.


reasoning: The paragraph focuses on Board and Audit Committee oversight of cybersecurity risk, describing the Board's overall responsibility, the Audit Committee's monitoring role, and the cadence of updates between management and the Committee. While management roles (VP of Strategic Initiatives and CFO) are mentioned, they appear as objects of the Committee's oversight activities rather than the primary subject; the Board and Audit Committee are the grammatical subjects of the majority of sentences.


reasoning: The paragraph describes the scope of a cybersecurity incident (distinguishing between customer databases not accessed versus employee records that were extracted) and details response actions including data deletion confirmation and individual notifications, fitting Incident Disclosure. It contains no specific dates, dollar amounts, named third-party firms, or quantified metrics—only vague descriptors like 'certain,' 'limited number,' and unnamed 'third parties'—making it Generic Boilerplate per the calibration examples.


reasoning: The paragraph identifies specific management positions (Executive Vice President of Technology, Director of Information Technology) comprising a named Cybersecurity Committee, their meeting cadence, and reporting line to the CFO. While past incidents and materiality are mentioned, the detailed description of management structure and specific titles constitutes the primary substance.


reasoning: The paragraph describes internal cybersecurity processes including patch management, software version maintenance, employee training, and third-party security reviews. It contains no named frameworks, specific dates, quantifiable metrics, named tools, or identifying details beyond generic security practices applicable to any company.


reasoning: The paragraph describes the board of trustees' oversight responsibility for cybersecurity risks and identifies specific board members (Nathaniel A. Davis and Patricia L. Gibson) with relevant expertise, making board governance the clear focus.


reasoning: The paragraph describes the company's internal security awareness training program for personnel and customer education initiatives, which falls under risk management processes. However, it contains only generic descriptions ('mandatory initial and annual training', 'security awareness', 'electronic convenience products') without specific dates, headcounts, named frameworks, cybersecurity-specific titles, or identifiable tools that would distinguish this disclosure from any other company's training program.


reasoning: The paragraph describes the company's internal access control processes (least privilege methodology, user provisioning/de-provisioning, routine access reviews, and single sign-on controls) without referencing specific frameworks, named tools, dates, headcounts, or organizational structures unique to this company. The language consists of standard cybersecurity practices applicable to any organization.


content_category: Third-Party Risk

reasoning: The paragraph centrally addresses vendor oversight, describing the company's vendor management program, security questionnaires, audits, and contractual obligations imposed on providers. It contains no specific dates, dollar amounts, named vendors, frameworks, or unique program identifiers, and describes generic processes applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity program structure, incident classification system (Levels 1-5), and response protocols. While it mentions the Directors Risk Committee and Corporate Security Group, the focus is on the processes and functions rather than board oversight or individual management qualifications.


reasoning: Paragraph describes the company's internal incident response planning, testing, and backup procedures. It contains no specific dates, named frameworks, tools, team compositions, or unique program identifiers; the language ('incident response plan', 'regular testing', 'essential data') is entirely generic and could apply to any company.


reasoning: Although the CISO is the grammatical subject, the paragraph describes the functional activities and processes used to monitor cybersecurity risks (briefings, threat intelligence, security tools, alerts) rather than the CISO's personal qualifications or reporting structure. Per the Person-vs-Function test, this describes what the role does, making it Risk Management Process. The paragraph identifies the specific cybersecurity title 'CISO' and the named committee 'ERMC' (Enterprise Risk Management Committee), making it Firm-Specific.


reasoning: The paragraph identifies specific cybersecurity management roles (Director of Information Security, Chief Information Officer), their reporting lines, and committee memberships (Risk Committee, Operational Risk and IT Steering Committees). While the Board is mentioned, the grammatical focus and detail are on the management structure and responsibilities, not board oversight processes.


specificity_confidence: medium

reasoning: The paragraph constitutes a materiality assessment regarding the impact of cybersecurity threats on the company's business and financial condition for the reporting year, which falls under Strategy Integration. While the materiality language is boilerplate, the specific temporal reference to '2024' qualifies as a specific date fact, making the disclosure Firm-Specific rather than Generic Boilerplate.


reasoning: The paragraph describes the company's internal risk management framework, including the three lines of defense model, technology control testing, and third-party due diligence processes. While it identifies the VP of Information Security Systems, the focus is on the function and activities performed rather than the individual's personal qualifications or background, making it about the process rather than the management role.


reasoning: The paragraph describes internal cybersecurity processes (monitoring, defense-in-depth safeguards, vulnerability assessments, and incident response planning) rather than the CISO's personal qualifications or background. While the CISO is mentioned as implementing these activities, the focus is on the function, not the person. Specificity is Firm-Specific due to the cybersecurity-specific title 'CISO' and the specific departmental composition 'accounting team' as part of the incident response structure.


reasoning: The paragraph describes the company's internal cybersecurity framework and policy objectives, fitting Risk Management Process. It references a specifically named internal document, the 'Enterprise Information Systems Security Policy,' which distinguishes it from generic boilerplate.


reasoning: The paragraph describes the company's internal risk assessment ('risk... is minimal') and security controls ('standard commercial software,' 'password protection and data encryption'), which falls under Risk Management Process. While the CEO is mentioned as responsible for oversight, this is a generic C-suite role without specific qualifications or reporting lines described. The disclosure contains no named frameworks, specific dates, dollar amounts, or unique organizational details that would elevate it beyond generic boilerplate language applicable to any small company.


reasoning: The paragraph focuses entirely on vendor oversight, including onboarding assessments, contractual security requirements, and incident investigation for third-party providers, making Third-Party Risk the appropriate category. The disclosure contains no named entities, specific dates, frameworks, or quantifiable details, consisting entirely of generic descriptions of standard third-party risk management practices.


reasoning: The paragraph provides a detailed narrative of an actual cybersecurity incident including specific dates (June 2023 and September 2023), scope (unauthorized access to email accounts of two employees), response actions (customer notification), and quantified financial impact ($25,000), meeting the threshold for Incident Disclosure with multiple verifiable hard facts.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment and management processes, including integration into overall risk management strategy and review of security reports. While it identifies the COO and SVP for Operations as responsible parties, these are generic C-suite roles (explicitly excluded from specific facts per instructions) and the focus is on the processes themselves rather than personal qualifications or reporting lines. No named frameworks, dates, numbers, or firm-specific details are present.


reasoning: The paragraph describes the company's internal risk management program, policies, and the specific composition of the Security Steering Group (including CISO, Chief Product Officer, and VP of Cloud Technology), focusing on processes and organizational structure rather than board oversight or individual management qualifications.


reasoning: The paragraph focuses on the Audit Committee's oversight of cybersecurity risks and management's quarterly reporting thereto, making the board committee the grammatical subject. However, it contains only generic elements—standard 'Audit Committee' references, vague 'quarterly' cadences, and unspecific 'management' roles without naming any cybersecurity-specific titles, frameworks, or verifiable facts unique to the company.


reasoning: The paragraph describes a specific cybersecurity incident including unauthorized access, data exfiltration (images of video meetings and screens), public release of information, ransom demands, and response actions taken. However, it contains no specific dates, dollar amounts, named third-party firms, named tools, or quantified metrics—using only vague descriptors like 'certain systems,' 'a portion,' and 'some vendors and customers.'


reasoning: The paragraph focuses on identifying specific personnel (VP of IT) and their qualifications (25 years experience, DoD Research background), reporting lines, and the CFO's supervisory role (23 years experience), satisfying the PERSON-VS-FUNCTION test for Management Role. It meets the Quantified-Verifiable threshold with two specific numerical claims (25 and 23 years of experience).


reasoning: Paragraph focuses on management reporting lines and role identification, describing the IT Team Director's meetings with the CFO and CEO regarding cybersecurity risks and the specific reporting structure to the CFO, CEO, and General Counsel in the event of an incident. This aligns with the Management Role category definition covering reporting lines, rather than describing board oversight or risk management processes.


reasoning: The paragraph identifies a specific management position ('Director of IT') as the grammatical subject responsible for cybersecurity risk management and describes their experience/qualifications, satisfying the Management Role category. While the description of activities is generic, the specific job title and entity name ('Oblong') distinguish this from boilerplate text, making it Firm-Specific.


reasoning: The paragraph begins and ends with board oversight (the board has 'overall oversight responsibility' and incidents are reported to the audit committee and board), establishing governance as the primary topic. While it identifies the Vice President of Operations as the individual directing cybersecurity programs, this serves to describe the management structure under the board's supervision rather than focusing on management qualifications or processes as the main subject.


reasoning: The paragraph describes internal processes for managing cybersecurity risks (security controls and mitigation measures) but contains no named frameworks, specific roles, dates, dollar amounts, or tools that would identify it as unique to this company.


reasoning: The paragraph provides a materiality assessment stating that no material cybersecurity incident occurred during the specified reporting period, which falls under Strategy Integration per the guidance that standalone materiality conclusions belong to this category. The inclusion of the specific fiscal year-end date 'December 31, 2024' qualifies as one specific fact, making the disclosure Firm-Specific rather than Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management activities, including assessments, penetration testing, and incident response planning. It references a specifically named internal program ('Cyber Incident Response Plan'), which qualifies as a firm-specific fact, but lacks quantifiable details such as specific dates, dollar amounts, or named third-party firms that would be required for Quantified-Verifiable classification.


reasoning: The paragraph centers on vendor oversight and contractual security requirements imposed on third-party vendors, fitting the Third-Party Risk category. It contains no named entities, specific dates, recognized frameworks, or quantifiable details that would distinguish it from any other company's disclosure.


reasoning: The paragraph describes the company's internal processes for assessing and managing cyber risks, including adoption of the NIST framework and a specifically named internal program (CIRP), which qualifies as a firm-specific identifier. It does not reference specific management roles, board oversight, or actual incidents.


reasoning: The paragraph describes the company's enterprise risk management integration and internal processes for managing cybersecurity risk (identification, mitigation strategies, controls, and reporting cadence). While it mentions the Audit Committee and a Co-President, the focus is on the functional risk management activities and ERM program structure rather than board-specific oversight mechanics or cybersecurity-specific management qualifications. No specific frameworks, dates, dollar amounts, or named cyber-specific roles (e.g., CISO) are provided—only generic governance titles (Co-President, Audit Committee) and standard practices that could apply to any company.


reasoning: The paragraph describes the company's internal security awareness training, testing programs, and insurance procurement as ongoing risk management activities. However, it contains only generic cadences ('annual', 'periodic', 'regular') without specific dates, dollar amounts, named vendors, or other verifiable details that would identify this disclosure as unique to Zurn Elkay.


reasoning: The paragraph identifies specific cybersecurity management roles (IT Director, Cyber Security) and describes the composition and reporting structure of the Cyber Incident Management Team (CIMT), fitting the Management Role category. It contains firm-specific details including the CIMT acronym, the specific departmental composition of the team, and the cybersecurity-specific director title.


reasoning: Paragraph contains a standalone materiality conclusion stating that no cybersecurity incidents have materially affected the company in the last three years, without describing any specific incident details, scope, or response actions. This is standard boilerplate materiality language that could apply to any company.


reasoning: The paragraph describes the company's internal incident response planning and testing procedures, which is a core risk management process. It contains no specific dates, named frameworks, team compositions, or other unique identifiers—only generic references to 'incident response and recovery plans' and 'regular' testing that could apply to any company.


reasoning: The paragraph describes the company's internal technical security controls and architecture (.pem file authentication, SSL encryption, AWS Shield deployment) as part of its cybersecurity risk management processes. It contains specific technical details about the company's unique implementation rather than generic statements, but lacks two hard verifiable facts (dates, dollar amounts, headcounts, or multiple named third-party firms) required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal processes for cybersecurity risk assessment, mitigation, continuous monitoring, and reporting to senior management. It qualifies as Firm-Specific due to the inclusion of one quantified fact—the third-party partner's duration of experience (over 21 years)—which is not generic boilerplate.


reasoning: Paragraph primarily describes the company's internal risk management processes, ERM integration, and adoption of FFIEC frameworks. While the CISO and board oversight are mentioned, the focus is on the function and processes (identifying, preventing, mitigating threats) rather than the CISO's personal qualifications or board governance specifics. The disclosure includes cybersecurity-specific roles (CISO) with specific reporting lines (to CRO) and named regulatory frameworks (FFIEC), making it Firm-Specific rather than generic boilerplate.


reasoning: The paragraph identifies specific cybersecurity leadership roles (CIO and Director of IT), their reporting lines, and qualifications/experience, which aligns with the Management Role category. It contains firm-specific details including the dual role of the CIO with subsidiary Kronos, the specific reporting structure for CompX's IT director, and reference to the ISA (Intercompany Services Agreement).


reasoning: The paragraph exclusively addresses vendor oversight, due diligence, and contractual security requirements for third-party service providers, making Third-Party Risk the central topic. It contains no named standards, specific dates, dollar amounts, named firms, or other verifiable details—only generic descriptions of risk management activities that could apply to any company.


reasoning: The paragraph focuses on identifying specific cybersecurity management roles (CIO and Senior Director of Information Security), their reporting lines, and detailed professional qualifications including specific years of experience (25 and 20) and named certifications (CISM, Zero Trust Certified Architect), satisfying the person-vs-function test for Management Role. Board and Audit Committee mentions are incidental to the escalation process description.


reasoning: The paragraph describes the company's internal cybersecurity risk management framework (EISF) and its alignment with various recognized standards and regulations, which constitutes a description of internal processes. It is Firm-Specific because it names the company's specific internal program (EISF) with a unique identifier, distinguishing it from generic sector-adapted language that only references external frameworks.


reasoning: The paragraph describes internal employee-level cybersecurity processes (training programs, phishing tests, awareness campaigns) rather than the CISO's personal qualifications or reporting structure. While the CISO is mentioned, the focus is on the IT team's functional activities supporting the program. The mention of 'CISO' provides one firm-specific detail, but no quantifiable metrics, dates, or vendor names are present to reach Quantified-Verifiable.


reasoning: The paragraph describes the company's internal risk management framework, risk assessments, and coordination between the Enterprise Risk function, Internal Audit, and Compliance. While it mentions the CRO and CISO, the focus is on the processes and activities of the program, not the individuals' qualifications. Specificity is Firm-Specific due to the naming of the cybersecurity-specific CISO role and the specific departmental composition involving Internal Audit and Firm-wide Compliance.


reasoning: The paragraph identifies specific cybersecurity management roles (VP/CIO, Director of Information Security), their detailed qualifications (27 years experience, Doctorate, degree), reporting lines, and committee structures, fitting the Management Role category. It contains multiple hard verifiable facts including specific years of experience (27 years) and named academic credentials (Doctor of Business Administration, degree in Information Technology Management), meeting the Quantified-Verifiable threshold.


reasoning: While the CFO is identified as the responsible party, the paragraph describes internal risk management activities (day-to-day oversight, platform utilization, board reporting) rather than the CFO's personal qualifications or background. The mention of the 'Coalition management platform' identifies a specific third-party tool used in the process.


category_confidence: medium

reasoning: The Board of Directors is the grammatical subject of the main clause, which describes the Board's active oversight role in discussing cyber risks and inquiring of management regarding controls. While the paragraph includes a materiality assessment (that cybersecurity is not considered a material risk), the primary disclosure describes the Board's governance activities. The specific mention that the Company does not employ a CIO constitutes a firm-specific organizational fact.


reasoning: The paragraph describes the company's internal process for identifying and managing cybersecurity risks through the engagement of external service providers, making it a risk management function rather than third-party vendor oversight. It lists only generic categories of service providers (e.g., 'threat intelligence service providers,' 'penetration testing firms') without naming specific firms, tools, dates, or quantities, qualifying as generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal technical architecture and data storage security controls as part of its cybersecurity program. It meets the Quantified-Verifiable threshold by naming two distinct hard facts: the specific product AWS RDS and the third-party firm AWS (Amazon Web Services).


reasoning: The paragraph focuses entirely on the qualifications, educational backgrounds, certifications, and career histories of specific individuals (the CISO and CIO), satisfying the Management Role definition. It contains multiple independently verifiable hard facts including a specific timeframe (early 2023), named previous employer (Comerica Bank), named universities (University of Illinois, Oakland University), and specific professional certifications (CISSP, CRISC, CCISO), exceeding the threshold for Quantified-Verifiable.


reasoning: The paragraph identifies the Chief Information Officer (CIO) and describes the Information Security Governance Committee, explicitly noted as comprising senior management members, which governs the information security program and oversees Board communications. This focuses on management roles, reporting lines, and committee composition rather than Board oversight (the committee reports to the Board but is not a Board committee) or specific risk assessment processes.


reasoning: The paragraph identifies the Chief Information Security Officer by title, details their specific qualifications (36 years of experience, over 24 years as the Company's CISO), and describes the composition of the cybersecurity risk steering group (chaired by the Chief Insurance Officer and including technology, security, privacy, and legal teams). This focuses on management roles, reporting structures, and personnel qualifications rather than internal processes or board oversight. While it contains specific durations (36 years, over 24 years), these are biographical details and exact durations that contribute to Firm-Specificity rather than the Quantified-Verifiable threshold, which requires two hard facts such as dates, dollar amounts, headcounts, percentages, or named third-party firms/products.


reasoning: The paragraph contains only generic forward-looking risk language and a vague acknowledgment of past attacks without any narrative detail (dates, scope, systems affected, or response actions). It provides no substantive disclosure about governance structures, management roles, risk processes, or specific incidents.


reasoning: The paragraph describes the company's internal cybersecurity measures and their review/update processes, which falls under Risk Management Process. It contains no specific details, dates, named roles, frameworks, or quantifiable information—only generic language about prevention, detection, and regular reviews that could apply to any company.


reasoning: The paragraph enumerates the components of the company's cybersecurity program (incident response, risk assessments, training, vendor management) focusing on internal processes and organizational structure rather than individual qualifications. It qualifies as Firm-Specific due to the identification of the CISO role and the specific listing of participating departments (Global Technology & Operations, Risk, Compliance, Legal, Privacy and Internal Audit).


reasoning: The paragraph identifies specific cybersecurity leadership roles (CTO, DPI Head, and SSA) and details their qualifications, prior employment history at Bear Stearns, tenure dates (joining in 1997, seven years at previous employer), and reporting lines to the Audit Committee. It satisfies Quantified-Verifiable specificity by containing multiple independently verifiable hard facts including specific years, durations, and a named third-party firm.


reasoning: The paragraph identifies the Chief Technology Officer as the grammatical subject, describing their reporting line to the CEO, their 25 years of experience, and their leadership of the cybersecurity function. This focuses on management role identification and qualifications rather than internal processes alone. The specificity is Firm-Specific due to the cybersecurity-specific title (CTO) and the specific duration of experience cited, though it lacks a second hard verifiable fact (such as specific dates, dollar amounts, or named third-party firms) needed for Quantified-Verifiable.


reasoning: The paragraph contains a materiality assessment stating that no cybersecurity incidents have had material adverse impacts to date, and directs readers to Risk Factors for additional information on materiality effects, which falls under Strategy Integration per the tiebreaker rules for materiality disclaimers. The content is entirely generic boilerplate with no named frameworks, specific roles, dates, dollar amounts, or other identifying details.


reasoning: The paragraph describes a specific historical cybersecurity incident with precise details including the date (June 2018), financial impact ($10 million), and affected system (email system), meeting the criteria for Incident Disclosure. The presence of both a specific date and exact dollar amount provides two independently verifiable hard facts, satisfying the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's cybersecurity risk management policies and procedures (detection, analysis, response, controls, assessments), which focuses on internal processes even though they are administered by an affiliate. It identifies the specific third-party provider CIM Group and names the NIST Cybersecurity Framework as the standard leveraged.


reasoning: The paragraph focuses on identifying the vCISO (a cybersecurity-specific management role), their qualifications (CISSP certification, decade of experience), and reporting structure (reports directly to the board), which aligns with Management Role. It also references the ISSC committee composition. While it mentions oversight activities, the emphasis on the individual's credentials and background triggers the Person-vs-Function test for Management Role. Specificity is Firm-Specific due to named cybersecurity titles and committee, but lacks two hard verifiable facts (dates, dollar amounts, exact headcounts, or named third-party firms/tools) required for Quantified-Verifiable.


reasoning: Paragraph describes the establishment of an internal cross-functional team and its operational role in implementing the cybersecurity program, applying the person-vs-function test (focus is on the team's collective experience and day-to-day duties, not individual management credentials). Contains cybersecurity-specific title 'Director of Cybersecurity' and specific numeric claim 'over 85 years' of experience, but only one hard verifiable fact counts toward Quantified-Verifiable threshold (named roles are excluded).


reasoning: Paragraph focuses on the qualifications and support structure of the IT Lead (11 years experience) rather than detailing the risk processes themselves, satisfying the Person-vs-Function test for Management Role. Contains two specific numerical values (11 years, 8 years) that independently verify experience levels, meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal cybersecurity functions (risk assessment, security controls, incident response) managed by a generic 'information technology department.' It contains no named frameworks, specific roles (e.g., CISO), dates, numbers, or other unique identifiers that would distinguish it from any other company's disclosure.


reasoning: The paragraph contains a materiality disclaimer stating the company has not experienced material cyber-attacks and cross-references Item 1A for risk factor disclosures regarding material effects on business strategy and financial condition, fitting Strategy Integration. It lacks specific dates, dollar amounts, named frameworks, or identifiable roles, rendering it Generic Boilerplate.


reasoning: The paragraph provides a standalone materiality assessment regarding the impact of cybersecurity risks and prior incidents on business strategy and financial condition, which falls under Strategy Integration. It contains standard boilerplate language without naming specific incidents, dates, frameworks, or roles, making it Generic Boilerplate.


reasoning: The paragraph focuses on generic C-suite and management roles (CEO, CFO, corporate controller) and their responsibilities for assessing cybersecurity risk and briefing the audit committee. It contains only standard titles and vague cadences ('once per year') with no cybersecurity-specific roles, named frameworks, specific dates, or other firm-identifying details.


reasoning: Paragraph describes management's supervision of internal cybersecurity processes (briefings, threat intelligence, security tools) rather than identifying specific management personnel or their qualifications. Contains no named frameworks, specific dates, dollar amounts, or other verifiable facts unique to the company.


reasoning: The paragraph focuses on the qualifications and professional certifications of specific personnel (the VP of Risk Management and MSSP staff), satisfying the Person-vs-Function test for Management Role. It lists multiple specific, named certifications (CISA, CISSP, CRMA, etc.), which constitute independently verifiable hard facts, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the board of directors' oversight of cybersecurity risks and mentions formalizing governance structures, which falls under Board Governance. It contains no named committees, specific frameworks, dates, or organizational details that would identify this specific company, making it generic boilerplate language applicable to any registrant.


reasoning: The paragraph describes the company's internal risk assessment and management processes, including integration with ERM and listing categories of cyber risks faced. It contains no named frameworks, specific roles, dates, or quantifiable details that would identify it as unique to Sabre Corp—it could apply to any company.


reasoning: The paragraph identifies the CISO by title, details reporting lines to senior management, and extensively describes the incumbent's specific qualifications (Master's degree, certifications from ISC2 and IAPP, and 30+ years experience), fitting the Management Role category focused on personnel credentials. It meets the Quantified-Verifiable threshold by providing a specific duration (thirty years) and naming two distinct third-party certification bodies.


reasoning: The paragraph describes the Board of Directors' expected oversight responsibilities and anticipated briefing cadence from management, with the Board as the grammatical subject. However, the repeated use of 'We expect' and future-tense verbs ('will become,' 'will be responsible') indicates these are forward-looking intentions rather than descriptions of current implemented governance. The disclosure contains no specific committee names, dates, or organizational details beyond generic references to the Board of Directors and senior management.


reasoning: The paragraph identifies specific management roles (CTO and VPCS), their cybersecurity responsibilities, and reporting lines (VPCS reports to CTO), fitting the Management Role category. It contains cybersecurity-specific titles and organizational structure details that are firm-specific, but lacks hard verifiable facts (dates, dollar amounts, headcounts, named third-party firms/tools) required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal risk management processes, including ERM program integration, framework adoption, and the structure of its cybersecurity program. While it identifies specific management roles (CTO/CIO and CISO), the focus is on the organizational processes and risk management functions rather than biographical details or board governance.


reasoning: Paragraph identifies specific management roles (Executive Director of IT and CFO) as the grammatical subject and describes their cybersecurity responsibilities. While CFO is a generic C-suite title, 'Executive Director of IT' is a specific organizational role that identifies the company's unique management structure for cybersecurity oversight.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and mentions oversight responsibility. However, the Board of Directors and senior management are not the grammatical subjects (the subject is 'primary cybersecurity oversight responsibility'), and no specific frameworks, roles (e.g., CISO), dates, or quantifiable details are provided, making the content generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity processes, controls, and mitigation measures (incident response plans, vulnerability management, risk assessments, encryption, etc.), which constitutes Risk Management Process. It contains one firm-specific fact—the mention of a 'dedicated CISO' (a cybersecurity-specific title)—but lacks named frameworks, specific dates, dollar amounts, or third-party firms, making it Firm-Specific rather than Quantified-Verifiable or Sector-Adapted.


reasoning: The paragraph describes internal threat monitoring and risk anticipation activities, which constitutes a Risk Management Process. The language is entirely generic—containing no named tools, specific dates, team compositions, or unique program identifiers—and could apply to any company without modification.


reasoning: The paragraph identifies specific cybersecurity leadership roles (CIO and CISO) and provides detailed qualifications, tenure (since 2023), and educational background for the CIO, focusing on management personnel rather than processes. While board oversight is mentioned, the detailed biographical information and Working Council composition indicate the primary focus is on management roles.


reasoning: Paragraph describes the company's internal risk management processes (risk assessment, ERM integration, incident preparation, security assessment reviews) and assigns execution responsibilities to management. While management roles are grammatical subjects, the content focuses on process activities rather than personnel qualifications or reporting lines. Contains only generic references (CEO, CFO, Board of Directors, 'information technology team') with no specific cybersecurity titles, frameworks, dates, or quantifiable details.


reasoning: The paragraph describes internal cybersecurity processes (training programs, security operations, vulnerability management, threat monitoring) without referencing specific frameworks, named tools/products, dates, headcounts, or departmental compositions. The practices listed (phishing simulations, 24/7 monitoring, IDS/IPS) are standard industry activities that could apply to any company.


reasoning: The paragraph describes the company's internal incident response and escalation procedures, including the specific composition of the cross-functional steering committee (IT, Finance, and Legal) and protocols for escalating material incidents to the Audit Committee and Board. This represents IR planning and risk assessment processes rather than a description of an actual incident or board governance structure.


reasoning: This paragraph contains a standalone forward-looking materiality assessment regarding potential cybersecurity risks without describing any actual incident, governance structure, or risk management processes. The language is generic boilerplate that could appear in any company's filing, containing no named entities, dates, frameworks, or specific details unique to Caesars Entertainment.


reasoning: The paragraph is centrally focused on vendor oversight, describing contractual requirements and due diligence processes imposed on third-party service providers. It contains no named vendors, specific dates, dollar amounts, frameworks, or quantifiable details that would identify it as unique to Omeros Corp.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including the adoption of the NIST framework and control testing procedures, without referencing specific board oversight, management roles, or actual incidents.


reasoning: Paragraph describes the company's internal risk assessment and mitigation processes (continuous identification, assessment, prioritization) but focuses on the function rather than specific people or qualifications. Contains no named frameworks, specific dates, dollar amounts, headcounts, or named tools/roles beyond the generic 'cybersecurity team' descriptor.


reasoning: The paragraph describes a specific cybersecurity incident including exact dates (February 23 and 28, 2023), scope of impact (internal servers, IT telephony, extracted data), and detailed response actions (activating incident response plans, engaging experts, notifying law enforcement), fitting the Incident Disclosure category. The presence of two specific dates satisfies the threshold for Quantified-Verifiable.


reasoning: Paragraph describes the company's internal process for monitoring cybersecurity risks associated with third-party service providers. While focused on vendor risks, it describes the monitoring activity (a risk management process) rather than specific vendor oversight mechanisms, contractual standards, or requirements imposed on vendors. Contains no specific dates, named roles, frameworks, or verifiable facts—only generic references to 'service providers,' 'continuously monitor,' and standard risk impact language.


reasoning: The paragraph describes the company's internal risk management structure and processes, including team responsibilities, oversight relationships between IT, C&RM, and Internal Audit, and specific professional certifications held by team members. It focuses on organizational function rather than individual management roles or board oversight. The naming of specific certifications (CISSP, CISM, CRMA, CRISC) and the detailed organizational structure provide firm-specific detail beyond generic boilerplate, though no quantifiable data (dates, dollars, headcounts) meets the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal risk management processes, including the establishment of an IT risk committee in 2023 with specific departmental representation, meeting cadence, and reporting structure to the CISO and board. While the CISO is mentioned, the focus is on the function and processes rather than the individual's qualifications.


reasoning: The paragraph describes the Audit and Examination Committee's oversight responsibility for cybersecurity risk management and the quarterly reporting cadence from management, which falls under board governance of cyber risk. The Information Security Officer is identified as the specific cybersecurity role providing these reports, making the disclosure firm-specific.


reasoning: The paragraph describes the Bank's internal cybersecurity processes including monitoring, employee training, penetration testing, and incident response planning. It mentions third parties and insurance only as components of these internal processes rather than as standalone vendor oversight or financial strategy topics. No specific frameworks, dates, dollar amounts, named vendors, or cybersecurity-specific roles are identified; the language consists entirely of generic security practices that could apply to any financial institution.


reasoning: The paragraph describes the company's internal risk management processes, specifically the Cybersecurity Council's activities and executive management's role in assessing material cybersecurity risks. While it mentions specific cybersecurity titles (CIO, VP of Information Security), the focus is on organizational functions and processes rather than individual qualifications or board governance.


reasoning: The paragraph describes the company's internal incident response procedures, including severity classification and escalation protocols, which falls under Risk Management Process. The language is entirely generic and could apply to any company, with no named frameworks, roles, dates, or specific organizational details.


reasoning: The paragraph describes the company's cybersecurity metrics and reporting framework, underlying data sets, and reporting cadences to various governance bodies, which constitutes a description of internal risk management processes rather than focusing on the personal qualifications of the Chief Security Officer or solely on board oversight mechanics.


reasoning: This paragraph provides a standalone materiality conclusion stating that cybersecurity threats have not materially affected the company, without describing any specific incident, dates, or financial impacts. The language is standard SEC boilerplate regarding materiality assessments and contains no named frameworks, roles, or quantifiable data specific to the firm.


reasoning: The paragraph identifies the 'Vice President, Information Technology' as the specific management role responsible for cybersecurity governance and describes their reporting cadence and lines to the Audit and Reserves Committee. The grammatical subject is the management role, not the board committee, and the content focuses on the role's responsibilities rather than detailed risk processes or board oversight expertise.


reasoning: The paragraph discusses insurance reimbursements and materiality assessments regarding a prior cybersecurity incident without describing the incident's specific details, timing, scope, or response actions, fitting the Strategy Integration definition. It contains no specific dates, dollar amounts, named insurance carriers, or other verifiable facts that would distinguish it from standard boilerplate language used across filings.


reasoning: The paragraph describes the company's internal incident response and vulnerability management processes, including escalation procedures and reporting workflows. While it mentions specific management titles, the focus is on the functional process (how incidents are escalated and to whom) rather than the personal qualifications of the individuals. The inclusion of the specific title 'Executive Director of IT' and the explicit team composition (CFO, Executive Director of IT, VP of Finance) provides firm-specific detail beyond generic boilerplate.


reasoning: The paragraph describes the company's internal risk assessment processes (penetration testing and red-team exercises) and specific operational policies governing those processes, namely the three-year rotation limit for testing firms and biennial red-team exercise cadence. While third-parties are mentioned, they are service providers executing the company's risk management activities rather than the subject of vendor oversight.


reasoning: The paragraph focuses on Board and Audit Committee oversight of cybersecurity risk, including the Committee's charter responsibilities, composition requirements for directors with cyber expertise, and the briefing cadence from management. While CDIO and CISO roles are mentioned, they appear in the context of describing the governance reporting structure rather than as the primary subject.


reasoning: The paragraph describes an actual cybersecurity incident that occurred on June 30, 2024, including the detection date, unauthorized access to systems, and response actions (engaging external experts), which meets the criteria for Incident Disclosure rather than Strategy Integration or Risk Management Process.


reasoning: The paragraph identifies specific cybersecurity and IT management positions (Senior ISO, Director of IT, Director of Information Services) as the grammatical subjects, detailing their reporting lines to the CFO and CRO and their respective responsibilities. This focuses on the organizational structure and roles rather than the processes themselves, satisfying the Person-vs-Function Test for Management Role. It reaches Firm-Specific by naming cybersecurity-specific titles and the company's unique reporting structure.


reasoning: This paragraph contains a standard negative materiality disclaimer regarding the absence of material cybersecurity incidents, which per instructions categorizes as Strategy Integration. It offers no specific dates, roles, frameworks, or verifiable facts unique to the company, rendering it Generic Boilerplate.


reasoning: The paragraph describes Board oversight of the cybersecurity program and incident reporting thresholds, with the Board as the grammatical subject. It identifies specific cybersecurity leadership roles (CTO and CISO) that report to the Board, making it Firm-Specific, though it lacks quantifiable metrics, dates, or named third-party vendors that would be needed for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal risk management processes, including risk assessments, safeguards implementation, and monitoring activities. While it identifies the 'Senior Director, Head of IT and Informatics' as the role responsible for these functions and notes their reporting line to the CFO, the focus is on the processes and activities performed (assessing, monitoring, managing risks) rather than the individual's qualifications, credentials, or career history. Per the person-vs-function test, this falls under Risk Management Process. The specificity is Firm-Specific because it identifies a cybersecurity-specific management title ('Senior Director, Head of IT and Informatics'), which is not a generic C-suite role.


reasoning: The paragraph identifies specific cybersecurity management roles (CIO and SDIS), their reporting lines, and the SDIS's detailed qualifications and professional background. Per the person-vs-function test, the focus is on the person (tenure, certifications, degree) rather than abstract processes, fitting Management Role. It meets the Quantified-Verifiable threshold with multiple hard facts: a specific duration (15 years) and two named professional certifications (CISSP and CISM).


reasoning: The paragraph describes the company's internal cybersecurity processes (risk assessments, security controls, training, incident response, third-party risk management) without referencing the board, specific management roles, or actual incidents. It contains no named frameworks, specific dates, dollar amounts, headcounts, named third-party firms, or cybersecurity-specific titles (e.g., CISO), and uses generic program names like 'cybersecurity incident response plan' and 'security team' that could apply to any company.


reasoning: The paragraph provides a standalone materiality conclusion stating that no material cybersecurity incidents impacted the company in the last three years, which falls under Strategy Integration per the instructions regarding materiality assessments. The inclusion of the specific assessment date (December 31, 2024) makes the disclosure Firm-Specific rather than generic boilerplate.


reasoning: The paragraph focuses primarily on the identification, reporting structure, and detailed professional qualifications (educational backgrounds, certifications, and organizational memberships) of the CIO and CISO. While Board and Audit Committee oversight are mentioned, the extensive biographical details about these specific cybersecurity management roles place this squarely in Management Role per the person-vs-function test.


reasoning: The paragraph describes the integration of cybersecurity policies and procedures into the broader enterprise risk management program, which falls under Risk Management Process. The language is entirely generic boilerplate, containing no specific frameworks, named committees, dates, or quantifiable details that would identify this as unique to Niagen Bioscience.


reasoning: The paragraph is exclusively focused on vendor oversight, describing due diligence processes and contractual security requirements imposed on third-party service providers, which aligns with the Third-Party Risk category. It contains no named entities, specific dates, dollar amounts, or unique program identifiers—only generic descriptions of standard third-party risk management practices that could apply to any company.


reasoning: The paragraph centers on XPLR's reliance on external affiliates (NEE Management and NEER) to provide substantially all IT and cybersecurity functions, making vendor oversight the central topic. It names two distinct third-party entities, meeting the threshold for Quantified-Verifiable specificity.


reasoning: Paragraph describes the company's internal briefing processes for management and the Board on cybersecurity risks and their integration into the overall risk management framework. It is not about the qualifications of the management roles (Management Role) nor primarily about Board oversight governance (Board Governance). The presence of the cybersecurity-specific title 'CIO' and the specific reference to 'EchoStar's Board of Directors' (rather than generic 'the Board') makes this Firm-Specific.


reasoning: The paragraph describes internal cybersecurity processes including vulnerability scanning, penetration testing, and tabletop exercises, which falls under risk management and incident response planning. However, it contains no named frameworks, specific dates, identified personnel, or named third-party firms—only generic references to 'regular scans,' 'external service providers,' and 'leading cybersecurity firms' that could apply to any company.


reasoning: The paragraph describes the company's internal incident response protocols and governance processes, including the establishment of a crisis management team and materiality evaluation procedures. It identifies specific cybersecurity leadership roles (CIO, CISO) and names specific internal committees/teams, making it firm-specific rather than generic boilerplate.


reasoning: The paragraph describes the governance process for briefing the Audit Committee and Board of Directors on cybersecurity risks, focusing on oversight cadence and reporting structures. It contains only generic references to standard governance bodies (Audit Committee, Board of Directors, management team) and vague reporting frequencies ('twice a year,' 'regularly') without specific dates, named cybersecurity roles, or organizational details unique to the company.


reasoning: Paragraph describes the company's internal incident detection capabilities and response procedures (escalation, containment, restoration), which are core risk management processes. However, it uses only generic language ('cross-functional incident response plan,' 'reviewed annually,' 'periodically conducted') without naming specific tools, frameworks, dates, roles, or team compositions that would identify this as unique to Enviva.


reasoning: The paragraph focuses on identifying the CISO and COO, detailing their specific qualifications, career history (30+ years experience, prior roles at two large retailers), and reporting structure, which falls under Management Role. While it mentions risk processes, the specific biographical details and team composition (information security, IT and privacy teams) provide firm-specific substance that distinguishes this from generic disclosures.


reasoning: The paragraph describes the company's internal process of engaging external service providers to assist with evaluating and enhancing its information security policies and procedures, which falls under risk management processes. It contains no specific details—no named providers, frameworks, dates, dollar amounts, or specific roles—making it generic boilerplate that could apply to any company.


reasoning: The paragraph describes the company's planned internal cybersecurity risk management activities (threat detection, tabletop exercises, threat monitoring) without referencing specific frameworks, dates, roles, or tools, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal incident response framework and procedures (DSEP), including escalation protocols and assessment criteria, which falls under Risk Management Process. It contains firm-specific details including a uniquely named internal program (DSEP) and specific cybersecurity-related management titles (CISO, Chief Privacy Officer, VP of Technology Risk), meeting the threshold for Firm-Specific.


reasoning: The paragraph presents a standalone materiality conclusion stating that no cybersecurity threats have materially affected the company, which falls under Strategy Integration per the tiebreaker rules. The content consists entirely of generic materiality disclaimers and cross-references to Risk Factors without any named entities, specific dates, frameworks, or quantifiable details, making it Generic Boilerplate.


reasoning: The paragraph describes the company's (via its Advisor) internal cybersecurity processes—maintaining maturity, setting improvement objectives, and incorporating third-party assessment feedback—making it Risk Management Process. It contains one specific, quantified fact (the Director's 20 years of experience), which qualifies as Firm-Specific under the threshold requiring at least one unique identifying fact, but does not reach Quantified-Verifiable status which requires two hard verifiable facts.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and its integration with enterprise risk management, focusing on processes and standards. It names two recognized frameworks (NIST CSF and CIS) but provides no firm-specific implementation details, dates, roles, or organizational specifics that would distinguish Crane NXT's program from any other company using these same standards.


reasoning: The paragraph describes the company's internal risk assessment methodology and selection of security controls, which falls under Risk Management Process. It specifically names the CIS Critical Security Controls framework, qualifying it as Sector-Adapted, but lacks any firm-specific details such as dates, roles, metrics, or unique program identifiers.


reasoning: The paragraph describes an actual cybersecurity event (targeting of the online banking platform by threat actors creating phishing sites) with a timeframe ('beginning of the year') and impact assessment ('did not suffer losses'), fitting the Incident Disclosure category. However, it lacks specific dates (exact month/year or date), dollar amounts, named threat actors, named systems beyond generic 'online banking platform,' or named third-party firms, making it Generic Boilerplate.


reasoning: The paragraph leads with a materiality assessment for 2023 and references the June 2022 network outage primarily to explain incurred costs and security enhancements rather than to provide detailed incident narrative, fitting the tiebreaker for Strategy Integration when materiality is the main point with only brief incident mention. The specific dates ('In 2023', 'June 2022') and incident type ('network outage') make the disclosure firm-specific.


reasoning: The paragraph focuses on the qualifications, tenure, and committee participation of specific management personnel (the chief risk officer and interim chief information officer), applying the person-vs-function test. It contains two independently verifiable hard facts regarding years of professional experience (15 and 30 years), which meets the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph exclusively addresses vendor oversight, including pre-engagement due diligence, contractual security requirements, and ongoing monitoring of third-party service providers, which aligns with Third-Party Risk. It references Service Organization Controls (SOC) reports, a recognized industry framework, but contains no firm-specific details such as named vendors, dates, dollar amounts, or unique internal program identifiers.


reasoning: Paragraph describes the company's internal processes for risk assessment, threat identification, and ERM integration. While it briefly mentions Audit Committee oversight, the focus is on operational processes and a specific cross-functional team composition (information security, finance, compliance, legal), which qualifies as a firm-specific organizational detail.


reasoning: The paragraph contains a standalone materiality conclusion stating that no material cyber breaches have been experienced, which per the tiebreaker rules maps to Strategy Integration. The reference to reviewing policies is generic, and the disclosure lacks specific dates, named roles, frameworks, or quantifiable details, rendering it generic boilerplate.


reasoning: Paragraph describes the company's internal cybersecurity processes, integration with ERM, and adoption of recognized frameworks (NIST, ISO). While the Board is mentioned as providing oversight, the grammatical subject and focus are on the company's risk management policies and practices, not board governance activities. The disclosure names specific standards but contains no firm-specific details such as dates, headcounts, named roles, or unique program identifiers.


reasoning: The paragraph describes the integration of cybersecurity risk management into the broader enterprise risk management program and mentions shared methodologies and governance processes, which constitutes a description of internal risk management processes. It contains no specific dates, titles, named standards, quantifiable metrics, or unique program identifiers that would distinguish it from any other company's disclosure.


reasoning: The paragraph describes the company's internal cybersecurity policies, processes, and controls integrated into enterprise risk management, aligned with recognized frameworks. While it mentions the Board and management, the focus is on the function and framework adoption (NIST, ISO, Secure Controls Framework) rather than governance structure or specific personnel.


reasoning: The paragraph focuses on a specific cybersecurity management position (Director of Information Technology and Data Management Systems), detailing the title, reporting line to the CEO, and specific qualifications (20+ years experience), which satisfies the person-vs-function test for Management Role. While the Board is mentioned, the specific details about the individual's credentials and reporting structure are the substantive content.


reasoning: The paragraph describes a specific historical cybersecurity incident with concrete details including the date (June 2018), financial impact ($10 million), and nature of the attack (unauthorized email access resulting in fraudulent payment disbursements). While the paragraph includes materiality conclusions, the detailed incident narrative with specific dates and scope triggers Incident Disclosure classification. The specific date and dollar amount provide two hard verifiable facts, meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal cyber risk management processes, including threat hunting, network monitoring, threat intelligence sharing, and third-party security assessments. While it mentions reviewing third-party service providers, this is presented as one component of the broader risk management program rather than the central topic. The disclosure lacks specific frameworks (e.g., NIST, ISO 27001), dates, named tools, specific organizational titles (e.g., CISO), or quantified details, consisting entirely of general security practices that could apply to any company.


reasoning: The paragraph assigns cybersecurity risk oversight responsibility to the board of directors and audit committee, making board governance the primary topic. It contains no specific facts—only generic references to standard governance bodies (board of directors, executive officers, audit committee) without naming specific individuals, dates, frameworks, or organizational details unique to the company.


reasoning: Paragraph identifies specific cybersecurity-related management roles (CISO, CIO, CRO) and their qualifications (over 15 years experience), describing the hierarchical escalation path to these executives and potentially the Risk Committee. The focus on named roles and their expertise credentials places this in Management Role rather than process description.


reasoning: The paragraph describes the company's internal incident response planning and preparation activities, including policy maintenance and exercise protocols, which falls under Risk Management Process. However, it contains only generic descriptions of standard cybersecurity practices (employee handbook, Code of Conduct, incident response plan, regular exercises) without naming specific frameworks, dates, tools, or unique organizational details that would identify this as specific to PDF Solutions.


reasoning: The paragraph describes the company's systematic, cross-functional approach to identifying and mitigating cybersecurity threats and its ERM integration, including specific internal governance structures. While it mentions Board oversight and the CIO, the focus is on the company's internal processes and controls rather than board expertise or management qualifications.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including policies, risk assessments, team responsibilities, and third-party vetting as components of its own processes. The content contains generic descriptions of standard security practices applicable to any company, with no named frameworks, specific titles (e.g., CISO), dates, dollar amounts, or named third-party firms.


reasoning: The paragraph focuses on the qualifications, credentials, and career history of specific cybersecurity personnel (LMC's Head of Cybersecurity and QVC's VP Information Security), including specific tenures (25+ and 30+ years) and professional certifications (CISM, CRISC, CISSP), which fits the Management Role category. It meets the Quantified-Verifiable threshold with multiple specific durations and named certifications.


reasoning: The paragraph focuses on a specific management role (informational technology consultant) and their qualifications/career history (25 years of experience), which fits the Management Role category under the person-vs-function test. The specific number of years of experience qualifies as a firm-specific fact.


reasoning: The paragraph describes the company's internal processes for assessing risks, selecting third parties, responding to incidents, training personnel, and monitoring IT responsibilities. This falls under Risk Management Process. However, it contains no specific facts—no named roles (CISO/CIO), committees, dates, frameworks, numbers, or unique program identifiers—and could apply to any company, making it Generic Boilerplate.


reasoning: The paragraph discusses the company's expenditure of resources on cybersecurity risk management, strategy, and governance, falling under the company's internal risk management activities. However, it contains no specific frameworks, titles, dates, or quantifiable details, consisting entirely of generic language applicable to any technology company.


reasoning: The paragraph describes internal risk management processes including the CSIRP (Cyber Security Incident Response Plan), escalation protocols, and briefing cadences to leadership and the Board. While it mentions the CIO, the focus is on the functions and processes rather than the individual's qualifications. Specific identifiers include the CIO title, the named CSIRP program, and the Executive Response Team.


reasoning: The paragraph describes the company's internal Enterprise Risk Management Committee (ERMC) processes, including quarterly risk assessments and the integration of cybersecurity action plans from the CISO into decision-making, which constitutes a risk management process. It contains firm-specific elements including the named ERMC committee and cybersecurity-specific roles (CISO, CDO).


reasoning: The paragraph describes the company's internal ERM program and how cybersecurity risk is evaluated and managed through specific organizational functions (GRC) and reporting structures. While it mentions specific cybersecurity roles (CISO, CDIO), the focus is on the process and organizational framework rather than the individuals' qualifications, satisfying the person-vs-function test for Risk Management Process.


reasoning: The paragraph describes an actual cybersecurity incident, including the specific discovery date (April 5, 2024), the affected subsidiary (Targus), the nature of unauthorized access, containment measures, and operational impact. While it includes a materiality assessment, the primary content is the incident narrative itself. The presence of a specific date and named subsidiary makes this Firm-Specific rather than generic boilerplate.


reasoning: The paragraph describes internal risk management activities (penetration testing and vulnerability assessments) but contains only generic elements: unnamed 'leading service providers,' non-specific cadence ('annual'), and no named frameworks, tools, or specific roles. It lacks any firm-specific details that would distinguish it from any other company's disclosure.


reasoning: The paragraph identifies a 'cybersecurity sub-committee' as the grammatical subject responsible for oversight and management of cyber risks, and specifies their combined years of expertise (45 years). This describes a governance committee's role and qualifications, fitting the Board Governance category which covers committee oversight and board cyber expertise.


reasoning: The paragraph focuses on the CISO's personal qualifications, career history, education, and direct reports, making the management role the grammatical subject. It meets the Quantified-Verifiable threshold through multiple specific headcounts and durations (20+ years experience, 20+ team members, two IS leads).


reasoning: The paragraph describes the company's internal information security processes for identifying, assessing, and managing cybersecurity risks to its systems and data, which fits the Risk Management Process category. It contains no specific dates, named frameworks, cybersecurity-specific roles, third-party firms, tools, or quantifiable details, making it generic boilerplate language applicable to any company.


reasoning: The paragraph describes the company's internal incident response structure, named internal programs (IRT, Cybersecurity Plan), and monitoring processes. While executive titles appear, they are listed as team members rather than being the focus of the disclosure, and the Board is mentioned only as a recipient of reports rather than the primary subject.


reasoning: The paragraph describes internal risk management processes (monitoring threat environments, conducting scans, completing audits) performed by management, making it about the function rather than the people. However, it contains no firm-specific details: the roles mentioned (SVP of Finance, Director of IT) are generic executive positions, and the activities described (maintaining tools, third-party assessments) lack named frameworks, specific dates, dollar amounts, or identified tools/products.


reasoning: The paragraph describes the company's internal information security processes including change management, patching, multifactor authentication, and monitoring. It contains no specific details—no named consultants, tools, dates, frameworks, or cybersecurity-specific roles—that would identify this as unique to EXOZYMES INC. The mention of the Audit Committee is standard governance language and does not provide firm-specific detail.


reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities and reporting cadence regarding cybersecurity, with the board committee as the grammatical subject. It identifies the Chief Information Officer (a cybersecurity-specific title per the IS list) as leading the cybersecurity team, distinguishing it from generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including IT risk assessments, specific assessment toolkits, an Information Security Department, and incident response protocols. It references multiple named third-party entities (FFIEC, Bankers Electronic Crimes Task Force, U.S. Secret Service) and named tools (Cybersecurity Assessment Toolkit, Ransomware Assessment Toolkit), satisfying the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal processes for assessing cyber risks, monitoring systems for vulnerabilities, and utilizing security tools (SIEM, EDR, IDPS, etc.), fitting the Risk Management Process category. It lacks any specific dates, named products/tools, frameworks, headcounts, or quantified details, consisting entirely of generic security activities and tool categories applicable to any company.


reasoning: Paragraph describes an actual cybersecurity incident involving employee interactions with suspicious websites, containment actions, and forensic investigation results, which qualifies as Incident Disclosure. However, it contains no specific dates, dollar amounts, named third-party firms, products, or other verifiable hard facts—only vague temporal references ('During the reporting period') and generic incident descriptions, making it Generic Boilerplate.


reasoning: The paragraph describes the integration of cybersecurity risk assessment into the company's overall enterprise risk management framework and the internal processes for prioritizing and mitigating threats. While it references the Vice President of IT, the focus is on the risk management function and activities rather than the individual's qualifications, reporting lines, or background.


reasoning: The paragraph describes the company's internal risk governance process, specifically the Engineering Risk Steering Group's functions in overseeing risk decisions, monitoring control performance, and reviewing compliance approaches. While the CISO is mentioned, the focus is on the committee's activities and structure rather than the individual's qualifications or reporting lines alone.


reasoning: The paragraph describes the company's internal cybersecurity risk management activities, including periodic reviews, audits, and annual risk assessments using a specific named tool. While the Board is mentioned as approving and receiving reports, the grammatical subjects are the Information Security Program and team, focusing on operational processes rather than governance structure or specific personnel.


reasoning: The paragraph focuses exclusively on the company's oversight of cybersecurity risks presented by third parties, vendors, and service providers, which is the central topic of the Third-Party Risk category. The disclosure contains no named frameworks, specific dates, dollar amounts, cybersecurity-specific roles, or unique organizational details that would identify Quad/Graphics specifically, making it generic boilerplate language applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity processes, technologies, and risk management activities including vulnerability assessments, penetration testing, and tabletop exercises. It qualifies as Firm-Specific due to the explicit certification claim regarding payment card industry standards (PCI DSS), which constitutes a verifiable firm-specific fact beyond generic process descriptions.


reasoning: The paragraph describes an actual cybersecurity incident with specific dates (August 5-8, 2025), unauthorized access details, and forensic investigation status, satisfying the Incident Disclosure criteria. It contains one hard verifiable fact (specific dates) and a named incident identifier, which qualifies as Firm-Specific but does not reach the two-hard-fact threshold for Quantified-Verifiable.


reasoning: The paragraph exclusively addresses oversight of third-party service providers through vendor questionnaires, due diligence, and contractual security terms. The description uses generic language (risk-based approach, vendor questionnaires, security terms) without naming specific vendors, frameworks, dates, or quantifiable details that would identify Madrigal's unique program.


reasoning: Paragraph describes a specific past cybersecurity incident including when it occurred (2022), scope of impact (Company's network), and response actions activated (protocols, investigation), fitting the Incident Disclosure definition. Contains one specific temporal fact (year 2022) that distinguishes it from generic boilerplate, but lacks a second hard verifiable fact (e.g., month/date, dollar amount, named firm) required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal process for assessing and reporting cybersecurity threats, including the workflow from identification by the CIO/CISO to materiality determination by the MAT and escalation to the Risk Committee. It contains firm-specific elements including cybersecurity-specific roles (CISO, CIO), a named board committee (Risk Committee), and a designated internal team (MAT), but lacks quantifiable metrics or dates required for Quantified-Verifiable.


reasoning: Paragraph focuses entirely on oversight of third-party SaaS providers and service partners, including contractual security requirements and onboarding assessments. Contains no named entities, dates, frameworks, or specific details that would identify this as unique to Karat Packaging.


reasoning: The paragraph identifies the company's Chief Technology Officer as the executive responsible for cybersecurity, details their reporting lines to the Board's Audit Committee, and lists specific qualifications including tenure and external committee memberships, fitting the Management Role category. While it contains specific facts about the CTO's experience and external roles, it lacks the required two hard verifiable facts (specific dates, dollar amounts, headcounts, percentages, named third-party firms, or named tools) necessary for Quantified-Verifiable classification.


reasoning: The Board of Directors and Audit Committee are the grammatical subjects overseeing enterprise-wide risk management including cybersecurity, with the VP IT serving as the reporting role rather than the focus. The specific title 'VP IT' qualifies as a cybersecurity-specific role per the IS list.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, enterprise-wide security program, and implemented controls, which aligns with Risk Management Process. Although the CISO is mentioned as managing the program, the focus is on the function and activities rather than the individual's qualifications or background. The specific title 'Chief Information Security Officer' constitutes a firm-specific detail per the guidelines, distinguishing it from generic boilerplate.


reasoning: The paragraph describes internal processes for threat awareness, personnel education, and system upgrades, fitting Risk Management Process. It contains no named frameworks, specific dates, cybersecurity-specific roles (CFO is generic), or named third parties—only generic references to 'expert consultants' and 'personnel' that could apply to any company.


reasoning: This paragraph is purely a cross-reference directing readers to the Risk Factors section and contains no substantive cybersecurity disclosure, governance description, or process details of its own.


reasoning: The paragraph describes internal employee training processes (monthly awareness training, phishing exercises, role-based training) as part of the company's cybersecurity risk management. However, it contains only generic practices without specific dates, metrics, named tools, or unique program identifiers, making it applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity processes (threat identification, incident evaluation, response procedures) performed by its information security and data privacy teams. It contains no named frameworks, specific dates, dollar amounts, named tools, or unique program identifiers that would distinguish it from a generic disclosure.


reasoning: The paragraph describes an actual cybersecurity incident with specific details: the discovery date (February 14, 2025), the nature of the incident (unauthorized third-party access to email systems), and the operational impact (misdirected vendor payments). It also references the fiscal year end date (June 30, 2025). Because it contains two specific dates, it meets the threshold for Quantified-Verifiable.


reasoning: The paragraph narrates a specific past cybersecurity incident, including the exact date (January 31, 2022), the affected systems (Aurora acquisition), response actions taken, and investigation findings. This fits the Incident Disclosure category. It qualifies as Firm-Specific due to the specific date and named acquisition, though it does not reach Quantified-Verifiable status as it lacks a second hard verifiable fact (such as a named forensics firm, dollar amount, or headcount).


reasoning: The paragraph focuses exclusively on vendor oversight processes—specifically the assessment and monitoring of third-party providers to ensure compliance with security standards—making it Third-Party Risk. It contains no named entities, specific dates, frameworks, or unique organizational details, rendering it Generic Boilerplate that could apply to any company.


reasoning: Paragraph provides a detailed narrative of an actual cybersecurity incident (fraudulently-induced wire transfers), including specific timing (early Fiscal 2024), response actions (contacting banks, law enforcement, forensic investigation), and financial impact, satisfying Incident Disclosure criteria. It meets the Quantified-Verifiable threshold with two hard facts: the specific fiscal year date and the exact $2.7 million loss amount.


reasoning: The paragraph describes board and Audit Committee oversight activities, including receiving periodic updates and annual discussions with senior management regarding cybersecurity threats, making the board/committee the grammatical subject. It contains only generic governance references (Board, Audit Committee, CEO) and vague timing descriptors ('periodic,' 'annual') without specific dates, named frameworks, cybersecurity-specific roles, or other firm-unique details that would distinguish this disclosure from any other company.


reasoning: The paragraph describes a specific 2021 cybersecurity incident involving malware, detailing the attack vector, response actions (quarantine, server rebuild), operational impact (server outage), and scope (1,700 flight cancellations). It includes multiple quantified, verifiable facts including specific dates (2021; year ended December 31, 2023), dollar amounts ($16 million), headcounts (1,700 cancellations), and percentages (half of loss recovered).


reasoning: The paragraph describes the company's internal incident response workflow, risk assessment methodology (four-tier system), and business continuity planning, which are core risk management processes. While it references specific cybersecurity roles (CISO, CIO) and a detailed tiered classification system, it lacks independently verifiable hard facts such as specific dates, dollar amounts, headcounts, percentages, or named third-party firms/tools required for Quantified-Verifiable classification.


reasoning: The paragraph describes the company's internal risk assessment procedures, including quarterly meetings of the Information Security Steering Committee and annual cybersecurity risk assessments incorporating tabletop exercises and penetration testing. It identifies firm-specific organizational elements including the CISO role and the named Information Security Steering Committee.


reasoning: Paragraph presents a standalone materiality assessment regarding cybersecurity risks and discloses the absence of material incidents in recent fiscal periods, which falls under Strategy Integration. The specific naming of fiscal years 2025 and 2026 provides firm-specific temporal context, distinguishing it from generic boilerplate, though it lacks the quantified metrics or named third-party entities required for Quantified-Verifiable classification.


reasoning: The paragraph focuses on Board oversight activities, with the Board as the grammatical subject receiving reports, briefings, and continuing education presentations on cybersecurity. While the Chief Information Officer is mentioned as presenting to the Board, the primary focus is governance and oversight functions rather than management role structure or qualifications.


reasoning: The paragraph describes an actual cybersecurity incident with specific details: the date (September 14, 2023), what occurred (social engineering attack on an outsourced vendor, unauthorized access to the loyalty program database), and response actions taken (activation of the IRP, investigation, notifications to law enforcement and regulators). This matches the Incident Disclosure category. Specificity is Firm-Specific due to the specific date and reference to the company's IRP, but does not reach Quantified-Verifiable as it lacks a second hard verifiable fact such as a named third-party firm, dollar amount, or specific product/tool.


reasoning: The paragraph provides a negative materiality assessment stating that no cybersecurity incidents occurred that affected business operations, which aligns with Strategy Integration's coverage of materiality conclusions and business impact rather than describing an actual incident or governance processes. The specific fiscal year-end date 'December 31, 2024' qualifies as one hard verifiable fact, making the disclosure Firm-Specific.


reasoning: The paragraph describes an actual cybersecurity incident affecting third-party vendor Change Healthcare, including specific dates (March 7 and March 18, 2024), the scope of impact on the company's Exogen device claims processing, and response actions taken. While it contains materiality assessments, the primary substance is the incident narrative with multiple independently verifiable facts.


reasoning: The paragraph provides a materiality assessment regarding cybersecurity risks ('have not materially affected... our business strategy, results of operations, or financial condition') and mentions the absence of cyber insurance coverage, but contains no specific details about governance structures, management roles, processes, or actual incidents. It uses standard SEC boilerplate language that could apply to any company.


reasoning: This paragraph contains generic forward-looking risk language stating that third-party cybersecurity incidents could materially affect the company. It does not describe the company's internal cybersecurity governance, management roles, risk processes, or vendor oversight programs, nor does it disclose a specific incident or materiality assessment. It is boilerplate that could apply to any company.


reasoning: The paragraph describes the Audit Committee and Board of Directors overseeing cybersecurity risks, making Board Governance the appropriate category. It contains only standard governance references (Audit Committee, Board of Directors) and vague timing ('periodic basis'), with no firm-specific details, frameworks, or quantifiable data.


reasoning: The paragraph describes the company's internal cybersecurity processes including continuous monitoring, incident response planning, and employee training, which falls under Risk Management Process. It contains no specific details—no named tools, frameworks, dates, roles, or programs—making it generic boilerplate that could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including ERM integration, risk assessment cadences, and reporting to specific named committees (Enterprise Risk Committee, Security Steering Committee) with defined compositions involving cybersecurity-specific roles (CISO, CIO). It focuses on organizational processes and structures rather than individual qualifications or board oversight alone.


reasoning: The paragraph's central and exclusive focus is on oversight of third-party vendors, service providers, and external users, describing the company's approach to identifying and monitoring cybersecurity threats from these external parties. No specific vendors, dates, frameworks, dollar amounts, or quantifiable details are provided—only generic descriptions of oversight activities that could apply to any company.


reasoning: The paragraph identifies the Vice President of Information Technology as the specific management role responsible for cybersecurity monitoring, incident awareness, and reporting to management, falling under Management Role. It includes the cybersecurity-specific title 'Vice President of Information Technology' as a firm-specific fact, but lacks the required two hard verifiable facts (dates, dollar amounts, headcounts, percentages, named third-party firms, or named products) for Quantified-Verifiable classification.