reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, describing the scope of affected systems (back-office), the nature of exfiltrated data (PII, bank account information), and specific response actions (regulatory cooperation, customer notifications). It contains two hard verifiable facts: the specific timing 'fourth quarter of 2023' and the specific headcount 'three state consumer and financial service regulators'.


content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities and quarterly briefing cadence regarding information security, with the committee as the grammatical subject. The identification of a 'chief security officer' (a cybersecurity-specific title) provides a firm-specific detail, though no second hard verifiable fact (date, dollar amount, percentage, or named third party) is present to reach Quantified-Verifiable.

provider: moonshotai

stage: benchmark


content_category: Risk Management Process

reasoning: The paragraph describes internal cybersecurity processes including risk assessments, penetration testing, maturity testing, and monitoring activities performed by the IT security team. Third-party risks are mentioned only as a component of the overall framework, not as the central topic. No specific frameworks (e.g., NIST, ISO), dates, dollar amounts, named vendors, or cybersecurity-specific roles (e.g., CISO) are disclosed, making the content generic boilerplate that could apply to any company.


content_category: Incident Disclosure

reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident that occurred on September 23, 2023, describing the scope (internal IT infrastructure, billing systems), operational disruptions (order processing, logistics), and financial impacts, concluding with a materiality assessment. It contains two specific verifiable dates: the exact incident date (September 23, 2023) and the specific fiscal quarter affected (first quarter of fiscal 2024).


content_category: Third-Party Risk

reasoning: The paragraph focuses exclusively on third-party vendor oversight, including engagement of security vendors, contractual security requirements imposed on suppliers, and monitoring of third-party compliance, making Third-Party Risk the central topic. The disclosure lacks named vendors, specific dates, dollar amounts, or other verifiable details, consisting entirely of generic descriptions applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including risk identification, monitoring, mitigation, and reporting structures, rather than focusing on the qualifications of the specific individual (Principal Accounting Officer) or board oversight alone. It meets the Quantified-Verifiable threshold by citing three specific fiscal years (2021, 2022, 2023) and a specific percentage (100% independent audit committee).


reasoning: The paragraph describes the company's internal processes for assessing, identifying, and managing cybersecurity risks, including yearly risk assessments, an incident response team, and an incident response plan. While it mentions the CISO's qualifications (25 years experience), the focus is on the overall risk management functions and organizational structure rather than the individual's biography, satisfying the Person-vs-Function Test for Risk Management Process.


reasoning: The paragraph describes internal risk management processes including vulnerability scanning, penetration testing, threat intelligence monitoring, and incident escalation protocols. While Mr. Daly and team certifications are mentioned, the focus is on ongoing operational activities rather than personal qualifications or organizational structure, satisfying the person-vs-function test for Risk Management Process. Specificity is Firm-Specific due to named certifications (CISSP, SANS Institute Global Information Assurance Certification) and the named third-party organization (SANS Institute).


reasoning: The paragraph describes the company's internal incident response framework, team structure, and escalation procedures, which falls under risk management processes. It contains no specific dates, named roles (e.g., CISO), named committees beyond the standard Audit Committee, specific numbers, or other firm-specific details that would distinguish this disclosure from any other company's generic incident response description.


reasoning: The paragraph focuses on Board and Audit Committee oversight of cybersecurity risk, with the Board and committees as grammatical subjects discussing their delegated responsibilities and briefing cadences. It identifies specific cybersecurity leadership roles (CIDO and Senior Director, Global IT Security) responsible for providing updates to the Board, which are firm-specific details not found in generic boilerplate.


content_category: None/Other

reasoning: This paragraph is a pure cross-reference directing readers to Item 1A Risk Factors for cybersecurity risk descriptions. It contains no substantive disclosure about the company's actual cybersecurity governance, processes, or incidents, and therefore falls under None/Other per the classification guidelines.


content_category: Strategy Integration

reasoning: The paragraph provides a standalone materiality disclaimer stating that cybersecurity threats have not materially affected the company, which falls under Strategy Integration per the guidelines. It contains no named entities, frameworks, roles, dates, or specific details—only boilerplate language and a cross-reference to Risk Factors that does not alter the classification.


reasoning: The paragraph focuses exclusively on vendor security assessments, onboarding, and contract review processes for service providers, making vendor oversight the central topic. The language is entirely generic, referencing an unnamed 'industry leading third-party vendor security ratings company' without identifying specific vendors, standards, dates, or quantifiable details.


reasoning: The paragraph describes the company's internal risk management processes, specifically engaging external experts to conduct system audits, threat assessments, and monitoring. It does not name the third-party firm, cite specific dates or costs, or identify unique tools, making it generic boilerplate describing common security practices applicable to any company.


content_category: Management Role

reasoning: The paragraph focuses primarily on management reporting structures, identifying the CISO and Chief Risk Officer and detailing their reporting lines to the Risk Management Council and Board Risk Committee. While board oversight is mentioned, the emphasis is on the management organizational hierarchy and reporting cadences rather than board governance processes or operational risk management activities.


reasoning: The paragraph describes the company's internal cybersecurity organizational structure and risk management processes, specifically the Information Security Office and its Information Security Incident Response Plan. While the CIO is mentioned as leading the office, the focus is on organizational function and processes rather than the individual's qualifications or background, satisfying the person-vs-function test for Risk Management Process. The disclosure includes specific organizational titles and department names that distinguish it from generic boilerplate.


reasoning: The paragraph focuses on the qualifications and experience of the management team, specifically identifying the Director of Information Technology and their 35 years of combined experience. It describes the team's credentials, track record, and responsibilities, making it about the person/role rather than just abstract processes.


reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity risk and the reporting cadence from management (COO), making Board Governance the appropriate category. It contains only generic governance elements—standard Board and Audit Committee references, a generic C-suite title (COO), and vague temporal language ('periodic')—with no firm-specific details, named frameworks, or cybersecurity-specific roles.


reasoning: The paragraph identifies specific cybersecurity leadership roles (CISO, CIO) and details their reporting lines and organizational structure (four divisions), fitting the Management Role category definition which includes reporting lines. While the Audit Committee is mentioned, the grammatical subjects are management roles. The disclosure contains firm-specific organizational details (CISO, CIO, four divisions) but lacks quantifiable data like specific dates, dollar amounts, or named third-party firms required for Quantified-Verifiable.


reasoning: The paragraph focuses on the Chief Information Officer's reporting structure to the Audit Committee, the scope of reports (risk assessment, incidents, etc.), and the CIO's specific qualifications (20 years of experience). While board and committee oversight are mentioned, the grammatical subjects in the latter half are the CIO, and the specific tenure detail qualifies as person-specific information. The disclosure contains firm-specific facts (CIO title and specific duration of experience) but lacks a second hard verifiable fact (such as a specific date, dollar amount, or named third party) needed for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal information security processes for identifying, assessing, and managing cybersecurity risks to its systems and data. It contains no named frameworks, specific dates, dollar amounts, named roles, or other distinguishing details that would identify it as specific to this company.


reasoning: The paragraph describes the company's internal incident response workflows and escalation procedures, including the specific 'Incident Management Team' and 'disclosure committee' involved in mitigation and escalation, which falls under risk management processes rather than board governance or a specific incident disclosure.


reasoning: The paragraph's central topic is vendor oversight, describing vetting processes, contractual security requirements, and third-party attestations. It identifies specific internal departments (legal, procurement/sourcing) involved in managing these relationships, distinguishing it from generic boilerplate.


reasoning: The paragraph is centrally focused on vendor oversight, describing the company's reliance on third-party service providers and its processes for assessing and mitigating cybersecurity risks associated with those providers. It contains no specific dates, dollar amounts, named third-party firms, or quantifiable details—only generic descriptions of 'pre-engagement and periodic risk assessments' and 'strategic risk management committees' that could apply to any company.


reasoning: The paragraph focuses on board and committee oversight of cybersecurity risk, with the board enterprise risk committee and cybersecurity subcommittee as the grammatical subjects reviewing information and engaging with management. It identifies specific governance structures (enterprise risk committee, cybersecurity subcommittee) and the CISO role, but contains no quantifiable data or dates.


reasoning: The paragraph describes the company's internal cybersecurity processes (program implementation, threat monitoring, incident response) and organizational coordination, with the CISO acting as the process owner rather than the biographical subject. It contains firm-specific organizational details including the CISO role and specific team names (Technology and ERM), but lacks quantifiable data points like dates, headcounts, or vendor names needed for Quantified-Verifiable.


reasoning: While the CFO is identified as overseeing the program, the paragraph primarily describes the company's internal cybersecurity processes, protocols, safeguards, and frameworks (ISO 27001 alignment, incident response plan, ISMS process, third-party assessments). Under the person-vs-function test, the content remains coherent even without the CFO reference, confirming the focus is on the Risk Management Process rather than the individual's qualifications.


reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity risks and their briefing cadence, with the board/committee as the grammatical subject. It identifies the specific title 'Senior Director of Information Technology' (a cybersecurity-specific role) as providing updates, which constitutes a firm-specific fact, though it lacks the hard verifiable facts (dates, dollars, percentages, named firms) required for Quantified-Verifiable.


reasoning: The paragraph primarily presents a boilerplate materiality assessment stating that cybersecurity risks have not materially affected the company's business strategy, results of operations, or financial condition. While it briefly mentions experiencing threats and breaches 'from time to time,' it provides no specific details (dates, scope, or response actions) about any actual incident, and the cross-reference to Risk Factors does not constitute firm-specific substance.


reasoning: The paragraph explicitly describes Board oversight of cybersecurity risk, with the CFO providing ultimate direction. However, the CFO is a generic financial C-suite role (not CISO/CTO/CIO), so it does not qualify for Management Role. No specific committees, dates, frameworks, or firm-specific details are disclosed, making this generic boilerplate language applicable to any company.


reasoning: Paragraph focuses on the CISO's personal qualifications, tenure, and credentials rather than processes, fitting Management Role. Contains multiple hard verifiable facts: specific year (2012), specific duration (over two decades), specific count (four certifications), and four named professional certifications (CISM, CISA, CDPSE, CCNA), exceeding the two-fact threshold for Quantified-Verifiable.


reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity risk management, with the Board as the grammatical subject. However, it contains only generic references to standard governance bodies (Board of Directors, Audit Committee) and vague cadences ('periodic', 'each quarter') without specific dates, named cybersecurity roles (e.g., CISO), or unique program identifiers, making it generic boilerplate applicable to any company.


reasoning: The paragraph identifies the Chief Information Security Officer as the person responsible for cybersecurity and describes their reporting line to the IT/Cybersecurity Committee, making the management role the grammatical subject and primary focus. It contains firm-specific details including the cybersecurity-specific title (CISO) and a named non-generic board committee (IT/Cybersecurity Committee), but lacks quantifiable data points like dates, headcounts, or dollar amounts needed for Quantified-Verifiable.


reasoning: The paragraph provides a standalone materiality conclusion stating that cybersecurity risks have not materially affected the company's business strategy, results of operations, or financial condition, which falls under Strategy Integration. It contains no specific dates, dollar amounts, named entities, or firm-specific details—only generic risk categories (phishing, ransomware) and boilerplate language that could apply to any company.


reasoning: Paragraph describes the company's internal incident response planning and testing activities (tabletop exercises, response procedures), which fall under risk management processes. The mention of cyber insurance is incidental and does not shift the primary focus to financial strategy. The content contains no specific facts—'tabletop exercises,' 'incident response procedures,' and 'cyber insurance' are generic terms applicable to any company without identifying dates, amounts, tools, or specific roles.


specificity_confidence: medium

reasoning: The paragraph primarily presents a materiality disclaimer stating that cybersecurity incidents have not materially affected the company's business strategy, results of operations, or financial condition, which falls under Strategy Integration. Although the paragraph includes cross-references to Risk Factors, these do not override the classification because a substantive materiality conclusion is present. The reference to 'our bitcoin' in the cross-reference constitutes a firm-specific fact unique to Strategy Inc (MicroStrategy), distinguishing the disclosure from generic boilerplate.


reasoning: The paragraph describes the company's internal risk management processes (hiring personnel, maintaining budgets, incident preparation, approving processes, reviewing assessments) and assigns responsibility for these functions to specific management roles. Per the Person-vs-Function test, because the paragraph focuses on what the roles DO (processes and activities) rather than the individuals' qualifications, credentials, or reporting lines, it falls under Risk Management Process rather than Management Role. The mention of the 'Cybersecurity Risk Management Committee' and the specific composition of officers responsible for these activities ('Chief Business Officer, Chief Accounting Officer, and Head of Legal') provides firm-specific detail.


reasoning: The paragraph describes internal processes for evaluating cyber risks, detecting vulnerabilities through technical safeguards, and incident notification procedures. While the CISO and Head of Legal are mentioned, they are not the grammatical subjects nor is the focus on their personal qualifications; rather, it describes their collaborative functions within the risk management framework.


reasoning: The paragraph centers on vendor oversight, describing due diligence processes for third-party providers, contractual security requirements imposed on vendors processing customer data, and evaluation methods for third-party security postures. It references recognized standards (ISO certifications and SOC reports) but contains no firm-specific details such as named vendors, dates, or quantified metrics.


reasoning: The paragraph describes an internal process (briefing senior management on cybersecurity matters) rather than the personal qualifications or reporting structure of the SVP of IT, placing it in Risk Management Process per the person-vs-function test. It contains one firm-specific fact—the title 'SVP of IT'—which is a specific cybersecurity-related role, but lacks additional hard verifiable facts (dates, dollar amounts, percentages, named firms) needed for Quantified-Verifiable.


reasoning: The paragraph describes an actual cybersecurity incident including the timeframe (Q3 2022), unauthorized access and exfiltration of employee PII, operational impacts, and response actions, fitting Incident Disclosure. It contains a specific date (September 30, 2022), making it Firm-Specific.


reasoning: The paragraph identifies specific management personnel (senior vice president, finance and accounting; senior IT consultant) and details their qualifications, experience levels, and reporting structure, fitting the Management Role category. It contains one firm-specific fact: the consultant's 'over 20 years of experience' provides a specific duration that distinguishes this disclosure from generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion stating that no cybersecurity incidents have materially affected the company, which falls under Strategy Integration per the tiebreaker rules. The language is entirely boilerplate, containing no specific dates, incidents, named entities, or firm-specific details that could not apply to any company.


reasoning: The paragraph describes the Committee's oversight of cybersecurity risks, including the cadence of reports from management (quarterly), incident update protocols, and the Committee's own reporting to the full Board and continuing education activities. While the CTO is mentioned as the reporter, the grammatical subjects of the latter half are the Committee itself, and the content focuses on governance processes. The specificity is Firm-Specific due to the identification of the Chief Technology Officer (a cybersecurity-specific title), though other elements like 'the Committee' and 'quarterly' are generic.


reasoning: The paragraph focuses on board-level oversight, specifically describing the composition and expertise of the Technology & Cybersecurity Committee and director training practices. The naming of a non-standard board committee (Technology & Cybersecurity Committee) provides a firm-specific detail that distinguishes this disclosure from generic governance language.


reasoning: The paragraph constitutes a materiality assessment discussing how cybersecurity risks may materially affect business and financial condition, which falls under Strategy Integration. It lacks any specific dates, named frameworks, roles, or quantifiable details, consisting entirely of generic forward-looking statements and a cross-reference to Risk Factors.


reasoning: The paragraph contains a standalone materiality disclaimer regarding cybersecurity risks ('have to date not materially affected... our business strategy, results of operations or financial condition'), which qualifies as Strategy Integration under the tiebreaker rules. The cross-reference to Risk Factors does not change this classification. The text consists entirely of boilerplate language with no specific dates, named roles, frameworks, or quantified details that would identify it as unique to this company.


reasoning: Paragraph provides a detailed narrative of a specific cybersecurity incident from March 2021, describing the cause (systems outage), response actions (forensic firms, legal counsel, system restoration), operational impact (brewery operations, production, shipment delays), and quantified financial costs ($2.4 million). The inclusion of specific dates and dollar amounts provides multiple independently verifiable hard facts.


reasoning: The paragraph discusses the existence of cybersecurity insurance coverage, which falls under business/financial impact and risk mitigation strategy (Strategy Integration). The disclosure contains no specific details such as coverage limits, premiums, named insurers, or policy terms, making it generic boilerplate language that could apply to any company.


reasoning: The paragraph provides a standalone materiality assessment stating that prior cybersecurity incidents have not materially impacted business strategy, operations, or financial condition, which falls under Strategy Integration. It contains no specific facts, dates, dollar amounts, named roles, or other identifying details, making it Generic Boilerplate that could apply to any company.


reasoning: Paragraph describes the company's internal incident response planning, including CIRT strategies aligned with DHS ICS-CERT practices and the CIO's process for assessing third-party providers. While it mentions third-party oversight, this is framed as an internal process rather than the central topic of vendor requirements. Contains two named third-party entities (DHS ICS-CERT and CONA), satisfying the threshold for Quantified-Verifiable.


reasoning: Paragraph focuses on reporting lines of CISO and CTO to the Board and Audit Committee, with management roles as primary grammatical subjects. Contains cybersecurity-specific titles (CISO, CTO), a named non-generic committee (Enterprise Risk Management Committee), and a specific numeric detail (six components).


reasoning: The paragraph focuses on the qualifications, tenure, and career history of specific cybersecurity personnel (CISO and SVP Global Security), applying the Person-vs-Function test to classify as Management Role. It meets Quantified-Verifiable specificity through multiple hard facts: a precise duration (31 years), a named corporate entity (Inmarsat), and specific government organizations (UK Ministry of Defence, Central Government).


reasoning: The paragraph provides a standalone materiality assessment regarding cybersecurity risks without describing any specific incident, which falls under Strategy Integration. It contains only standard forward-looking disclaimers and materiality language without any specific facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal process for managing cybersecurity risks through engagement with third-party consultants and service providers, including vendor selection criteria. It contains no named entities, specific dates, dollar amounts, or verifiable facts—only generic references to 'Management,' 'professional services and consulting firms,' and 'third-party service providers'—making it boilerplate language applicable to any company.


reasoning: Paragraph contains standalone materiality conclusions regarding cybersecurity risks without describing specific internal processes or incidents, fitting the Strategy Integration category. The language is standard boilerplate that could apply to any company, with no named entities, dates, or specific details.


reasoning: The paragraph focuses on specific cybersecurity management roles (Director of Enterprise Information Security and Information Security Officer), their reporting structures, and specific qualifications including 30 and 22 years of experience respectively. The inclusion of two specific numerical values (30 and 22 years) provides the hard verifiable facts required for Quantified-Verifiable classification.


reasoning: The paragraph provides a generic description of cybersecurity threats (hackers, nation-state actors, social engineering) and potential impacts without disclosing specific board governance, management roles, internal risk processes, third-party oversight programs, actual incidents, or strategic financial assessments (materiality/insurance). It contains no company-specific details, named frameworks, or quantifiable facts.


reasoning: The paragraph describes the company's internal governance processes and oversight structures (establishment of specific committees, reporting cadences, and review protocols) rather than focusing on board oversight as the grammatical subject or individual management qualifications. It passes the person-vs-function test: removing the CISO/CEO titles still leaves a coherent description of the governance function. It contains firm-specific elements including named committees (Information Security Council, Executive Information Security Committee) and the cybersecurity-specific role (CISO), but lacks two hard verifiable facts (dates, dollar amounts, named vendors) needed for Quantified-Verifiable.


category_confidence: medium

reasoning: The paragraph identifies data breaches as a cybersecurity risk and describes potential business impacts (reputational harm, legal liabilities), which falls under risk identification/assessment within Risk Management Process. However, it contains no specific details about the company's actual systems, data types, historical incidents, or unique risk profile, making it generic boilerplate applicable to any entity.


reasoning: Paragraph primarily describes internal cybersecurity processes including the IS Program's objectives, the Information Security Incident Response Team's responsibilities, and detailed incident response protocols. While the Board and CISO are mentioned, they frame the description of program activities rather than constituting the main focus of governance oversight or individual management qualifications.


reasoning: This is a blank check company (SPAC) explicitly stating it has no operations and no cybersecurity personnel or processes of its own. Per the classification rules, SPACs explicitly stating they have no operations or formal cybersecurity processes must be classified as None/Other regardless of incidental mentions of board oversight or third-party risks.


reasoning: The paragraph identifies specific management roles (CTO, Senior VP of IT & Security) and details their qualifications, tenure, and years of experience, making it about the persons rather than just processes. Multiple specific year counts (17, 10, 19) and cybersecurity-specific titles provide two or more hard verifiable facts, meeting the Quantified-Verifiable threshold.


reasoning: The paragraph identifies specific cybersecurity leadership roles (CSO and CISO) and details their personal qualifications, educational backgrounds, and career histories, including specific durations of experience ('over 25 years', 'nearly eight years'). Under the person-vs-function test, removing the titles and credentials would eliminate the substance of the disclosure, confirming this is about the persons holding management roles rather than the processes they perform.


reasoning: The paragraph describes standard Board and Audit Committee oversight responsibilities for cybersecurity risk management using generic language applicable to any public company. The Audit Committee is explicitly listed as a standard/generic governance body in the instructions, and there are no specific details regarding briefing cadences, board expertise, or unique organizational structures.


reasoning: The paragraph identifies specific cybersecurity leadership roles (CISO and CIDO) with quantified experience levels and detailed reporting lines to the board and executive team, satisfying the Management Role criteria. It contains firm-specific details including the exact titles, specific tenure durations (15+ years), and the multi-functional composition of the governance team.


reasoning: The paragraph identifies specific individuals (Katherine Dowling and Hong Kim) by name, details their cybersecurity-specific titles (CTO), qualifications, career history, and reporting structure, making it clearly about management roles rather than processes.


reasoning: The paragraph describes an internal employee training process for cybersecurity management and incident response. It contains no named frameworks, specific dates (only the generic cadence 'annual'), named roles, or quantifiable details, making it generic boilerplate that could apply to any company.


reasoning: This paragraph is a pure cross-reference to the Risk Factors section containing no substantive disclosure about cybersecurity governance, processes, or incidents, fitting the definition of None/Other. As a standard cross-reference with no named entities, dates, or specific details, it qualifies as Generic Boilerplate.


reasoning: The paragraph discusses external state regulatory trends and states the Company monitors them, but provides no substantive disclosure about the Company's specific cybersecurity governance, management roles, internal processes, or strategy. It is generic forward-looking context about the regulatory environment that could apply to any regulated entity.


reasoning: The paragraph focuses on the Cybersecurity and Technology Oversight Committee (CyTOC) as the grammatical subject, describing its receipt of regular updates from management, participation in simulation exercises, and briefing of the full Board, which constitutes board-level oversight of cyber risk.


reasoning: Paragraph describes senior management's activities in identifying and assessing cybersecurity risks as part of internal risk evaluation processes. The disclosure lacks specific roles, frameworks, dates, or organizational details unique to the company, consisting entirely of generic risk assessment language.


reasoning: The paragraph focuses on materiality assessments regarding past and future cybersecurity incidents (noting 'minor adverse impacts' and lack of 'material losses'), forward-looking risk expectations, and cross-references to Risk Factors rather than describing specific incident details or vendor oversight processes. It contains no named entities, dates, frameworks, or specific details that would identify it as unique to Toyota Motor Credit Corp.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including incident response planning, business continuity management, and disaster recovery exercises. While it mentions reporting to the audit committee, the grammatical focus is on the company's own processes and procedures rather than board oversight. The disclosure contains no firm-specific details—no dates, dollar amounts, named tools, specific roles (e.g., CISO), or unique program identifiers—and describes standard practices (annual testing, quarterly reporting) that could apply to any company.


reasoning: As a blank check company (SPAC), the entity explicitly states it has no operations and no personnel or processes of its own to address cybersecurity threats. Per the classification rules, SPACs explicitly stating they have no operations or formal processes are classified as None/Other regardless of incidental mentions of board oversight.


reasoning: The paragraph centers on the VP of Information Technology role, detailing their reporting lines to executive leadership and the Board, their incident coordination responsibilities, and specific qualifications (25 years of experience). This focuses on the identification and credentials of a cybersecurity management position rather than board governance processes or risk management activities. The specificity derives from naming the cyber-specific executive title and stating the exact duration of their professional experience.


reasoning: The paragraph identifies the specific management role (Vice President of Informatics) responsible for leading cybersecurity processes and describes their qualifications (20+ years experience) and departmental oversight scope. Under the person-vs-function test, the paragraph focuses on the individual's credentials and organizational responsibilities rather than describing the processes themselves.


reasoning: The paragraph identifies specific management teams (Information Security, Compliance, Legal, Internal Auditing) responsible for cybersecurity oversight and details their qualifications (average 20+ years experience), focusing on the people and their backgrounds rather than processes or board governance.


reasoning: The paragraph focuses on the audit committee's oversight activities, including receiving reports from Apollo's CISO and addressing cybersecurity topics, making the board committee the grammatical subject. It qualifies as Firm-Specific by naming the cybersecurity-specific role (CISO) and the specific service provider (Apollo).


reasoning: The paragraph describes board-level oversight activities, with the CyTOC (a specific board committee) and the Board as grammatical subjects receiving updates from management, participating in simulations, and briefing the full Board. While it mentions the CISO and ERM program, the focus is on governance structure and oversight cadence rather than management qualifications or internal risk processes.


reasoning: The paragraph describes the company's internal risk management governance structure and oversight processes through the Information Technology Steering Committee, including its oversight of security programs and risk mitigation efforts. While it identifies specific management roles (CIO, CTO, ISO), the focus is on the committee's functions and activities rather than the individuals' qualifications or reporting lines, making Risk Management Process the appropriate category. The disclosure includes firm-specific details such as the named committee and specific cybersecurity-related titles.


reasoning: Paragraph describes the Fund's internal process for identifying and overseeing cybersecurity risks associated with third-party service providers, relying on specific personnel and departmental expertise. The explicit listing of the cross-functional teams involved (risk management, legal, IT, compliance) constitutes a firm-specific organizational detail, distinguishing it from generic boilerplate.


reasoning: The paragraph focuses on identifying specific cybersecurity leadership roles (CTO, CSO, CIO), their qualifications, career histories, and reporting relationships. It passes the person-vs-function test as it centers on the individuals' backgrounds and organizational structure rather than describing internal processes or board oversight.


reasoning: The paragraph describes internal processes for cybersecurity risk management, including an internal working group, real-time monitoring procedures, and incident response protocols, rather than focusing on individual qualifications (Management Role) or board oversight (Board Governance). It mentions the CISO—a cybersecurity-specific title—which qualifies as a firm-specific fact per the guidelines, while COO and CCO are generic C-suite roles that do not contribute to specificity.


reasoning: The paragraph constitutes a standalone materiality conclusion stating that no cybersecurity threats materially affected the company during the fiscal year ended December 31, 2023, coupled with a forward-looking materiality assessment. The inclusion of the specific fiscal year-end date 'December 31, 2023' provides one firm-specific fact, distinguishing it from generic boilerplate.


reasoning: The paragraph's primary purpose is a materiality assessment stating that cybersecurity risks 'have not materially affected us,' which falls under Strategy Integration per the tiebreaker rules. It contains only generic language with no named frameworks, specific dates, dollar amounts, cybersecurity-specific roles, or other verifiable facts that would identify it as unique to this company.


reasoning: The paragraph focuses on the Risk Committee's oversight responsibilities and the specific management-level subcommittees (EROC, TSRC, ORC) that report to it, making the board committee the grammatical subject. It contains multiple firm-specific elements including named non-generic committees, specific committee acronyms, and the CISO role, but lacks quantifiable data points like dates, dollar amounts, or headcounts needed for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal risk assessment processes, including penetration testing and alignment with external frameworks. It names recognized standards (NIST CSF and PCI DSS) but lacks firm-specific details such as dates, named third-party firms, or unique program identifiers.


reasoning: The Board is the grammatical subject throughout, describing oversight, briefing cadence, and participation in exercises. No specific dates, named roles (e.g., CISO), named committees beyond the standard Board, or quantifiable details are provided; the disclosure consists of standard governance practices applicable to any company.


reasoning: The paragraph focuses on the qualifications, career history, and certifications of a specific management role (VP of IT), making it about the person rather than the function. It meets Quantified-Verifiable specificity by containing two or more independently verifiable hard facts: a specific duration (25 years), a specific number of previous employers (three public companies), and named professional certifications (CISM).


reasoning: The paragraph is primarily a materiality disclaimer stating that cybersecurity risks have not materially affected the company to date, despite generic references to past 'threats and breaches' without specific incident details (no dates, scope, or response actions). It concludes with a cross-reference to Risk Factors, fitting the Strategy Integration category for standalone materiality assessments.


reasoning: The paragraph describes the Board of Directors' and Audit Committee's oversight of cybersecurity risk, including the frequency of updates received from management. While CIO and CISO titles are mentioned, they appear in the context of describing the reporting structure to the board rather than as the primary subject of the disclosure.


reasoning: The paragraph provides generic contextual language about the importance of cybersecurity and the threat landscape (ransomware, denial-of-service) but contains no substantive disclosure regarding the company's specific governance structures, management roles, risk management processes, or incidents. It serves as introductory text that could apply to any company.


reasoning: The paragraph centers on the Caterpillar CIO as the grammatical subject, detailing her specific qualifications, career history, tenure, and appointment date rather than abstract processes. It meets the Quantified-Verifiable threshold with two hard facts: the specific appointment date (September 2020) and precise tenure duration (nearly twenty-five years).


reasoning: The paragraph describes the company's internal cybersecurity processes including risk assessments, security controls, incident response planning, and third-party risk management. It contains no named frameworks, specific cybersecurity roles (e.g., CISO), dates, dollar amounts, or named third-party firms/tools that would identify it as unique to this company—this language could apply to any organization.


reasoning: The paragraph describes Logitech's internal security capability and its two components (cybersecurity and product security), which constitutes a description of the company's risk management processes. However, it contains no specific details, dates, named roles, frameworks, or quantifiable information—only generic security objectives (confidentiality, integrity, availability) that could apply to any company.


reasoning: The paragraph focuses on the CISO's qualifications, career history, and reporting line to the EVP of Cloud + AI, as well as the establishment and composition of the Cybersecurity Governance Council (CGC). While Board oversight is mentioned briefly, the grammatical subjects are the CISO and CGC, making Management Role the appropriate category. The disclosure includes firm-specific details including named roles (CISO, Deputy CISOs), a unique internal council (CGC), and specific reporting structures, but lacks two hard verifiable facts (dates, dollar amounts, headcounts, or named third-party firms) required for Quantified-Verifiable.


reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity risks with specific reporting cadences (annual to the full Board, quarterly to the Audit Committee), fitting the Board Governance category. It includes the specific quantitative detail that the enterprise risk team reports on the 'top ten' enterprise risks, which distinguishes it from generic boilerplate.


reasoning: The paragraph describes the Sponsor's internal processes for identifying, assessing, and mitigating cybersecurity threats through a formal plan, which falls under Risk Management Process. It contains no specific dates, named frameworks (only vague 'industry standards'), specific roles, dollar amounts, or other identifying details that would distinguish this disclosure from any other entity's filing.


reasoning: The paragraph identifies specific cybersecurity leadership roles (CIO and CISO), details their qualifications, certifications, and collective experience, and names the Information Security Steering Committee that assists them, focusing on management structure and expertise rather than processes or board governance.


reasoning: The paragraph explains the SEC's regulatory purpose and intent behind Item 106(b) disclosure requirements rather than describing the company's own cybersecurity governance, risk management processes, or incidents. It contains no substantive disclosure about EAWD's specific cybersecurity program and functions as regulatory background material.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risk (supervising prevention/detection efforts, obtaining briefings, threat intelligence monitoring) but lacks any firm-specific details such as named frameworks, specific roles (e.g., CISO), dates, headcounts, or named third-party firms/tools. The language is sufficiently generic that it could apply to any company.


reasoning: This paragraph is forward-looking risk disclosure that explicitly states the company is unaware of any prior material cybersecurity incidents and describes hypothetical future impacts. It concludes with a cross-reference to Item 1A Risk Factors. It contains no substantive description of board governance, management roles, internal processes, actual incidents, or third-party oversight, fitting the definition of forward-looking disclaimers and cross-references.


reasoning: The paragraph contains a standalone materiality disclaimer stating that no cybersecurity incidents have materially affected the company, which per the instructions maps to Strategy Integration even when boilerplate. The language is entirely generic, containing no specific dates, dollar amounts, named roles, or other firm-specific facts that would distinguish it from any other company's filing.


reasoning: The paragraph identifies specific cybersecurity-related management positions (CISO, CTO, Chief Intellectual Property and Privacy Officer) and describes the ISO Committee's composition, emphasizing personnel qualifications (e.g., Chief Risk Officer's 25 years of experience) and specific operational roles rather than describing processes or board oversight.


reasoning: The paragraph describes the company's internal processes for monitoring cybersecurity incidents (prevention, detection, mitigation, remediation), which falls under Risk Management Process. It contains only generic references to 'Management' and unnamed 'service providers' without specific titles, dates, frameworks, or verifiable details that would identify this specific company.


reasoning: Paragraph describes the company's internal cybersecurity processes including training programs, vulnerability scanning, patching, and incident response planning. While most elements are generic security practices, the specific departmental composition of the cross-functional response team (listing IT, security, finance, risk management, investor relations, and legal) constitutes a firm-specific organizational detail.


reasoning: The paragraph describes internal systems and processes for overseeing third-party security risks and mentions cyber insurance, but lacks specific frameworks, named roles, dates, dollar amounts, or other verifiable facts unique to the company, rendering it generic boilerplate applicable to any entity.


reasoning: The paragraph describes the company's internal risk management processes, framework adoption (NIST, ISO), and integrated approach to cybersecurity threats, making it about the risk management function rather than board governance (despite the brief mention of Board oversight) or management roles. It names specific recognized standards but contains no firm-specific details such as dates, specific roles, team compositions, or certifications that would elevate it beyond Sector-Adapted.


reasoning: The paragraph describes the company's internal cybersecurity processes including employee training, policy implementation across standard domains (InfoSec, BCDR, Privacy), and third-party testing. It contains no named frameworks, specific roles, dates, tools, or quantifiable details—only generic descriptions of standard security practices applicable to any organization.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and its components (risk assessments, multi-year roadmap, incident response plan, third-party risk management process, etc.). It does not reference the board, specific management roles, actual incidents, or financial/materiality assessments. The disclosure contains no named frameworks, specific dates, dollar amounts, headcounts, named third-party firms, or cybersecurity-specific titles, consisting entirely of generic security practices that could apply to any company.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks, including a third-party risk management program, but uses entirely generic language without naming specific frameworks, roles, dates, tools, or organizational details that would identify ZeroStack Corp. specifically.


reasoning: The paragraph describes the company's internal cybersecurity processes and day-to-day activities performed by the information security team, including monitoring, threat assessment, third-party engagement, and escalation procedures to senior management. It contains no specific dates, dollar amounts, named frameworks (e.g., NIST, ISO), named third-party firms, named tools, or specific team compositions that would distinguish this disclosure from standard boilerplate language applicable to any company.


reasoning: The paragraph focuses entirely on vendor assessment, selection criteria, and contractual security controls imposed on third parties, making vendor oversight the central topic rather than internal processes. The disclosure lacks named frameworks, specific dates, dollar amounts, or firm-specific details, consisting only of general statements about 'high standards' and 'relevant privacy regulations' applicable to any company.


reasoning: The Audit Committee is the grammatical subject overseeing management's cybersecurity risk processes, and the CISO is specifically identified as presenting to the committee, providing one firm-specific fact.


reasoning: The paragraph describes internal IT support boundaries, control procedures, and disaster recovery planning between Hawaiian Electric and HEI. While it mentions third-party consultants and cloud software, these are components of the internal risk management process rather than the central topic of vendor oversight. All potential specific facts (e.g., 'general ledger application,' 'third party consultants,' 'annual' updates) consist of company self-references, unnamed entities, generic system types, or vague quantifiers that do not meet the threshold for Firm-Specific classification.


reasoning: Paragraph describes two actual cybersecurity incidents with specific dates (December 2021 and March 2024), operational impact details, and response actions. The presence of two specific dates satisfies the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal risk management processes (vulnerability testing, penetration testing, vendor utilization) with the company as the grammatical subject. It references a 'Risk Management Committee,' which qualifies as a named non-generic committee analogous to 'Risk Committee' under the IS list criteria, making the disclosure firm-specific.


reasoning: The paragraph focuses on board and committee oversight of cybersecurity risk, with the Technology and Cybersecurity Committee and Board of Directors as grammatical subjects overseeing management and receiving reports. It identifies specific cybersecurity leadership roles (CIO and CISO) and a non-standard board committee.


reasoning: The paragraph discusses AFG's recognition of cybersecurity threats and the importance of assessing and managing these risks, which aligns with Risk Management Process. However, it contains no specific details—no named frameworks, roles, dates, dollar amounts, or organizational specifics—and could apply to any company, making it Generic Boilerplate.


reasoning: The paragraph describes internal incident response protocols, materiality determination procedures, and disclosure policies (IR planning and ERM integration). It contains one specific hard fact—the 36-hour reporting requirement—which elevates it from generic boilerplate, but lacks a second verifiable fact (such as specific dates, dollar amounts, or named third parties) needed for Quantified-Verifiable.


reasoning: Paragraph focuses on the identification, qualifications (CISSP certification, 20 years experience), and hierarchical reporting lines of the VP Global Cybersecurity and the Cybersecurity Management Committee he chairs, satisfying the Person-vs-Function test for Management Role. Meets Quantified-Verifiable threshold with two hard facts: the named CISSP certification and the specific 20-year tenure claim.


reasoning: The paragraph describes internal cybersecurity training processes (awareness programs, phishing testing, new hire training) without naming specific frameworks, tools, dates, or organizational details. Mentions of 'management' and 'Board' oversight are generic and passive, serving as context for the process description rather than focusing on governance structure.


reasoning: The paragraph contains a negative materiality assessment ('have not experienced any material cybersecurity threats') and references cyber insurance coverage, which per the tiebreaker rules places it in Strategy Integration despite boilerplate language. It contains no specific dates, dollar amounts, named entities, or other verifiable facts—only generic forward-looking disclaimers and cross-references.


reasoning: The paragraph focuses on the CISO's personal qualifications (20+ years experience, certifications), specific title, and reporting lines (to the CDO), satisfying the Person-vs-Function test for Management Role. It contains the cybersecurity-specific title 'CISO' and a specific duration ('20 years'), meeting the Firm-Specific threshold, but lacks a second hard verifiable fact (such as named certifications, dates, or dollar amounts) required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal risk management process, specifically that the cybersecurity function is outsourced to external service providers and overseen by the Principal Financial Officer through defined reporting channels. It does not focus on the qualifications of the PFO (Management Role) or vendor oversight requirements (Third-Party Risk), but rather on the operational structure of the security program.


reasoning: The paragraph describes the company's internal risk management framework, incident response procedures, and reporting structures rather than focusing on a specific individual's qualifications. It identifies the CTO as a cybersecurity-specific role and claims ISO 27001:2013 certification, which exceeds merely naming the standard, making the disclosure firm-specific.


reasoning: Paragraph contains a standard materiality disclaimer stating no material cybersecurity incidents have been experienced, which falls under Strategy Integration per the tiebreaker rules. The language is boilerplate with no specific dates, roles, frameworks, or verifiable facts.


reasoning: The paragraph focuses on materiality conclusions regarding past incidents ('not aware... that have materially affected') and mentions cybersecurity insurance coverage without naming specific insurers, amounts, or incidents. Per the tiebreaker rules, materiality disclaimers without incident narrative detail map to Strategy Integration. The text contains no specific dates, dollar amounts, named frameworks, or identifiable roles, making it Generic Boilerplate.


reasoning: Paragraph describes the company's internal processes for providing cybersecurity support to Affiliates and conducting pre-investment diligence reviews of their security programs. No specific dates, named roles, frameworks, dollar amounts, or other verifiable facts are provided.


reasoning: The paragraph describes the company's internal cybersecurity processes including penetration testing, vulnerability management, employee training, and third-party oversight mechanisms. It fits Risk Management Process as it focuses on the company's own risk assessment and mitigation activities. However, it lacks any specific details—no named frameworks, specific dates, cybersecurity-specific titles (e.g., CISO), named tools, third-party firms, or quantifiable metrics—and describes generic practices (penetration testing, tabletop exercises) that could apply to any company, making it Generic Boilerplate.


reasoning: The paragraph exclusively addresses the company's approach to identifying cybersecurity risks from third parties (vendors, service providers), making vendor oversight the central topic rather than a component of general risk management. It contains no specific details, named entities, dates, or quantifiable information that would distinguish it from any other company's disclosure.


reasoning: The paragraph describes the operational cybersecurity processes, threat monitoring, and incident response procedures maintained by BNY Mellon as part of the company's risk management framework. It contains firm-specific facts including the named service provider (BNY Mellon), the cybersecurity-specific title of CISO, and the specific organizational unit (ISD).


reasoning: Paragraph identifies management responsibility for cybersecurity residing with unnamed third-party consultants (a third-party consultant and their Security Operations Center Manager) and describes their qualifications and oversight role. While it references cybersecurity-specific functions, it contains no named entities, dates, numbers, or specific frameworks that would distinguish this disclosure from any other company using outsourced security management.


reasoning: The paragraph provides a standalone materiality assessment stating that previous cybersecurity incidents and threats have not materially affected the company's business strategy, operations, or financial condition, without describing any specific incident narrative. It contains no specific dates, dollar amounts, named roles, frameworks, or organizational details unique to Celestica.


reasoning: The paragraph provides a standalone materiality conclusion stating that no cybersecurity threats have materially affected operations, without describing any specific incident. The content consists entirely of standard cross-references to Risk Factors and boilerplate materiality disclaimers that could appear in any company's filing, containing no named entities, specific dates, dollar amounts, or unique program details.


reasoning: The paragraph describes the Board and Audit Committee's oversight of cybersecurity risks and reporting cadence, with the board/committee as the grammatical subject. It contains only generic references to standard governance bodies (Board, Audit Committee, management) and vague cadences (quarterly, regular, ad hoc) without specific dates, named frameworks, or firm-specific details.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and its integration with enterprise risk management, including risk assessment processes. This fits the Risk Management Process category as it focuses on the company's own internal processes. The disclosure contains no specific dates, named roles, frameworks, team compositions, or quantifiable details that would distinguish it from any other company's filing, rendering it generic boilerplate.


reasoning: The paragraph describes internal processes including system monitoring and incident response procedures (runbook), not the CISO's personal qualifications or reporting structure. The mention of the CISO title qualifies as firm-specific under the cybersecurity-specific roles criterion, but no quantifiable details (dates, costs, headcounts) or named frameworks are present.


reasoning: The paragraph centers on the company's vendor management program, detailing security questionnaires, audits, vulnerability scans, and contractual obligations imposed on third-party providers, which falls squarely under Third-Party Risk. While it lists specific vendor types (CMOs, CROs) relevant to the therapeutics sector, the description contains no named frameworks, specific dates, dollar amounts, named third-party firms, or unique internal program identifiers, making it generic boilerplate applicable to any company with similar vendor oversight practices.


reasoning: Paragraph describes the company's internal cybersecurity processes and controls (risk assessments, incident response, vulnerability management, encryption, etc.) without referencing specific incidents, board oversight, or management roles. The language consists entirely of generic security measures and common practices applicable to any organization, with no named frameworks, specific dates, dollar amounts, unique program identifiers, or organizational details specific to Pulmonx Corp.


reasoning: The paragraph describes Ameren's internal enterprise risk management program for cybersecurity, including continuous risk assessment processes and the specific 'risk management steering committee' (a non-generic committee) that oversees these processes. While board oversight is mentioned, the focus is on the ERM program functionality and management framework rather than board activities or specific management roles.


reasoning: The paragraph narrates an actual cybersecurity incident, describing when it occurred (fourth quarter of fiscal 2025), the unauthorized activity detected, containment measures implemented, and specific operational impacts including disrupted order fulfillment and associated financial effects. It contains one specific temporal fact but lacks a second hard verifiable fact (such as dollar amounts, exact dates, or named third-party firms) required for Quantified-Verifiable classification.


reasoning: The paragraph describes the company's internal cybersecurity risk management framework, including threat assessment, countermeasures, employee training, and vulnerability assessments, which falls under Risk Management Process. It contains no specific dates, named roles (e.g., CISO), named third-party firms, dollar amounts, or recognized framework certifications, making it generic boilerplate applicable to any company.


reasoning: The paragraph provides a materiality assessment stating that no past cybersecurity incidents have materially affected the company's business or financial condition, which is a standalone materiality conclusion classified under Strategy Integration. The language is entirely boilerplate, containing no specific dates (only the relative reference 'as of the date of this Annual Report'), dollar amounts, named entities, or firm-specific details.


reasoning: The paragraph constitutes a standalone materiality assessment stating that no cybersecurity threats or incidents have materially affected the company, which per the guidelines maps to Strategy Integration. It contains no specific dates, dollar amounts, named roles, or other verifiable facts, making it generic boilerplate language applicable to any registrant.


reasoning: The paragraph focuses on a specific cybersecurity management role (CIO/CISO) as the grammatical subject and describes the incumbent's qualifications (25+ years experience) and responsibilities, triggering the Person-vs-Function test for Management Role. It contains firm-specific identifying details (the specific title and tenure length) but lacks a second hard verifiable fact (date, dollar amount, named firm, or tool) required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal risk assessment and mitigation processes, including evaluating safeguards, addressing gaps, and monitoring effectiveness. While specific management roles are identified, the focus is on the risk management activities themselves rather than the individuals' personal qualifications or organizational structure, satisfying the Person-vs-Function test for Risk Management Process. The disclosure includes specific job titles and years of experience, making it Firm-Specific.


reasoning: The paragraph describes internal risk assessment activities (penetration tests, security posture assessments) and use of consultants as part of the company's cybersecurity program, but contains no named frameworks, specific dates, identified third-party firms, or cybersecurity-specific roles. The language is generic and could apply to any company.


reasoning: The paragraph describes the company's ERM program structure, including the specific ERC committee overseeing risk identification and mitigation, day-to-day oversight by an Enterprise Risk Officer, and integration of cybersecurity into the ERM framework. While it mentions Ms. Murray's cyber training, the primary focus is on the internal risk management process rather than board governance as the main subject.


reasoning: The paragraph focuses on the Chief Information Officer's reporting lines to the Audit Committee and specific qualifications (20+ years experience), making it about the management role per the Person-vs-Function test. While board oversight is mentioned, the detailed discussion of the CIO's tenure and responsibilities makes Management Role the primary category. It is Firm-Specific because it identifies the cybersecurity-specific title 'Chief Information Officer' and provides a specific duration of experience, but lacks the two hard verifiable facts (dates, dollar amounts, headcounts, named third parties/tools) required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal risk assessment and cybersecurity program management processes, attributing responsibility to the management team. While the COO is mentioned, this is a generic C-suite title (not a cybersecurity-specific role like CISO/CTO/CIO), and the disclosure contains no named frameworks, specific dates, dollar amounts, headcounts, or named third-party firms.


reasoning: The paragraph centrally addresses vendor risk management, describing oversight of third-party service providers, requirements for SOC-1 reports from vendors, and access limitations based on vendor services. It identifies the specific cybersecurity-related title of Vice President of Information Technology as the role responsible for this oversight, which qualifies as a firm-specific fact.


reasoning: Paragraph describes the company's internal cybersecurity risk management processes and incident response plan. While senior management roles are identified as leaders, they are generic C-suite positions (CFO, General Counsel, VP Quality) rather than cybersecurity-specific titles, and the focus is on the processes rather than individual qualifications. No specific dates, frameworks, named tools, or quantifiable details are provided.


reasoning: The paragraph describes the company's risk assessment process considering cybersecurity risks from third-party vendors and service providers. Per the tiebreaker rules, internal processes mentioning vendors as one component fall under Risk Management Process rather than Third-Party Risk (which requires vendor oversight to be the central topic with specific contractual or monitoring mechanisms). The disclosure contains no named entities, specific dates, dollar amounts, or unique identifiers, making it generic boilerplate that could apply to any company.


reasoning: The paragraph describes the company's internal process for designing and assessing its cybersecurity program using ISO and NIST frameworks as guides to manage risks. It names recognized standards but lacks firm-specific details such as certification claims, specific organizational roles, or unique implementation features.


reasoning: Describes generic post-incident review processes including reassessment of program effectiveness and reporting to senior management and the Audit Committee. Contains no specific dates, named roles, unique program identifiers, or other firm-specific details.


reasoning: The paragraph describes the company's internal escalation protocols and incident response procedures for reporting cybersecurity incidents to the Board and Audit Committee. It focuses on management's process for determining timing and response actions, not an actual incident, specific personnel qualifications, or board oversight activities. No specific roles (e.g., CISO), dates, frameworks, or quantifiable details are provided.


reasoning: The paragraph describes the company's internal cybersecurity risk management activities (monitoring, threat intelligence analysis, scanning) rather than the personal qualifications or reporting structure of the Director. Per the person-vs-function test, removing the title leaves a coherent description of processes, confirming Risk Management Process. The specificity is Firm-Specific due to the cybersecurity-specific title 'Director of Information Technology,' but lacks a second hard verifiable fact (dates, dollars, named vendors) needed for Quantified-Verifiable.


reasoning: The paragraph identifies specific cybersecurity management roles (CIO and Director of Information Security and Compliance), provides quantified professional tenure (12 years experience, 7 years with Company), and describes the Security Council's advisory structure, making it primarily about management responsibilities and qualifications rather than just processes.


reasoning: This paragraph constitutes a standalone materiality assessment regarding potential future cybersecurity impacts rather than an incident disclosure, as it contains no narrative of what actually happened in past threats (no dates, scope, or response details). The language regarding 'material adverse effect on business strategy, results of operations, and financial condition' is standard boilerplate that could appear in any filing without modification.


reasoning: The paragraph describes internal technical safeguards and disaster recovery capabilities, which are components of the company's cybersecurity risk management process. However, it contains only generic descriptions of standard IT security practices (redundant facilities, data backups, fire suppression, disaster recovery plans) without naming specific frameworks, tools, dates, headcounts, or organizational details unique to SITE Centers Corp.


reasoning: The paragraph describes the company's internal incident response workflows, escalation procedures to management committees, and notification protocols for significant incidents. While it references specific cybersecurity leadership titles (CISO and Chief Enterprise Technology Officer), the focus is on the processes and activities performed rather than the individuals' qualifications or backgrounds.


reasoning: The paragraph describes the company's incident response processes and team structure rather than the CISO's personal qualifications or reporting lines, making it about function rather than the person. It contains firm-specific details including the cybersecurity-specific CISO title, named internal programs (IRT and IRP), and a specific cross-functional team composition that includes the company-specific 'ECDP' department alongside standard departments.


reasoning: The paragraph centers on a materiality assessment stating that cybersecurity incidents have not materially affected the company, coupled with forward-looking statements about strategic resource allocation ('make judgments about where and how to invest resources'). It does not describe specific incidents, governance structures, or management roles. It contains no specific dates, dollar amounts, named frameworks, or other verifiable facts unique to the company, consisting entirely of generic SEC disclosure language applicable to any registrant.


reasoning: The paragraph describes a specific historical cybersecurity incident, including the timeframe (three-month period ending September 30, 2022), operational impact (delays in sales transactions), data exfiltration scope (employee PII), and response actions (containment, notification, restoration, remediation measures), which meets the definition of Incident Disclosure. It contains one specific date, making it Firm-Specific rather than Generic Boilerplate, but lacks the second hard verifiable fact (e.g., dollar amount, named vendor, specific headcount) required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal risk management activities—specifically engaging external consultants to conduct audits, penetration testing, and threat assessments on its own systems—rather than oversight of vendor/supplier cybersecurity risks. It contains no named third-party firms, specific dates, quantifiable metrics, or unique program identifiers, making it generic language applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and controls (policies, tools, audits, training, etc.), fitting the Risk Management Process category. It contains no specific dates, named roles, named frameworks, dollar amounts, or other firm-specific details, consisting instead of a generic list of standard security measures applicable to any company.


reasoning: The paragraph describes internal audit activities concerning the company's information security program, which falls under risk management processes. It lacks specific dates, named frameworks, identified roles, named audit firms, or quantifiable details, making it generic boilerplate that could apply to any company.


reasoning: Paragraph focuses on the CSO's responsibilities, scope of authority over BHE and Subsidiary Registrants, and expertise evaluation by the Executive Committee, making the cybersecurity-specific management role the primary subject. The mention of expertise evaluation qualifies it as Management Role rather than Risk Management Process.


reasoning: The paragraph describes internal risk assessment processes and security controls but contains no named frameworks, specific dates, quantified metrics, or unique organizational details that would identify this particular company. Language such as 'periodic risk assessments' and 'preventative and detective security controls' is standard industry boilerplate applicable to any entity.


reasoning: The paragraph describes the company's internal cybersecurity processes including risk assessments, controls implementation, and third-party engagement, but lacks any specific details, named entities, dates, or quantifiable information that would distinguish it from standard boilerplate language applicable to any company.


reasoning: The paragraph discusses the company's implementation of security procedures and controls to mitigate threats and acknowledges the persistent threat environment, which falls under general risk management process disclosure. However, it contains no specific frameworks, named roles, dates, or verifiable facts—only generic references to 'security procedures,' 'Internet banking,' and 'third-party service providers' that could apply to any financial institution.


reasoning: Paragraph describes the company's internal cybersecurity processes including end-user training, layered defenses, monitoring, penetration testing, and simulations. While it mentions engaging third-party experts, these are unnamed consultants assisting with internal testing rather than vendor oversight. The disclosure contains no named frameworks, specific dates, dollar amounts, identifiable roles, or unique organizational details that would distinguish it from any other company's filing.


reasoning: Paragraph identifies specific management positions (Senior Director, HR & Infrastructure; CFO; General Counsel) with primary cybersecurity responsibility, describes their reporting lines to the audit committee and board, and details the composition of the Rapid Response Team. The focus is on organizational accountability and structure rather than process mechanics or board oversight itself.


reasoning: The paragraph describes the company's internal process for cybersecurity training and policy communication. It contains no named entities (only unnamed 'information technology partner'), specific dates, quantified metrics, or recognized frameworks, making it generic language applicable to any company.


reasoning: The paragraph identifies the Chief Security Officer as responsible for information security strategy and details the qualifications, experience, and specific industry certifications (CISSP, CISA, CISM, CEH, CompTIA series) held by both the CSO and Information Security team members. While the Enterprise Risk Management Committee is mentioned as providing board oversight, the substantive content focuses on management role identification and credentials.


reasoning: The company explicitly states it is a SPAC with no business operations and has not adopted any cybersecurity risk management program or formal processes. Per the instructions, SPACs explicitly stating they have no operations or formal processes are classified as None/Other regardless of incidental mentions of board oversight. The absence of a program is not a description of a program.


reasoning: The paragraph focuses exclusively on oversight of third-party service providers, including vendor codes of conduct, questionnaires, and contractual security terms, making it a Third-Party Risk disclosure. It contains no specific dates, named entities, frameworks, or quantifiable details that would distinguish it from standard vendor risk management language applicable to any company.


reasoning: The paragraph describes the company's internal processes for evaluating third-party risks and performing assessments of service providers, which constitutes risk management activities. It contains no specific frameworks, named roles, dates, dollar amounts, or other identifying details that would distinguish it from any other company's disclosure.


reasoning: The paragraph focuses on the qualifications, credentials, and career history of specific cybersecurity management roles (CTO and VPCS), including specific years of experience, educational backgrounds from named institutions, and multiple industry-recognized certifications (CISSP, CISM, CISA), which constitute hard verifiable facts per the calibration examples.


reasoning: The paragraph describes the company's internal incident response protocols, team structure, and testing procedures (table-top exercises). It identifies specific cybersecurity leadership roles (SDIS and DPO) that lead the response team, which qualifies as firm-specific content under the cybersecurity-specific titles criterion.


reasoning: The paragraph describes a specific cybersecurity incident (the CrowdStrike-caused outage on July 19, 2024), including the date of occurrence, the named third-party involved, and specific restoration timelines, which constitutes an incident narrative with multiple independently verifiable hard facts.


reasoning: The paragraph describes the company's internal cybersecurity processes and tool categories (SIEM, PAM, endpoint security, SOC monitoring) but does not name specific products, vendors, dates, headcounts, or dollar amounts. The reference to a 'third party' SOC lacks a named provider, and technology references are generic categories rather than specific implementations.


reasoning: This paragraph provides a general business description of the company's stage (pre-clinical) and therapeutic focus (pain indications and CNS disorders), containing no substantive cybersecurity governance, risk management, or incident disclosure content.


reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity risks, including briefing cadences and incident reporting protocols. While specific IT security roles (SRC Director and CIO) are mentioned, they appear as objects of the Board's oversight activities rather than as the grammatical subject, making Board Governance the appropriate category.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, risk assessments, controls, and threat intelligence activities. While CISO, CTO, and CIO titles appear, they are described in terms of functional responsibilities (overseeing, implementing, enforcing) rather than personal qualifications, credentials, or reporting lines, satisfying the person-vs-function test for Risk Management Process. The identification of these cybersecurity-specific leadership roles provides firm-specific detail.


reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities for cybersecurity risk, with the committee as the grammatical subject throughout, including discussions of briefing cadences and board expertise. It references the specific role of the CIO and identifies the 'internal accounting and security teams' as distinct entities involved in discussions, providing firm-specific detail beyond generic boilerplate.


reasoning: Paragraph describes the company's internal risk management processes, including the Information Technology Steering Committee's oversight of security programs, quarterly meeting cadence, and governance responsibilities. While specific cybersecurity titles (CIO, CTO, Information Security Officer) are identified, the focus is on the committee's functional activities and risk oversight rather than individual qualifications or board governance.


reasoning: The paragraph provides a negative materiality disclosure stating no material cybersecurity incidents have occurred to date and includes forward-looking materiality language regarding potential impacts on business strategy and financial condition, which falls under Strategy Integration per the materiality disclaimer classification rule. It contains no specific dates, dollar amounts, named roles, frameworks, or other verifiable facts, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity training infrastructure and integration process for acquisitions, which falls under Risk Management Process. However, it uses only generic terminology ('Learning Management System' or 'LMS' without naming a specific product) and lacks dates, quantifiable metrics, named tools, or unique program identifiers, making it applicable to any company with similar training structures.


reasoning: The paragraph's grammatical subject is the Audit Committee, describing its oversight role in receiving reports on cybersecurity threats and risk mitigation. This describes board committee oversight and briefing cadence, fitting the Board Governance category.


reasoning: The paragraph describes the company's internal incident response plan, governance structure, and processes for assessing and managing cybersecurity risks. While it mentions supply chain and subcontractors, this is incidental to the broader description of internal risk management processes rather than being centrally focused on vendor oversight. The disclosure contains no specific dates, named roles (e.g., CISO), named frameworks (e.g., NIST), named third-party firms, or quantifiable details—only generic language that could apply to any company.


reasoning: This paragraph is a pure cross-reference to Item 1A Risk Factors and contains no substantive disclosure about the company's cybersecurity governance, management, processes, or incidents. It merely directs readers to other sections for risk disclosures without providing any specific cybersecurity program details.


reasoning: The paragraph provides a standalone materiality conclusion stating no cybersecurity incidents materially affected the company during the specified fiscal year, which falls under Strategy Integration per the tiebreaker rules. It contains one specific date (year ended December 31, 2023), making it Firm-Specific rather than Generic Boilerplate, but lacks a second hard verifiable fact required for Quantified-Verifiable.


reasoning: The paragraph describes Ansys's internal Third-Party Risk Management Program and details its specific five-stage evaluation process (planning, due diligence, contracting/onboarding, ongoing monitoring, and termination/off-boarding), which constitutes a description of the company's own internal risk management processes rather than focusing on board oversight or specific contractual requirements imposed on vendors.


reasoning: The paragraph provides a detailed narrative of the MOVEit Cybersecurity Incident, including the specific disclosure date (February 29, 2024), scope of affected individuals (2.5-2.7 million), data types compromised (social security numbers), and third-party involvement (PBI). While materiality conclusions are included at the end, the descriptive incident details constitute the primary substance of the disclosure.


reasoning: The paragraph describes the company's internal incident response procedures, including threat assessment and escalation protocols, which falls under Risk Management Process. It references only generic executive titles (CEO, CFO, CLO, CRO, EVP/Operations) and standard incident response activities without firm-specific details, dates, or quantifiable metrics, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal incident response preparedness processes, including a specifically named internal program (TT&E) and its alignment with a specific NIST publication. It focuses on the company's own risk management activities (training, testing, exercises) rather than board oversight, management roles, or actual incidents.


reasoning: The paragraph focuses on the Board of Directors' responsibility for cybersecurity risk oversight and its administration through the Audit Committee, making Board Governance the appropriate category. It contains no specific facts such as named cybersecurity roles (e.g., CISO), dates, frameworks, or third-party firms—only generic references to the Board, Audit Committee, and executive officers that could apply to any company.


reasoning: The paragraph explicitly states the company was a SPAC with no business operations and has not adopted any cybersecurity risk management program or formal processes. Per the classification rules, SPACs explicitly stating they have no operations or no formal processes are classified as None/Other, and such paragraphs always receive Generic Boilerplate specificity regardless of dates mentioned.


reasoning: The paragraph discusses the company's general approach to identifying, assessing, and managing cybersecurity risks, which aligns with the Risk Management Process category. However, it contains no specific frameworks, named roles, dates, or quantifiable details—only generic risk categories (operational risks, IP theft, fraud) that could appear in any company's filing.


reasoning: The paragraph presents a list of oversight areas (items 'g' and 'h') regarding personnel qualifications and cybersecurity strategy/resource allocation, which in Item 1C context typically describes the scope of Board or committee oversight responsibilities. The content contains no specific facts—no named roles (e.g., CISO), committees, dates, dollar amounts, or frameworks—and could apply to any company.


reasoning: The paragraph describes a specific cybersecurity incident occurring on June 28, 2023, detailing the nature of the attack (ransomware, encryption, malware deployment), response actions (implementation of manual processes, no ransom payments), and operational impact. While it contains one hard verifiable fact (the specific date), it lacks a second countable element (dollar amount, headcount, percentage, or named third-party firm/product) required for Quantified-Verifiable status.


reasoning: Constellation Acquisition Corp I is a SPAC explicitly stating it has not adopted any cybersecurity risk management program or formal processes. Per the classification rules, SPACs explicitly stating the absence of a program default to None/Other regardless of incidental mentions of board oversight or materiality assessments.


reasoning: The paragraph primarily describes the company's adoption of recognized security frameworks (NIST, ISO) and integration of cybersecurity into enterprise risk management and incident response planning, which falls under Risk Management Process. It cites specific industry standards but contains no firm-specific details such as named roles, dates, or unique program identifiers, making it Sector-Adapted.


reasoning: The paragraph describes an actual data security incident from fiscal 2023 involving a third-party vendor, including the attack vector (zero-day vulnerability), scope (PHI and PII exposure), and specific response actions (engaging experts, notifying State Attorneys General). It contains multiple hard verifiable facts: the specific date (fiscal 2023), named third-party firm (Fortra, LLC), and named product (GoAnywhere MFTaaS).


reasoning: The paragraph focuses on the CISO as a specific management role, detailing reporting lines (to CIO, with updates to Audit Committee Chair and CFO) and specific qualifications including over 20 years of experience and three named professional certifications (CISSP, CISA, CRISC), which provide multiple verifiable hard facts.


reasoning: The paragraph focuses on the CISO's reporting structure and communication cadence (informing the Steering Body and elevating matters to the Audit Committee), making the CISO the grammatical subject. It references the specific internal 'Cybersecurity Executive Steering Body' (a non-generic committee name) and the cybersecurity-specific 'CISO' title, but lacks hard verifiable facts like dates, metrics, or third-party names required for Quantified-Verifiable.


reasoning: The paragraph describes internal risk management processes—regular meetings to review cybersecurity risks and the details of the company's global incident response plan—rather than focusing on the CIO's personal qualifications. The mention of the specific cybersecurity title 'CIO' provides one firm-specific fact, distinguishing it from generic boilerplate.


reasoning: The paragraph identifies specific cybersecurity leadership roles (CISO and CIO) as the grammatical subjects responsible for briefing the Board and Audit Committee, which fits the Management Role category covering identification and reporting lines. The specificity is Firm-Specific because it names cybersecurity-specific titles (CISO and CIO), which are distinct facts per the IS list, even though Audit Committee and Board references are generic.


reasoning: The paragraph describes the company's internal risk management governance structure and processes (reviewing risk surveys, reporting risks), not individual qualifications or board oversight. It is firm-specific due to the detailed, unique composition of the Risk Committee, including specific business units (American InterContinental University System, Colorado Technical University) and the CIO role.


reasoning: Although the paragraph opens with Board oversight, the CIO is the grammatical subject for the majority of the text, with emphasis on the role's specific qualifications (25 years experience), reporting lines (to CEO/CFO), and support team structure (Director of IT Security, vCISO), fitting the Management Role category.


reasoning: The paragraph focuses on the Audit Committee's oversight responsibility and the briefing cadence from management (CIO/CISO) to the committee, fitting the Board Governance definition. It identifies specific cybersecurity roles (CIO and CISO) that distinguish it from generic boilerplate.


reasoning: The paragraph provides a materiality assessment ('to date these incidents have not had a material impact') and discusses potential business/financial impacts of cyber disruptions, fitting Strategy Integration. It contains no specific dates, named entities, frameworks, or quantifiable details—only generic risk language that could apply to any company.


reasoning: The paragraph's grammatical subject is the 'Information Security committee' and describes its oversight activities (oversees the program, reviews threats, approves strategy), which falls under committee governance. It identifies specific cybersecurity leadership roles (CDIO, CISO) and a named non-generic committee, making the content firm-specific.


reasoning: The paragraph provides a standalone materiality conclusion stating that the Bank has not experienced any material incidents, and discusses SEC disclosure requirements for cybersecurity risk management and governance. It contains the specific regulatory effective date (December 18, 2023) and references a specific internal incident severity classification (S1-Critical/Material), which distinguishes it from generic boilerplate.


reasoning: The paragraph describes internal risk assessment and audit processes, focusing on what the company does (conducts assessments, reports to the Audit Committee) rather than board oversight as the primary subject or the VP's personal qualifications. It contains only generic governance elements (Audit Committee, VP of Internal Audit) and vague cadences ('periodically', 'quarterly') with no cybersecurity-specific titles, named frameworks, dates, dollar amounts, or other verifiable specifics.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents ('we have not experienced a cybersecurity incident that we deemed to be material') without describing any specific incident narrative, which falls under Strategy Integration per the tiebreaker rules. It contains no specific dates, dollar amounts, named entities, frameworks, or firm-specific details—only generic statements about IT reliance and boilerplate materiality language that could apply to any company.


reasoning: The paragraph provides a standard materiality disclaimer stating that cybersecurity risks have not materially affected the Bank's financial condition, which falls under Strategy Integration per the guidelines. It contains no specific dates, dollar amounts, named frameworks, or unique operational details, making it generic boilerplate language applicable to any entity.


reasoning: The paragraph describes the company's internal cybersecurity risk management approach, including integration into operations and use of recognized frameworks (ISO, NIST), rather than focusing on board oversight mechanics or management roles. While the Board is mentioned initially, the substantive content concerns the company's policies, standards, and cross-functional processes. It names specific standards (ISO, NIST) but lacks firm-specific details such as dates, headcounts, named roles, or certification claims, making it sector-adapted.


reasoning: The paragraph describes the company's process of integrating cybersecurity into enterprise risk management (ERM) to evaluate cyber risks alongside other risk types, which falls squarely under Risk Management Process. It contains no specific details, dates, named roles, departmental compositions, or frameworks that would identify it as unique to Zedge—this language could apply to any company.


reasoning: Paragraph describes the company's internal cybersecurity processes, including the policy framework, decentralized risk assessment by business units, and reporting lines to senior management. No specific roles (e.g., CISO), dates, numbers, named standards, or unique program identifiers are provided; the decentralized approach described could apply to any multi-unit organization.


reasoning: The paragraph describes the company's internal incident response planning, testing, and playbook procedures, which falls under Risk Management Process. However, it contains only generic descriptions ('incident response playbook', 'functional areas (e.g., legal)', 'regularly test') that could apply to any company without modification, and references standard governance entities (Board of Directors, senior management) that appear on the exclusion list.


reasoning: The paragraph describes internal incident response procedures and the coordination of cybersecurity initiatives. While it identifies the 'Senior Director - Information Security,' the description focuses on functional responsibilities (coordinating and directing initiatives) rather than personal qualifications or reporting lines, making Risk Management Process the appropriate category per the person-vs-function test. The Audit Committee mention is brief and passive, not the grammatical focus. The specific cybersecurity title provides the single firm-specific fact required for this specificity level.


reasoning: The paragraph describes the company's internal cybersecurity processes including threat intelligence monitoring, network surveillance, penetration testing, and vulnerability management. While the Information Security team is the grammatical subject, the content focuses on the team's operational activities and functions rather than individual qualifications or reporting structure, making it a process description rather than a management role profile.


reasoning: This paragraph constitutes a standalone materiality conclusion stating that no material cybersecurity incidents have occurred, which per SEC disclosure guidelines maps to Strategy Integration. It contains no named entities, dates, frameworks, or specific details—only generic forward-looking language that could appear in any company's filing.


reasoning: The paragraph describes the CISO's reporting lines to executive management and escalation procedures to the Compliance Committee and Board, fitting the Management Role category. It identifies the specific cybersecurity title (CISO) and a named board committee (Compliance Committee), meeting the Firm-Specific threshold.


reasoning: Paragraph identifies specific cybersecurity management roles (CISO and SVP IT) and their tenure ('over twenty years'), focusing on the people rather than just processes. The mention of incident response and materiality assessment is framed around these management roles' accountability. Contains cybersecurity-specific titles and a specific duration of experience, meeting Firm-Specific criteria, but only one hard verifiable fact (twenty years) prevents Quantified-Verifiable classification.


reasoning: The paragraph provides a detailed narrative of the MOVEit cybersecurity incident, including the specific date of disclosure (June 22, 2023), the named vendor (PBI), the specific system involved (MOVEit), the scope of impact (2.5-2.7 million records), and response actions taken. While it includes a materiality conclusion, the central content describes what happened in an actual incident, triggering the Incident Disclosure tiebreaker.


reasoning: The paragraph focuses on the CTO's qualifications, reporting relationship to the Risk Committee, and professional background, making it a Management Role disclosure. It contains firm-specific details including the cybersecurity-specific title, the non-generic Risk Committee name, specific years of experience, and named educational credentials.


reasoning: The paragraph describes the company's internal Cybersecurity Plan and processes for assessing and managing cyber risks, including protecting SCADA systems and complying with NERC CIP standards. It names a recognized industry standard (NERC CIP) and specific system types (SCADA) applicable to the utility sector, but contains no firm-specific details such as dates, headcounts, named roles, or unique program identifiers.


reasoning: Paragraph contains a materiality assessment stating no material cybersecurity events have been experienced and discusses potential future business/financial impacts, fitting Strategy Integration. Contains no specific facts, dates, roles, or frameworks, making it generic boilerplate.