content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: This paragraph is a biographical sketch of an executive with no reference to cybersecurity, board governance, risk management, incidents, or any related topics, making it non-cybersecurity content.

provider: xiaomi

stage: benchmark


content_category: Strategy Integration

reasoning: This paragraph provides a standalone materiality conclusion stating no material cybersecurity incidents, which aligns with Strategy Integration as it addresses business impact without describing any specific event.


reasoning: The paragraph is a standalone materiality conclusion stating no material cybersecurity threats or incidents, which aligns with Strategy Integration, and it contains no verifiable facts or named standards, making it generic boilerplate.


content_category: Risk Management Process

reasoning: The paragraph describes the company's internal cybersecurity processes and tools for threat identification and protection, fitting the Risk Management Process category. It lacks any named frameworks, specific details, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for integrating cybersecurity risks into enterprise risk management, with no specific details, frameworks, or verifiable facts, making it generic and applicable to any company.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks, such as annual risk assessments and implementation of controls, which aligns with Risk Management Process. It contains no specific dates, names, or verifiable facts, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and their integration into overall risk management, with no specific details or verifiable facts.


reasoning: The paragraph describes the company's internal cybersecurity training and tool usage, which are components of risk management processes, without referencing specific individuals, incidents, or verifiable details.


reasoning: The paragraph provides a materiality conclusion stating no past material effect from cybersecurity breaches and cross-references risk factors for future risks, which is characteristic of Strategy Integration with no specific details.


reasoning: This paragraph provides a materiality conclusion stating no cybersecurity incidents have materially impaired operations, which is a standalone assessment of business impact under Strategy Integration, and the cross-reference to risk factors does not change this classification.


reasoning: The paragraph provides a materiality conclusion about past and future cybersecurity incidents, which is characteristic of Strategy Integration, and contains no specific details, making it generic boilerplate.


reasoning: This paragraph provides a standalone materiality conclusion stating no material impact from cybersecurity threats, which aligns with Strategy Integration, and it contains no specific facts, making it Generic Boilerplate.


reasoning: This paragraph is a pure cross-reference to other sections of the filing with no substantive cybersecurity disclosure, fitting the None/Other category and Generic Boilerplate specificity.


reasoning: The paragraph is a standalone materiality conclusion stating that cybersecurity risks have not materially affected the company and are not likely to, which aligns with Strategy Integration, and it contains no verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's process of engaging third parties for cybersecurity risk assessment and control testing, which is a core internal risk management activity. It contains no specific dates, names, or quantifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity investments and activities to improve capabilities and support growth, which aligns with risk management processes, and it lacks any specific verifiable facts, making it generic boilerplate.


reasoning: The paragraph is a generic statement about the importance of cybersecurity with no specific details, processes, or disclosures, fitting 'None/Other' as it lacks substantive content and 'Generic Boilerplate' due to no verifiable facts or named standards.


content_category: Incident Disclosure

reasoning: The paragraph describes a specific cybersecurity incident involving a named third-party collection agency and provides a date, fitting the Incident Disclosure category, and contains two verifiable hard facts (date and named firm) for Quantified-Verifiable specificity.


content_category: Third-Party Risk

reasoning: The paragraph centers on the company's process for identifying and overseeing cybersecurity risks from third-party providers, which aligns with Third-Party Risk. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment process, which is a core component of risk management, but it contains no specific dates, names, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph directly addresses third-party risk management as the central topic, fitting the Third-Party Risk category. It contains no verifiable facts, named standards, or company-specific details, making it generic boilerplate.


reasoning: The paragraph describes a past ransomware incident with a specific date and response actions, fitting the Incident Disclosure category. The specific date (May 4, 2022) is a firm-specific fact, making it Firm-Specific.


reasoning: The paragraph is a standalone materiality conclusion stating no previous cybersecurity threats have materially affected the company, with no incident description, fitting Strategy Integration. It contains no verifiable facts or specific details, making it generic boilerplate.


reasoning: The paragraph is a standard materiality disclaimer stating no material impact from cybersecurity threats, followed by a cross-reference to risk factors, which aligns with Strategy Integration per tiebreakers. It contains no specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph is a standalone materiality conclusion stating no cybersecurity incidents have materially affected the company, with a cross-reference to risk factors, which aligns with Strategy Integration per the tiebreakers.


reasoning: This is a standalone materiality conclusion about cybersecurity incidents, which falls under Strategy Integration per the tiebreakers. It contains no verifiable facts or named entities, making it generic boilerplate.


reasoning: The paragraph explicitly discusses the company's processes for overseeing and managing risks associated with third-party vendors, which is the central topic, fitting the 'Third-Party Risk' category. It contains no specific dates, names, frameworks, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for integrating cybersecurity into enterprise risk management, with no specific details, dates, or verifiable facts.


reasoning: The paragraph describes a past cybersecurity incident with specific timing (July 2018), scope, and investigation outcomes, fitting the Incident Disclosure category. The specific date makes it Firm-Specific, as it is a verifiable fact unique to this company's disclosure.


reasoning: The paragraph describes a specific cybersecurity incident with dates, scope (429,252 customers), affected data, and response actions, clearly fitting the Incident Disclosure category.


content_category: Board Governance

reasoning: The paragraph describes board and audit committee oversight of cybersecurity risks, which is a standard governance disclosure with no specific dates, numbers, or named entities beyond generic references.


reasoning: The paragraph describes an actual cybersecurity incident with specific details on what happened, when it occurred, and response actions, which aligns with Incident Disclosure. It is Firm-Specific due to the verifiable date of the incident.


reasoning: The paragraph describes internal cybersecurity training and response exercises, which are core risk management activities. It contains no verifiable facts, named standards, or unique identifiers, using only common practices like phishing exercises and tabletop drills.


reasoning: The paragraph is a forward-looking disclaimer about general cybersecurity risks and potential material adverse effects, with no substantive disclosure about actual governance, processes, or incidents.


reasoning: The paragraph describes the company's internal processes for designing, implementing, and monitoring cybersecurity safeguards, which aligns with Risk Management Process, and contains no specific details, making it generic boilerplate.


reasoning: The paragraph is a generic statement about reliance on technology systems and data collection without any specific disclosure on cybersecurity governance, risk management processes, or incidents, making it non-substantive.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as assessments, audits, and training, with no focus on board governance, management roles, incidents, or strategy integration.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight responsibilities for cybersecurity risk, with specific management roles (CIDO and Senior Director, Global IT Security) involved in reporting, making it Firm-Specific.


reasoning: The paragraph focuses on the company's internal risk assessment and threat monitoring processes, with oversight from a specific management role, indicating it is about risk management functions rather than the person or other categories.


reasoning: The paragraph primarily addresses the materiality of cybersecurity incidents and ongoing risks, with a brief mention of past incidents and a cross-reference to risk factors, which aligns with Strategy Integration. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes such as security reviews, testing, and threat intelligence, which fits the Risk Management Process category. It contains no specific dates, names, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph centers on evaluating and mitigating cybersecurity risks from third-party service providers, with oversight by strategic risk management committees, making Third-Party Risk the appropriate category. The named committee is a firm-specific detail.


reasoning: The paragraph describes internal processes where FTI leverages its cybersecurity consulting team to advise internal stakeholders and enhance security posture, which aligns with risk management processes.


reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity risk and management's annual reporting, which is a standard board governance description with no specific dates, names, or verifiable details.


reasoning: The paragraph focuses on Tredegar's own Cybersecurity Program and its risk-based approach to managing vulnerabilities, including those from third-party service providers, which is central to internal risk management processes.


reasoning: The paragraph focuses on the Audit Committee's oversight of cybersecurity risk management, with the committee as the grammatical subject, fitting Board Governance. The mention of the CISO, a cybersecurity-specific title, provides a firm-specific detail.


specificity_confidence: medium

reasoning: The paragraph centers on the Board and Audit Committee's oversight responsibility for cybersecurity risks, with management roles mentioned in a supporting capacity. It includes a cybersecurity-specific title (CIO), which qualifies as a firm-specific fact.


reasoning: The paragraph describes a board committee receiving reports on cybersecurity risks and incidents, which is a core element of board oversight. It uses generic terms like 'the Committee' and 'regular reports' with no specific details, making it applicable to any company.


reasoning: The paragraph provides a materiality conclusion regarding cybersecurity incidents and references the Enterprise Risk Management program's risk recognition, focusing on business impact and risk integration without describing specific incidents or details.


reasoning: The paragraph focuses on management's role in steering the cybersecurity program and describes a multi-disciplinary approach using a 'three lines of defense' model for monitoring and responding to incidents, which centers on internal processes rather than individual roles or specific incidents.


reasoning: The paragraph focuses on internal cybersecurity processes like phishing simulations and employee training, which are core risk management activities, not specific to a person or board oversight.


reasoning: The paragraph describes an internal cybersecurity training process, which aligns with risk management activities. It contains no specific facts such as dates, names, or numbers, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes management's activities in monitoring cybersecurity risks and incidents, which is a process-oriented function rather than a focus on individual roles or qualifications.


reasoning: The paragraph describes the company's internal cybersecurity training and awareness processes, which aligns with risk management, and lacks any specific verifiable facts, names, or dates, making it generic boilerplate.


reasoning: The paragraph explicitly describes a material cybersecurity incident that occurred in 2017, including the theft of personal information, which is a direct disclosure of an actual event.


reasoning: The paragraph describes a specific cybersecurity incident with date, scope, and remediation actions, fitting Incident Disclosure. It contains a specific date (April 2022), which is a verifiable fact unique to this company, making it Firm-Specific.


reasoning: The paragraph describes an internal process of annual policy review by the Information Security team, which aligns with risk management activities, and lacks any specific details such as dates, names, or standards.


reasoning: The paragraph describes the Information Security Council's role in monitoring, deciding, and escalating cybersecurity risks, which is focused on internal risk management processes rather than board oversight or individual management roles.


reasoning: The paragraph centers on the Audit Committee's oversight role in cybersecurity, which is a board governance function, and contains only generic descriptions of risk management activities with no unique company-specific details.


reasoning: The paragraph is a general statement about cybersecurity threats and their potential impact without describing any specific governance, management roles, risk processes, incidents, or strategic elements, making it non-substantive and fitting 'None/Other'.


reasoning: The paragraph describes a past cybersecurity incident with a specific date, scope of disruption, and response actions, fitting the Incident Disclosure category. It contains one specific date (April 2022), which is a firm-specific fact, but lacks other verifiable details like named tools or amounts, so it is Firm-Specific.


reasoning: The paragraph focuses on the company's internal process of performing risk assessments using third-party experts and internal audit, which aligns with Risk Management Process. It contains no specific dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph is a general statement about the importance of IT systems and data handling, lacking any specific cybersecurity processes, governance, incidents, or strategies, and thus contains no substantive disclosure.


reasoning: The paragraph describes the Board's oversight activities, including receiving briefings from management and presentations from the CISO, with the Board and a committee as grammatical subjects, fitting Board Governance.


reasoning: The paragraph describes the company's internal cybersecurity controls and security awareness program, which are part of risk management processes. It includes a specific cybersecurity role (VP of Information Security), making it firm-specific.


reasoning: The paragraph describes the company's internal cybersecurity policies and controls, which are part of its risk management processes. It contains no specific verifiable facts, named standards, or unique details about the company.


reasoning: The paragraph describes the company's internal cybersecurity incident response processes, including escalation to specific management roles, which aligns with Risk Management Process. Specificity is Firm-Specific due to the mention of cybersecurity-specific titles like CISO.


reasoning: The paragraph describes a specific cybersecurity incident with verifiable details including dates, financial impact, and duration, fitting the Incident Disclosure category and containing multiple hard facts.


reasoning: The paragraph focuses on the Company's internal cybersecurity risk management processes and program, with oversight by specific management roles (CIO and CISO), making it Risk Management Process and Firm-Specific due to the named titles.


reasoning: The paragraph describes the company's internal processes for identifying and managing cybersecurity risks, such as risk assessments, training, and policy dissemination, which fits Risk Management Process. It contains no specific dates, named entities, or verifiable facts, relying on common practices that are generic and not firm-specific.


reasoning: The paragraph describes a specific cybersecurity incident with dates, scope, response actions, and quantified costs, fitting the Incident Disclosure category, and contains two hard verifiable facts (date and dollar amount) for Quantified-Verifiable specificity.


reasoning: The paragraph focuses on materiality disclaimers and potential financial impact of cybersecurity risks without describing any actual incident or specific company processes, which aligns with Strategy Integration.


reasoning: The paragraph focuses on the company's internal cybersecurity processes, including monitoring, incident response policy, and employee training, which aligns with Risk Management Process. It contains firm-specific details such as a cybersecurity-specific title and specific team composition.


reasoning: The paragraph describes oversight by the Board and Audit Committee, with the Board receiving annual reports and the Audit Committee receiving quarterly presentations on cybersecurity risks, but it uses generic governance terms and cadences without any specific verifiable facts.


reasoning: The paragraph describes the company's internal process of engaging external consultants as part of its information security program, which aligns with risk management processes. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph narrates a specific cybersecurity incident involving MOVEit in May 2023, detailing response actions and impact, which aligns with Incident Disclosure. It contains two verifiable hard facts—a specific date and a named product—meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes the process of reporting cybersecurity risks and integrating them into enterprise risk management through internal audits, which are internal processes, fitting the Risk Management Process category. The mention of the Chief Security and Trust Officer provides a firm-specific detail.


reasoning: The paragraph focuses on the company's internal processes for managing cybersecurity risks, such as conducting risk assessments and engaging external assessors, with no mention of board governance, management roles, or specific incidents. It contains no verifiable facts like named entities, dates, or standards, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity incident response process, including detection, analysis, and escalation procedures, which aligns with risk management processes. It contains no specific details such as dates, named frameworks, or unique identifiers, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes internal procedures and controls for cybersecurity incident disclosure and compliance programs, which are part of the company's risk management processes, with no specific verifiable facts provided.


reasoning: The paragraph provides a standalone materiality conclusion about the absence of material cybersecurity incidents, which aligns with Strategy Integration, and it contains no specific facts, frameworks, or unique details, making it generic boilerplate.


reasoning: The paragraph describes a cybersecurity incident with specific dates, impacts on operations and finances, and a materiality conclusion, fitting the Incident Disclosure category. It contains multiple verifiable dates (e.g., September 23, 2023, fiscal 2024 periods), meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes a specific cybersecurity incident (ransomware attack in 2021) and its operational impact, which fits the Incident Disclosure category. The specific date (2021) is a verifiable fact, making it Firm-Specific.


reasoning: The paragraph describes the company's internal cybersecurity monitoring and defense processes, such as threat intelligence analysis and vulnerability scanning, which aligns with Risk Management Process. It contains no specific dates, names, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph is a forward-looking disclaimer about cybersecurity risks and a cross-reference to Risk Factors, containing no substantive disclosure of governance, processes, or incidents.


content_category: Management Role

reasoning: The paragraph focuses on the CAO's responsibilities, experience, and qualifications, making it centered on a management role. It includes firm-specific details like tenure and titles, but lacks two hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph describes a specific cybersecurity incident with details on timing, nature (ransomware), and response actions, fitting the Incident Disclosure category. The specific date (May 2022) is a firm-specific fact, but no additional verifiable facts are present to reach Quantified-Verifiable.


reasoning: The paragraph describes the integration of cybersecurity risks into the enterprise risk management program and annual assessments, which are internal risk management processes without any specific details, named frameworks, or verifiable facts unique to the company.


reasoning: The paragraph's central topic is the oversight and management of third-party vendors through a dedicated risk management program, which aligns with the Third-Party Risk category. It contains no specific dates, named entities, frameworks, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes internal processes for evaluating cybersecurity effectiveness and management-level review activities, which aligns with Risk Management Process. The 'executive security council' is a named, non-generic committee indicating firm-specific detail.


reasoning: The paragraph focuses on the reporting of cybersecurity risks to the Audit Committee, a board committee, which is central to board governance oversight.


reasoning: The paragraph focuses on identifying the CISO and detailing their qualifications and experience, which is characteristic of management role disclosure.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, processes, and policies, with the NIST framework as a named standard, making it focused on risk management processes and sector-adapted in specificity.


reasoning: The paragraph details internal committees and processes for cybersecurity risk oversight, such as the ORMC and ERMC, which are specific to the company's risk management framework.


reasoning: The paragraph focuses on materiality assessments of cybersecurity incidents, stating that past incidents have not materially affected the business and providing disclaimers about future impacts, which is characteristic of Strategy Integration. It lacks any specific details such as dates, roles, or processes, rendering it Generic Boilerplate.


reasoning: The paragraph describes the company's internal risk management processes and cybersecurity improvements following an incident, but it contains no specific verifiable facts, named standards, or unique details, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on the Board of Directors and its named committees (RAC and TEC) providing oversight of cybersecurity risk management, which is central to Board Governance. It includes specific committee names and the CISO role, making it Firm-Specific.


reasoning: The paragraph centers on a materiality conclusion stating no material cybersecurity incidents have occurred and discusses potential business impacts, which aligns with Strategy Integration. It includes forward-looking disclaimers but lacks any incident narrative or firm-specific details.


reasoning: The paragraph describes internal cybersecurity processes, controls, and disaster recovery plans in general terms, with no specific verifiable facts, named entities, or references to actual incidents.


reasoning: The paragraph describes the ERC executive forum and specific management roles (CRO, CIO, interim CISO) involved in cybersecurity risk oversight, focusing on internal risk management processes rather than board governance or individual roles.


reasoning: The paragraph describes the company's internal risk management processes through the CSWAT team, which is a firm-specific structure with defined composition and functions, fitting the Risk Management Process category.


reasoning: The paragraph details a real cybersecurity incident with specific dates, impact on operations, and response actions, fitting the Incident Disclosure category. It contains multiple verifiable dates (December 30, 2022; January 6, 2023; February 10, 2023), meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's internal cybersecurity incident response process, including activation of the CIRT and notification procedures, which is a core risk management function. It contains firm-specific details such as the CISO role, CIRT, and BTTC committee.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including specific roles and team composition, which are firm-specific facts.


reasoning: The paragraph focuses on the company's internal risk management strategy and processes, such as assessments and reporting, which fits Risk Management Process. It contains no named entities, dates, or verifiable details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal risk management processes through a cross-functional Compliance Committee, including its activities and oversight mechanisms, rather than focusing on board governance or individual management roles.


reasoning: The paragraph describes the company's internal cybersecurity processes, including alignment with the NIST framework and various security controls, without focusing on specific incidents, governance, or management roles.


reasoning: The paragraph focuses on the board's oversight of cybersecurity through specific committees and engagement with the CISO, which aligns with Board Governance. It contains firm-specific details like the CISO role and named committees, making it Firm-Specific.


reasoning: The paragraph focuses on the Risk Committee's oversight responsibility and reporting structures involving named committees, which is core to board governance of cybersecurity.


reasoning: The paragraph describes the internal processes and team composition of the Global Privacy Office, which is part of the company's cybersecurity and privacy risk management activities.


reasoning: The paragraph focuses on the company's internal processes for identifying, assessing, and managing cybersecurity risks using the NIST framework, which aligns with Risk Management Process.


reasoning: The paragraph emphasizes board oversight by describing reports to the Board of Directors from specific management roles (ITSC and CIO), which is central to board governance of cybersecurity risk.


reasoning: The paragraph describes general cybersecurity processes like asset protection, monitoring, and vendor engagement for testing, with no specific details, incidents, or references to governance or roles.


reasoning: The paragraph focuses on the company's internal processes for cybersecurity oversight, including a named committee and designated roles, which aligns with Risk Management Process.


reasoning: The paragraph describes the company's internal process for handling cybersecurity threats and incidents, including communication, materiality assessment, and engagement of third parties, which aligns with risk management procedures. It references a specific internal committee (CIEC), making it firm-specific.


reasoning: The paragraph details a past cybersecurity incident with specific dates, scope of access to PII, response actions, and litigation outcomes, directly describing what happened.


reasoning: The paragraph focuses on the CISO and internal cybersecurity team's structure, qualifications, and responsibilities, which aligns with the Management Role category for identifying key personnel and their roles.


reasoning: The paragraph focuses on the company's internal incident response planning and team activities, which are core risk management processes. It includes specific cybersecurity roles (SDIS and DPO), indicating firm-specific details.


reasoning: The paragraph describes the company's internal processes for evaluating and managing cybersecurity risk as part of its enterprise risk framework, with details on board oversight and management responsibilities, fitting the Risk Management Process category. It includes specific facts like the CISO role and named non-generic committees, making it Firm-Specific.


reasoning: The paragraph describes the company's internal cybersecurity assessment processes, including vulnerability management and external evaluations, with specific named third-party organizations (DCMA and CMMC), making it Risk Management Process with verifiable facts.


reasoning: The paragraph focuses on the qualifications and experience of specific management roles (CISO and Director), which is characteristic of the Management Role category.


reasoning: The paragraph describes the Company's Incident Response Plan and its management, which is a core component of internal risk management processes, with no actual incident disclosed or primary focus on board oversight.


reasoning: The paragraph focuses on the company's internal processes for assessing and managing cybersecurity risks, such as controls, monitoring, and training, which aligns with Risk Management Process. It names the SOC 1, Type 2 standard, a recognized framework, but lacks any unique details about the company, making it Sector-Adapted.


reasoning: The paragraph details the reporting processes and review activities led by the CTO, such as quarterly meetings and specific report contents, which are internal risk management functions rather than focusing on personal credentials or board governance.


reasoning: The paragraph describes the company's internal cybersecurity processes, such as framework adoption and vulnerability testing, which aligns with Risk Management Process. It names the CIS framework, a recognized standard, but contains no unique firm-specific details like dates or amounts, making it Sector-Adapted.


reasoning: The paragraph centers on the Board of Directors' risk oversight and the Audit Committee's receipt of cybersecurity updates, with management reporting to them, fitting Board Governance. It includes cybersecurity-specific titles (CIO and CISO), which are firm-specific facts.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including threat monitoring, incident response, and reporting lines, with a specific cross-functional team composition that identifies unique roles involved.


reasoning: The paragraph focuses on identifying specific management roles (CDIO and VP) responsible for cybersecurity and their qualifications, which aligns with the Management Role category.


reasoning: The paragraph describes a specific cybersecurity incident involving MOVEit Transfer, including timing, scope, and response actions, which aligns with Incident Disclosure. It contains multiple hard verifiable facts such as the year 2023, the named firm Progress Software Corporation, and the named product MOVEit Transfer, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph centers on the company's oversight of third-party providers, including due diligence processes and contractual security requirements, which aligns with Third-Party Risk. It names recognized standards (SOC and ISO) but lacks unique firm-specific details, making it Sector-Adapted.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risk, with alignment to named frameworks like NIST CSF and CMMI, fitting the Risk Management Process category and Sector-Adapted specificity due to recognized standards without firm-unique details.


reasoning: The paragraph describes a specific cybersecurity incident with dates, scope, and response actions, fitting the Incident Disclosure category. The specific date (October 31, 2023) is a firm-specific fact, but no other verifiable facts are present.


reasoning: The paragraph describes the company's own internal risk management processes, including engaging third-party experts for cybersecurity assessments and exercises, which aligns with Risk Management Process.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as threat monitoring, incident response, and reporting procedures, with a specific team composition that identifies a unique aspect of this disclosure.


category_confidence: medium

reasoning: The paragraph describes general cybersecurity training, insurance, and vendor oversight procedures without any specific details, aligning with internal risk management processes.


reasoning: The paragraph describes internal processes for identifying, assessing, and mitigating cybersecurity risks through collaboration between legal, compliance, and IT teams, without focusing on individual qualifications or board oversight. No specific verifiable facts such as dates, amounts, or named entities are provided; all mentioned roles and teams are generic.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including specific roles, committees, and framework alignment, which aligns with Risk Management Process. It contains firm-specific facts such as named roles and committees but lacks quantifiable data, making it Firm-Specific.


reasoning: The paragraph centers on the Senior Director of Cybersecurity's qualifications and the security steering committee's composition, highlighting management roles and responsibilities in cybersecurity oversight.


reasoning: The paragraph centers on the management role, detailing the VP/CIO's qualifications, reporting line, and responsibilities, with board notification mentioned only briefly as a secondary point.


reasoning: The paragraph primarily describes the company's risk management program and how cybersecurity is integrated into it, with the CISO's role and reporting to a named committee as part of the process, making it Firm-Specific due to these specific internal details.


reasoning: The paragraph primarily provides a materiality assessment regarding cybersecurity incidents, stating they have not materially affected the business, which aligns with Strategy Integration. It contains no verifiable facts or named standards, making it Generic Boilerplate.


reasoning: The paragraph focuses on management roles like the CISO and CRO, detailing their qualifications, reporting lines, and oversight responsibilities, with board governance as a secondary element. It includes firm-specific facts such as cybersecurity-specific titles and named committees, but lacks quantified verifiable facts like dates or amounts.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight of cybersecurity risks and the establishment of a dedicated Cybersecurity Steering Committee with specific members, which is central to board governance.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including framework adoption and integration into enterprise risk management, which aligns with risk management processes rather than board oversight, management roles, or incident disclosure.


reasoning: This paragraph is a pure cross-reference to the Risk Factors section with no substantive cybersecurity disclosure, fitting the 'None/Other' category.


reasoning: The paragraph centers on the Audit Committee's oversight role in cybersecurity risks, with management roles mentioned as informants, making Board Governance the primary category.


reasoning: The paragraph focuses on the Audit Committee's oversight activities, including receiving quarterly reports and engaging with management on cybersecurity, which aligns with Board Governance. It contains firm-specific details by naming the CIO and CISO roles, making it Firm-Specific.


reasoning: The paragraph centers on the Board Risk Committee's primary responsibility for overseeing cybersecurity risk, supported by management reporting structures involving specific roles and committees.


reasoning: The paragraph emphasizes the Audit and Finance Committee's oversight responsibilities and regular updates from management, making Board Governance the primary category, and it is Firm-Specific due to the inclusion of cybersecurity-specific titles.


reasoning: The paragraph describes the company's cybersecurity risk management processes and incident response plan, with the CIO mentioned as leading the office, indicating a focus on function over person details.


reasoning: The paragraph describes the company's participation in an external group for benchmarking and general efforts to build privacy resilience, which aligns with risk management processes. It contains no specific dates, amounts, or verifiable facts, making it generic boilerplate applicable to many companies.


reasoning: This paragraph is a cross-reference to risk factors and contains no substantive disclosure about cybersecurity governance, processes, or incidents.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management program and the specific frameworks and certifications it uses, aligning with Risk Management Process. It is Firm-Specific because it includes named certification claims (ISO/IEC 27001:2013, ISO/IEC 27017:2015, SOC 2) that are unique to the company's program.


reasoning: The paragraph focuses on the company's internal processes for regulatory compliance and information security program design, referencing specific frameworks and laws, which aligns with Risk Management Process.


reasoning: The paragraph centers on the Chief Risk Officer's responsibilities and reporting line to the board, which is a management function, and contains no verifiable facts or named standards, making it generic.


reasoning: The paragraph describes the company's internal risk management processes, including security controls and the Information Security Program, without referencing specific incidents, management roles, or board oversight.


reasoning: The paragraph describes the company's internal process of engaging third-party providers to supplement incident response capabilities, which aligns with risk management processes rather than vendor oversight or incident disclosure.


reasoning: The paragraph is primarily a forward-looking disclaimer and cross-reference to Risk Factors with no substantive disclosure about cybersecurity governance, processes, or specific incidents.


reasoning: The paragraph describes the company's own internal processes for identifying and assessing cybersecurity risks, including general monitoring and assessment activities, without focusing on board governance, management roles, incidents, or strategic impacts.


reasoning: The paragraph describes the company's own internal processes for assessing and managing cybersecurity risks, including threat detection, incident response, and testing, with the CISO role identified as a specific fact.


reasoning: The paragraph's central topic is the oversight of cybersecurity risks from third parties, including vendors and service providers, with emphasis on contractual terms and requirements imposed on them, which directly matches the Third-Party Risk category.


reasoning: The paragraph details specific management roles (Chief Legal Officer, Chief Technology Officer, Information Security Manager) and committees (Board Risk Committee, Management Risk Committee) responsible for cybersecurity risk, aligning with the Management Role category. It contains firm-specific facts like named roles and committees, but no hard verifiable facts like dates or amounts, so it is Firm-Specific.


reasoning: The paragraph describes the company's internal processes for monitoring and responding to cybersecurity incidents, with the InfoSec Leadership Team as the subject performing these functions, which aligns with Risk Management Process. The named team is a firm-specific entity, making the disclosure Firm-Specific.


reasoning: The paragraph describes generic incident response procedures (containment, solution implementation, recovery) without referencing a specific incident or unique company details, fitting internal risk management processes.


reasoning: The paragraph focuses on the CIO and SDIS roles, their reporting lines, qualifications, and experience, which aligns with Management Role. It contains multiple verifiable facts including years of experience and named certifications, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph centrally discusses vendor risk evaluation and management, fitting the 'Third-Party Risk' category. It contains no specific dates, names, or verifiable facts, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on the cybersecurity team's ongoing activities such as vulnerability scans, penetration tests, and risk management processes, which are internal risk management functions rather than board oversight or incident disclosure.


reasoning: The paragraph describes a specific cybersecurity incident with a date and response actions, which aligns with Incident Disclosure. The specific date makes it firm-specific, but it lacks additional verifiable facts for quantified-verifiable.


reasoning: The paragraph details internal cybersecurity processes including incident response, risk assessments, vendor management, and cross-functional collaboration, which are core components of risk management.


reasoning: The paragraph describes a cybersecurity incident involving ransomware and exfiltration of personal information, along with notification actions, but contains no specific dates, names, or quantifiable details, making it generic boilerplate.


reasoning: The paragraph is a standalone materiality conclusion stating that cybersecurity threats have not materially affected the company, which aligns with Strategy Integration, and it contains no verifiable facts, named standards, or company-specific details, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including incident response plans and system reviews, with no reference to specific incidents, roles, or frameworks, fitting 'Risk Management Process'. It contains no verifiable facts or named standards, making it generic boilerplate.


reasoning: The paragraph focuses on identifying specific management roles (CTO, VP, Senior Director) and their qualifications overseeing cybersecurity, with board oversight mentioned as a secondary element.


reasoning: The paragraph describes the Enterprise Security Director's role, qualifications, and reporting lines, with specific details like years of experience and certification, making it a management role with quantified-verifiable facts.


reasoning: The paragraph centers on the Board's oversight activities, including meetings with specific management roles (CISO and CIO) and a dated event, making it Board Governance with firm-specific details.


reasoning: The paragraph primarily provides a materiality conclusion about no material cybersecurity incidents, with a brief mention of a past non-material incident, which aligns with Strategy Integration per tiebreakers. It includes a specific date (2020), making it Firm-Specific rather than Generic Boilerplate.


reasoning: The paragraph describes the qualifications, experience, and credentials of the CISO and cybersecurity team, which aligns with Management Role, and contains multiple hard verifiable facts such as specific years of experience and named certifications.


reasoning: The paragraph describes internal governance, risk, and compliance processes in generic terms without naming specific frameworks, roles, dates, or other verifiable facts, fitting Risk Management Process with Generic Boilerplate specificity.


reasoning: The paragraph describes the company's internal continuous monitoring strategy and program, which is a core component of risk management processes. It contains no specific details such as dates, numbers, or named entities, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes management team members' roles, qualifications, and experience, which aligns with the Management Role category, and it contains multiple hard verifiable facts such as specific durations of experience and educational degrees.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including team responsibilities and mitigation measures, with the CIO as a specific management role leading the effort.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, including framework adoption and general practices, with no reference to board governance, management roles, incidents, or third-party risk. It names recognized industry frameworks (NIST, CIS, COBIT, ISO) but contains no unique company-specific details, making it Sector-Adapted.


reasoning: The paragraph describes the Board receiving annual briefings from senior management, including the CIO and CISO, and participating in cybersecurity strategy discussions, which centers on board oversight. The mention of specific cybersecurity roles (CIO and CISO) provides firm-specific details.


reasoning: The paragraph describes the company's internal processes for integrating cybersecurity risks into its enterprise risk management program with annual reviews presented to the Board, focusing on process rather than specific incidents or roles.


reasoning: The paragraph focuses on the board's role in overseeing cybersecurity risk management, with the board as the grammatical subject, fitting 'Board Governance'. It contains no verifiable facts, named standards, or company-specific details, making it generic boilerplate.


reasoning: The paragraph focuses on reporting and oversight activities to board committees (Audit Committee and QRC) by specific management roles, which is central to board governance of cybersecurity risk.


reasoning: The paragraph focuses on the management team's oversight and reporting activities in cybersecurity, with no specific names, dates, or verifiable details unique to the company.


reasoning: The paragraph includes a materiality disclaimer and mentions cybersecurity insurance, which are key elements of Strategy Integration, and it lacks any verifiable facts, named standards, or firm-specific details, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident that occurred on February 16, 2022, including detection and response actions, which aligns with the Incident Disclosure category. The presence of a specific date makes it Firm-Specific, but it lacks additional verifiable facts for Quantified-Verifiable.


reasoning: The paragraph focuses on management roles, reporting lines, and qualifications, with the CIO's experience and degree providing specific verifiable facts.


reasoning: The paragraph details the Director of IT's qualifications, credentials, and reporting line, which centers on the person in the management role rather than just the cybersecurity processes.


reasoning: The paragraph describes internal processes for managing cybersecurity risks through collaboration between the enterprise risk management team, CSO, and IT risk management team, which fits the Risk Management Process category as it focuses on functions rather than board oversight or incidents.


reasoning: The paragraph describes a specific cybersecurity incident detected in early April 2023 and details response actions, fitting the Incident Disclosure category; the specific date makes it Firm-Specific.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, such as control assessments and policy implementation, with no reference to board oversight, management roles, or actual incidents. It names specific frameworks (Cyber Risk Institute Cyber Profile and NIST), making it Firm-Specific but not Quantified-Verifiable due to the absence of hard verifiable facts like dates or amounts.


reasoning: This paragraph is a standalone materiality conclusion stating no material cybersecurity incidents have occurred and risks are not reasonably likely to be material, which aligns with Strategy Integration per the tiebreakers. It contains no verifiable facts, named entities, or specific details, making it Generic Boilerplate.


reasoning: The paragraph focuses on the ISO's responsibilities and reporting lines, which fits the Management Role category, and it contains firm-specific details like the ISO title and team composition.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as threat identification and mitigation measures, without focusing on board oversight, management roles, or incidents. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal incident response process, including a specific team composition, which aligns with Risk Management Process. The detailed departmental list is a firm-specific fact, making the disclosure Firm-Specific.


reasoning: The paragraph describes encryption methods as part of the company's internal data protection processes, which falls under risk management. It contains no specific facts, named entities, or standards, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity processes, including program implementation and incident response, led by management roles, which aligns with Risk Management Process. It includes a cybersecurity-specific title, making it Firm-Specific.


reasoning: The paragraph describes the management structure and reporting lines for cybersecurity, with specific roles like CISO and CIO, making it Firm-Specific and fitting the Management Role category.


reasoning: The paragraph details the company's adoption and scope of a Cybersecurity Incident Response Plan, which is an internal risk management process, not focused on a person, board, or actual incident.


reasoning: The paragraph centers on overseeing third-party vendors and maintaining cybersecurity insurance, but lacks any specific details such as named entities, dates, or frameworks, making it generic boilerplate.


reasoning: The paragraph centers on the Caterpillar CIO's background, tenure, and role, along with the team she leads, which are management-focused details rather than board oversight or risk processes.


reasoning: The paragraph focuses on a materiality conclusion ('have not materially affected us') and includes a cross-reference to risk factors, which aligns with Strategy Integration, while containing no specific dates, names, or verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph describes CSB's internal cybersecurity processes, such as layered defenses and monitoring tools, which fits 'Risk Management Process.' It lacks any specific dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph focuses on the company's internal processes for incident response and third-party risk management, with specific references to the CIRT and CONA, making it Risk Management Process and Firm-Specific.


reasoning: The paragraph focuses on the audit committee receiving quarterly cybersecurity reports, which is a standard board oversight activity with no firm-specific details or verifiable facts.


reasoning: The paragraph describes the company's internal process for reporting cybersecurity status and handling incidents, including escalation procedures and reporting lines, which aligns with Risk Management Process. It lacks any specific dates, names, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph is a general acknowledgment of cybersecurity risks and dependencies without any specific details on governance, processes, incidents, or strategy, fitting 'None/Other' for lack of substantive disclosure and 'Generic Boilerplate' due to no verifiable facts.


reasoning: The paragraph centers on the CISO's responsibilities, background, and reporting structure, making it focused on a management role rather than board oversight or internal processes.


reasoning: The paragraph identifies specific management roles (Acting CISO and Acting CIO) with their experience and reporting lines, focusing on personnel rather than processes or incidents.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and its integration into overall risk management, with only a brief, generic mention of Audit Committee oversight, making it a process-focused disclosure without specific details.


reasoning: The paragraph focuses on DFIN's internal cybersecurity risk management processes, such as employee training simulations and incident response exercises, with the specific year 2023 providing a firm-specific detail.


reasoning: The paragraph describes internal cybersecurity risk management activities, including CIO-led meetings and the incident response plan, which are processes rather than person-specific details or incident disclosures.


reasoning: The paragraph describes a specific cybersecurity incident with a date and scope of data exposure, fitting the Incident Disclosure category. It contains one verifiable fact (the date), making it Firm-Specific but not Quantified-Verifiable.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks, including integration into ERM, monitoring, and reporting to the audit committee, with no specific verifiable facts or unique identifiers.


reasoning: The paragraph focuses on the company's internal process for identifying and assessing cybersecurity risks using a third-party firm, with no board or incident references, and contains no verifiable specific facts.


reasoning: The paragraph focuses on the company's internal risk assessment processes, such as annual assessments and risk register updates, which are core elements of risk management, with no mention of board oversight, management roles, or specific incidents.


reasoning: The paragraph describes the company's internal cyber risk management processes, including integration into the ERM program and governance through specific committees like the IRM Steering Committee, with the CSO as a member.


reasoning: The paragraph describes the composition and function of the IT/Cybersecurity Committee, which is part of the company's internal risk management process for cybersecurity oversight, including specific roles and departmental involvement.


reasoning: The paragraph describes management's functional responsibilities in integrating cybersecurity into business processes and risk management, aligning with internal risk management processes rather than specific role identification. It contains no specific verifiable facts, dates, or named entities, making it generic boilerplate applicable to any company.


reasoning: The paragraph centers on the CSO's qualifications, reporting lines, tenure, and committee involvement, making Management Role the appropriate category. It contains multiple firm-specific facts such as named committees and specific durations of experience.


reasoning: The paragraph is a forward-looking risk disclaimer describing general cybersecurity threats without referencing any actual incidents, specific governance, management roles, or internal processes, fitting 'None/Other' with no verifiable facts.


reasoning: The paragraph is a standalone materiality conclusion with no incident description, which aligns with Strategy Integration per the tiebreakers, and it contains no specific facts, making it Generic Boilerplate.


reasoning: The paragraph centers on identifying the CISO, their qualifications (specific years of experience), reporting structure to the COO, and team expertise, which are core elements of management roles in cybersecurity governance.


reasoning: The paragraph details the company's internal cybersecurity risk management framework and incident response procedures, with the ISO 27001 certification serving as a firm-specific fact.


reasoning: The paragraph ends with a standalone materiality conclusion about cybersecurity incidents, which aligns with strategy integration, and it contains no specific facts, making it generic boilerplate.


reasoning: The paragraph focuses on the IT department's internal cybersecurity processes, including roles, controls, monitoring, and framework adoption, which fits Risk Management Process. It is Firm-Specific due to the mention of specific executive titles and named standards like NIST and PCI.


reasoning: The paragraph describes the qualifications, credentials, and tenure of the CISO and CIO, which aligns with Management Role, and contains firm-specific details such as named institutions, certifications, and a specific date.


reasoning: The paragraph centers on the CISO and CIO's individual responsibilities, qualifications, and experience, which aligns with Management Role content.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats and incidents, which aligns with Strategy Integration per tiebreakers. It contains no verifiable facts or named standards, making it generic boilerplate.


reasoning: The paragraph focuses on the executives' qualifications and experience in leading cybersecurity processes, which aligns with Management Role, and it includes firm-specific details like the named InfoSec Leadership Team and individual educational backgrounds.


reasoning: The paragraph describes the company's internal risk management processes, including assessment against the NIST framework and consideration of third-party providers' programs, with no incident, board, or management role focus.


reasoning: The paragraph describes management's role in monitoring and participating in cybersecurity risk management processes, including incident response and reporting, which aligns with Risk Management Process. It names the Information Technology Steering Committee, a specific non-generic committee, making it Firm-Specific.


reasoning: The paragraph details BD's internal cybersecurity policies, framework alignments, and specific certification achievements, which are central to the company's risk management processes.


reasoning: The paragraph describes management team supervising cybersecurity risk processes, which aligns with Risk Management Process, and contains no specific details such as dates, names, or frameworks, making it Generic Boilerplate.


reasoning: This is a forward-looking risk statement about potential operational disruptions from cybersecurity incidents, with no substantive disclosure about governance, processes, or actual incidents, making it None/Other and Generic Boilerplate.


reasoning: The paragraph focuses on the Risk Committee receiving reports from IT Management, which is a board governance activity involving oversight of cybersecurity. It names a non-generic committee, making it firm-specific, but lacks quantified or verifiable details like dates or amounts.


reasoning: The paragraph focuses on the company's internal processes for incident response, including testing and escalation protocols, which aligns with Risk Management Process. It lacks any specific details such as dates, names, or numbers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity policies and processes based on recognized frameworks, fitting Risk Management Process, and names specific standards like NIST and ISO, which makes it Sector-Adapted.


reasoning: The paragraph is a forward-looking risk disclosure about potential data breaches, which provides no substantive information on actual cybersecurity governance, processes, or incidents, fitting None/Other. It contains no specific facts, named entities, or verifiable details, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes, such as strategy implementation, employee training, and third-party engagements, without referencing specific roles, incidents, or financial impacts, fitting the Risk Management Process category.


reasoning: The paragraph centers on the qualifications, reporting lines, and experience of specific management roles (Information Security Director and CIO), fitting the Management Role category. It contains two hard verifiable facts (over 55 and over 31 combined years of experience), meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management program and processes, with the CTO and CISO mentioned as part of the oversight structure, aligning with Risk Management Process. It is Firm-Specific due to the inclusion of cybersecurity-specific roles (CTO and CISO).


reasoning: The paragraph's main point is a materiality disclaimer stating that cybersecurity risks have not materially affected the company, with only a vague reference to past incidents and a cross-reference to risk factors, fitting the Strategy Integration category. No specific, verifiable facts are present, making it generic boilerplate.


reasoning: The paragraph describes Honda's internal cybersecurity risk management processes, including designated divisions with a specific headcount and organizational structure, which are firm-specific details.


reasoning: The paragraph focuses on vendor oversight and cybersecurity risk management for third-party providers, which aligns with the Third-Party Risk category. It describes generic processes without any specific details, making it Generic Boilerplate.


reasoning: The paragraph focuses on the CISO's responsibilities, qualifications, and experience, fitting the Management Role category. It contains two hard verifiable facts (13 years tenure and over 20 years experience), meeting the Quantified-Verifiable threshold.


reasoning: The paragraph focuses on the board of directors' oversight and reporting of cybersecurity risk management, which aligns with Board Governance. It lacks any verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including risk assessment, security controls, incident response, and employee training, which aligns with Risk Management Process. It lacks any specific details such as dates, roles, frameworks, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for cybersecurity incident communication, escalation, and materiality assessment, which aligns with risk management. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph describes the cybersecurity team's role in regularly updating the Audit Committee, which focuses on management's reporting responsibilities, and contains no specific dates, names, or verifiable facts, making it generic.


reasoning: The paragraph focuses on the company's internal cybersecurity processes, including team responsibilities and framework adoption, with the CIO as a specific role indicating firm-specific detail.


reasoning: The paragraph describes the Audit Committee's oversight role in receiving reports on cybersecurity threats and risks, which is a board governance function, but contains no specific details such as dates, roles, or frameworks.


reasoning: The paragraph is a standalone materiality conclusion stating no material impact from cybersecurity threats, which aligns with Strategy Integration per tiebreakers, and it contains no specific facts, using only generic boilerplate language.


reasoning: The paragraph focuses on a materiality conclusion regarding past incidents and potential business impacts, which aligns with Strategy Integration. It contains no verifiable facts or company-specific details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal process of engaging with specific external entities for cybersecurity threat intelligence, which is a component of risk management.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as vulnerability management and third-party oversight, without any specific details, making it generic boilerplate.


reasoning: The paragraph focuses on the CISO's qualifications and experience, which is central to identifying management roles in cybersecurity governance.


reasoning: The paragraph describes the Board of Directors and Audit Committee overseeing cybersecurity risk management with generic oversight and cadence, fitting Board Governance. It lacks any named entities, specific dates, or unique details, making it generic boilerplate.


reasoning: The paragraph describes the company's own internal cybersecurity processes, including threat assessment, monitoring, and training, which aligns with Risk Management Process.


reasoning: The paragraph describes the company's general internal process for identifying and managing cybersecurity risks, with no specific details, verifiable facts, or named standards.


reasoning: The paragraph identifies the CDO and describes their responsibilities in overseeing cybersecurity activities, fitting the Management Role category for role identification and duties.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and managing cybersecurity risks, with no specific dates, amounts, named entities, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes the TRCC, a management committee, overseeing technology and cybersecurity risk management practices, including escalation and remediation processes, which aligns with internal risk management processes.


reasoning: The paragraph focuses on the company's internal processes for identifying, detecting, preventing, and remediating cybersecurity vulnerabilities, highlighting resource constraints, which fits 'Risk Management Process.' It contains no specific facts, frameworks, or unique details, making it generic boilerplate.


reasoning: The paragraph focuses on materiality conclusions about cybersecurity incidents and risks, including statements about no material breaches and immaterial expenses, which is characteristic of Strategy Integration. It lacks any specific dates, amounts, named entities, or frameworks, making it generic boilerplate that could apply to any company.


reasoning: The paragraph emphasizes the management roles of the CISO and CIDO, their qualifications, and reporting lines, with board oversight mentioned as part of the structure, making Management Role the most applicable category.


reasoning: The paragraph describes general state regulatory activity and the company's monitoring thereof, with no specific details about the company's cybersecurity program, governance, or incidents.


reasoning: The paragraph describes the qualifications and credentials of the IT Director and IS Director, which are management roles, fitting the Management Role category. It includes multiple hard verifiable facts such as a specific number of years of experience and named certifications, meeting the threshold for Quantified-Verifiable specificity.


reasoning: This paragraph presents a materiality conclusion about cybersecurity risks, which is a key element of Strategy Integration, and it lacks any specific details such as dates, names, or quantifiable facts, making it generic boilerplate.


reasoning: The paragraph provides a materiality assessment of cybersecurity threats, stating no material adverse effects to date and referencing risk factors, which aligns with Strategy Integration as it focuses on business impact without describing an incident or specific processes.


reasoning: The paragraph describes internal programs for incident response, business continuity, and disaster recovery, which are part of the company's risk management processes, with no specific details about incidents, board oversight, or management roles.


reasoning: The paragraph describes the internal working group and processes for cybersecurity threat management, with the specific CISO role indicating firm-specific details.


reasoning: The paragraph describes the company's internal cybersecurity program design and assessment processes based on named frameworks, fitting 'Risk Management Process', and names recognized standards without unique company details, making it Sector-Adapted.


reasoning: The paragraph centers on the management team's role and responsibilities in cybersecurity oversight, with a brief mention of Audit Committee oversight, fitting the Management Role category. It contains no specific dates, names, numbers, or standards, making it generic boilerplate applicable to many companies.


reasoning: The paragraph describes the company's internal risk assessment process involving a GRC team, which fits Risk Management Process, but it lacks any verifiable facts, named standards, or unique details, making it generic boilerplate.


reasoning: The paragraph centers on the management team's roles, responsibilities, and specific qualifications, with multiple verifiable years of experience that meet the Quantified-Verifiable threshold.


reasoning: The paragraph focuses on the qualifications, certifications, and experience of specific management roles (CISO, CIO, CRO, CEO, General Counsel), fitting the Management Role category. It contains multiple hard verifiable facts, including specific certification years and headcounts, meeting the Quantified-Verifiable threshold.


reasoning: The paragraph provides a materiality conclusion about cybersecurity incidents and discusses cyber insurance as part of risk strategy, which aligns with Strategy Integration; it contains no verifiable facts or named standards, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes, including testing, training, and third-party oversight, which aligns with Risk Management Process. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal risk management process that includes engaging third-parties for assessments and monitoring, but it lacks named firms, dates, or other verifiable details, making it generic boilerplate.


reasoning: The paragraph primarily provides a materiality assessment stating that cybersecurity risks have not materially affected the business as of a specific date, which is characteristic of Strategy Integration. The inclusion of the specific date 'December 31, 2023' makes it Firm-Specific.


reasoning: The paragraph describes coordinating incident response activities and procedures, which is a core internal risk management process. It contains no specific dates, names, or verifiable facts, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on the VP of IT's role, responsibilities, qualifications, and the management committee structure, which aligns with Management Role. It contains firm-specific facts such as the VP's tenure, experience, and committee composition, making it Firm-Specific.


reasoning: The paragraph focuses on the company's internal cybersecurity processes, such as strategy implementation, employee training, and policy areas, which fits Risk Management Process. It contains no specific dates, names, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on the company's internal processes for cybersecurity risk oversight, including a named committee, specific management roles with reporting lines, and experience details, aligning with Risk Management Process and containing firm-specific facts.


reasoning: The paragraph describes management's responsibilities in assessing and managing cybersecurity risks, which aligns with the risk management process function, and it contains no specific verifiable facts such as dates, names, or numbers.


reasoning: The paragraph centers on the audit committee's oversight of cyber risks, including receiving reports from Apollo's CSO/CISO, which fits Board Governance. The mention of Apollo as a named entity makes it Firm-Specific.


reasoning: The paragraph focuses on identifying the CISO, their qualifications (20 years of experience), and reporting lines to a named committee, which aligns with the Management Role category. It contains multiple firm-specific facts such as the CISO title, a non-generic committee name, and a specific number of years, making it Firm-Specific.


reasoning: The paragraph describes the company's engagement of third parties for cybersecurity activities like designing controls, penetration testing, and monitoring, which are part of its internal risk management processes, not vendor oversight or incident disclosure.


reasoning: The paragraph centers on vendor oversight and compliance requirements, with specific departmental collaboration (legal and procurement/sourcing) indicating firm-specific details.


reasoning: The paragraph focuses on the company's internal processes for assessing and managing cybersecurity risks, including tools, SOC activities, and incident response protocols, with the CISO identified as a specific role in the escalation chain.


reasoning: The paragraph centers on the Audit Committee's oversight responsibilities for information security, with the committee as the grammatical subject, aligning with Board Governance. It includes the specific title 'chief security officer,' making it Firm-Specific.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and managing cybersecurity threats using general methods and tools, which fits Risk Management Process. It lacks any named frameworks, specific details, or verifiable facts, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes management roles (CIO and General Counsel) meeting with the Board of Directors to review cybersecurity metrics and processes, which centers on board oversight of cyber risk.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including testing, monitoring, and assessments, with no focus on board oversight, specific roles, or incidents. It contains no verifiable facts such as dates, amounts, or named entities, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal risk management process for cybersecurity, focusing on roles, responsibilities, and remediation activities led by specific management titles and a named committee.


reasoning: The paragraph focuses on the audit committee receiving reports on cybersecurity, which is a board governance oversight activity. It contains no specific details such as dates, names, or frameworks, using only generic terms like 'audit committee' and 'regular reports'.


reasoning: The paragraph describes the integration of cybersecurity risk into enterprise risk management processes, focusing on internal procedures and generic management roles without any specific or verifiable details.


reasoning: The paragraph centers on the CISO's qualifications, tenure, and reporting line, which directly identifies a management role. It contains firm-specific details such as the cybersecurity-specific title 'CISO' and specific certifications.


reasoning: The paragraph describes the company's internal cyber risk management process, with specific roles identified for oversight and collaboration, fitting Risk Management Process and firm-specific due to named positions.


reasoning: The paragraph centers on the Vice President, Head of Technology, detailing their qualifications and role in leading cybersecurity processes, fitting the Management Role category. It contains two hard verifiable facts: a specific duration of experience and a named certification, meeting the Quantified-Verifiable threshold.


reasoning: The paragraph identifies specific management roles (CIO and CISO) with detailed qualifications, including experience durations and certifications, making it focused on personnel rather than processes.


reasoning: The paragraph centers on the roles, qualifications, and backgrounds of specific individuals (Katherine Dowling and Hong Kim) responsible for cybersecurity oversight, fitting Management Role. It contains multiple hard verifiable facts such as specific dates, named institutions, and companies, meeting the Quantified-Verifiable threshold.


reasoning: The paragraph details the company's internal cybersecurity risk management processes across multiple areas, such as governance, technical safeguards, and incident response, with the central focus on program functions rather than specific incidents or roles.


reasoning: The paragraph is a materiality disclaimer stating that cybersecurity risks have not materially affected the company and are not likely to do so, which aligns with Strategy Integration. It contains no specific facts, named entities, or verifiable details, making it Generic Boilerplate.


reasoning: The paragraph centers on vendor security assessments, which is the core of third-party risk management, but it lacks any specific details like named firms, dates, or metrics, making it generic boilerplate.


reasoning: The paragraph centers on the Chief Information Officer's reporting lines, qualifications, and oversight role, with board engagement as supporting context, fitting Management Role. It includes firm-specific facts such as the cybersecurity-specific title and quantified experience duration.


reasoning: The paragraph is a materiality disclaimer stating cybersecurity threats have not materially affected the company, with a cross-reference to risk factors, fitting Strategy Integration. It contains no specific details about incidents, processes, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including specific toolkits and assessments, which aligns with the Risk Management Process category. It names recognized industry frameworks (FFIEC and Bankers Electronic Crimes Task Force toolkits) but lacks unique firm-specific details, making it Sector-Adapted.


reasoning: The paragraph describes the Board's oversight function through specific committees and management roles reporting to them, making it Board Governance with firm-specific details.


reasoning: The paragraph focuses on the company's internal cybersecurity processes, including incident response testing and procedures, with a general mention of cyber insurance, which aligns with risk management activities rather than board oversight, management roles, or incident disclosure.


reasoning: The paragraph describes board-approved committees (ITAC, ERM, ITSC) overseeing cybersecurity governance, with specific management roles and an internal program (IRP), making it firm-specific and centered on board oversight.


reasoning: The paragraph describes general cybersecurity threats without referencing any specific incident, company process, board oversight, management role, or materiality assessment, making it non-substantive disclosure akin to boilerplate risk factor language.


reasoning: The paragraph provides a standalone materiality conclusion about cybersecurity risks with no incident narrative, and it includes a specific date, making it Firm-Specific.


reasoning: The paragraph focuses on the function of providing briefings on cybersecurity matters, which is a risk management activity, and the specific title 'SVP of IT' identifies a cybersecurity-related role unique to the company.


reasoning: The paragraph centers on the company's approach to identifying cybersecurity risks from third parties, making Third-Party Risk the appropriate category. It lacks any specific facts, named entities, or verifiable details, so it is generic boilerplate.


reasoning: The paragraph focuses on the company's oversight and management of cybersecurity risks from third-party service providers, which is the central topic, aligning with Third-Party Risk. It contains no specific dates, named entities, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes a specific cybersecurity incident with a date and named third-party firm, fitting Incident Disclosure, and contains two hard verifiable facts for Quantified-Verifiable specificity.


reasoning: The paragraph provides a materiality assessment stating no cybersecurity incidents have materially affected the company, which aligns with Strategy Integration per the tiebreakers. It contains no specific facts such as dates, names, or numbers, making it generic boilerplate.


reasoning: The paragraph focuses on the company's internal processes for cybersecurity incident planning, exercises, and reporting, with no reference to specific incidents, individuals, or verifiable details.


reasoning: The paragraph centers on the management team (CFO, VP of Finance, etc.) leading cybersecurity processes and their prior experience, aligning with the Management Role category. It contains no hard verifiable facts such as dates, amounts, or named entities, and the roles listed are generic C-suite positions, making it Generic Boilerplate.


reasoning: The paragraph provides a materiality conclusion about past cybersecurity incidents and discusses financial implications such as insurance coverage, which aligns with Strategy Integration, and it contains no verifiable facts or named standards, making it generic boilerplate.


reasoning: The paragraph focuses on the company's internal product cybersecurity risk assessment and management processes, including alignment with the ISO 21434 framework and a certification claim, which is a firm-specific fact.


reasoning: The paragraph primarily describes the qualifications, experience, and responsibilities of the CTO, CSO, and CIO, with a focus on their roles and backgrounds, making it centered on management roles in cybersecurity governance.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, including oversight by specific teams and their qualifications, which aligns with Risk Management Process rather than board or individual management roles.


reasoning: The paragraph details the specific management role (SVP, Head of Legal and Compliance) responsible for cybersecurity risk management and incident response, with reporting to the Audit Committee, making management role the central focus.


reasoning: The paragraph identifies the IT management team and specific C-suite executives (COO, CFO, General Counsel) as responsible for cybersecurity risk management, with board oversight, fitting the Management Role category for role identification.


reasoning: The paragraph describes senior management's role in identifying and assessing cybersecurity risks, which is a generic internal risk management process with no specific details or verifiable facts.


reasoning: The paragraph focuses on potential material effects of cybersecurity risks and cross-references risk factors, which aligns with Strategy Integration for materiality assessments. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph explicitly states the company is a blank check company with no operations and no cybersecurity program or processes of its own, which aligns with the None/Other category for SPACs with no substantive cybersecurity disclosure.


reasoning: The paragraph focuses on the potential material impact of cybersecurity threats and includes a materiality disclaimer, which aligns with Strategy Integration. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal process of conducting risk assessments and audits, which aligns with Risk Management Process. It contains no specific dates, frameworks, or unique details, making it generic boilerplate applicable to any company.


reasoning: This paragraph is solely a cross-reference to another section with no substantive cybersecurity content, aligning with the None/Other category for non-disclosure elements.


reasoning: The paragraph primarily presents a materiality conclusion stating that no cybersecurity threats have materially affected or are likely to affect the company, which is a core element of Strategy Integration. It contains no specific incidents, dates, or verifiable details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal safeguards and disaster recovery plans, which are core elements of risk management processes. It contains no specific verifiable facts, names, or dates, making it generic boilerplate.


reasoning: The paragraph describes the company's own cybersecurity risk mitigation processes, including alignment with specific frameworks and regulatory requirements, which fits Risk Management Process. It names recognized standards (NIST, C2M2) and a regulatory body (BPU), but lacks unique firm-specific details beyond sector adaptation.


reasoning: The paragraph describes the company's internal protocols for reporting cybersecurity incidents, which is a component of risk management processes, and contains no specific verifiable facts such as dates, names, or numbers.


reasoning: The paragraph primarily assesses the materiality of cybersecurity incidents and references risk factors, with no specific incident narrative, aligning with Strategy Integration. It contains no verifiable facts or named standards, making it generic boilerplate.


reasoning: The paragraph describes the company's internal information security processes for identifying and managing cybersecurity risks, with no mention of board governance, management roles, specific incidents, or third-party oversight as the central topic.


reasoning: The paragraph describes the company's internal incident response plan and team, which are part of risk management processes. It contains no specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the Board and Audit Committee's oversight of cybersecurity risk through periodic reports from management, which is a standard governance structure without unique details.


reasoning: The paragraph explicitly states that the company is a blank check company (SPAC) with no operations and no cybersecurity processes of its own, which falls under the None/Other category for non-substantive disclosures. It contains no specific facts, using only generic language about risks and reliance on third parties.


reasoning: The paragraph describes Logitech's internal security processes, such as cybersecurity and product security, which fits the 'Risk Management Process' category. It lacks any specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph centers on the management team's qualifications and oversight of cybersecurity, with specific roles and experience details, fitting Management Role. It contains firm-specific facts like a cybersecurity title and duration of experience, but not enough hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph centers on the Fund's oversight of cybersecurity risks from third-party service providers, relying on specific departments within the Investment Adviser, which aligns with Third-Party Risk. It includes a firm-specific detail about the personnel involved, but no hard verifiable facts like dates or amounts.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes, including annual assessments, framework alignment, incident response planning, and training, with the CFO overseeing these efforts rather than focusing on the individual's qualifications.


reasoning: The paragraph describes a specific cybersecurity incident in February 2022 with details on scope, response, and post-incident actions, fitting Incident Disclosure. It contains firm-specific facts like the date and CISO addition, but only one hard verifiable fact (date), so it is Firm-Specific, not Quantified-Verifiable.


reasoning: This paragraph provides a materiality assessment of cybersecurity incidents, concluding no material impact to date, which aligns with Strategy Integration per the tiebreakers, and contains no specific facts, making it Generic Boilerplate.


reasoning: The paragraph discusses cybersecurity insurance as a protective measure, which relates to financial risk mitigation and falls under strategic planning for cyber risk.


reasoning: The paragraph focuses on the Board and Audit Committee receiving regular reports on cybersecurity risks, which is a standard board oversight activity with no company-specific details.


reasoning: The paragraph describes a cybersecurity incident with details on data exfiltration, affected data types, and response actions, clearly fitting Incident Disclosure. It contains specific facts like a date and a count of regulators, making it Firm-Specific, but lacks multiple hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph focuses on the management roles (senior vice president and senior IT consultant) responsible for cybersecurity, including their qualifications and reporting lines, which aligns with the Management Role category. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph is a materiality conclusion stating no cybersecurity incidents have materially affected the business, which aligns with Strategy Integration as it discusses business impact without describing an actual incident. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion about cybersecurity threats, which aligns with Strategy Integration, and contains no specific details or verifiable facts, making it generic boilerplate.


reasoning: The paragraph centers on the CyTOC committee's oversight activities, such as receiving updates from management and briefing the Board, which aligns with Board Governance. It includes named committees and roles, making it Firm-Specific but not Quantified-Verifiable due to the absence of hard verifiable facts like dates or amounts.


reasoning: The paragraph describes the company's internal cybersecurity processes, including third-party assessments and vendor oversight, which aligns with Risk Management Process. It contains no named entities, specific dates, or verifiable facts, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the internal governance process through a management committee that oversees cybersecurity risks, aligning with Risk Management Process. It includes named cybersecurity-specific roles and a specific committee, meeting the criteria for Firm-Specific details.


reasoning: The paragraph focuses on management's role in monitoring cybersecurity processes, which aligns with internal risk management activities, and it contains no specific dates, names, numbers, or standards that identify unique company details.


reasoning: The paragraph describes the Board and Audit Committee's oversight of cybersecurity risk management, with the Board and committee as grammatical subjects, fitting Board Governance. It contains no verifiable facts, named standards, or company-specific details, making it generic boilerplate.


reasoning: The paragraph focuses on the Board's oversight of cybersecurity risks, delegation to the Audit Committee, and receiving briefings from management including the CTO, which aligns with Board Governance. The mention of the CTO role provides a firm-specific detail.


reasoning: The paragraph describes the management-led Risk Committee's structure and its role in reviewing and reporting on cybersecurity risks, which is a core component of the company's internal risk management processes.


reasoning: The paragraph centers on the Board-appointed Audit Committee's oversight responsibilities, including receiving reports from the CISO and reviewing third-party assessments, which aligns with Board Governance.


reasoning: The paragraph focuses on internal processes for evaluating and addressing cybersecurity risks, with collaboration between the risk management team, CISO, and Head of Legal, making it about the function rather than individual roles.


reasoning: The paragraph focuses on the CISO's functions in implementing cybersecurity programs, monitoring threats, and coordinating teams, which aligns with risk management processes. It includes the specific cybersecurity title 'CISO', making it Firm-Specific, but lacks quantified details.


reasoning: The paragraph is a standalone materiality conclusion stating no material cybersecurity incidents have occurred, which aligns with Strategy Integration per the tiebreakers. It contains no verifiable facts or named standards, making it generic boilerplate.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes, including incident response planning, risk identification, and reporting, with specific roles and committees as part of the framework.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks, including third-party risk as a component, which aligns with Risk Management Process. It contains no specific details, named standards, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes a general post-incident process of reassessing cybersecurity programs and reporting to senior management and the Audit Committee, which focuses on internal risk management procedures without specific details or incident references.


reasoning: The paragraph describes the company's internal cybersecurity incident response procedures, which is a risk management process. It lacks any specific dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident with details on timing, operational impact, data exfiltration, and response actions, which aligns with the Incident Disclosure category. It includes a specific date (three-month period ending September 30, 2022), qualifying it as Firm-Specific, though no other quantifiable facts are present.


reasoning: The paragraph centers on vendor assessment and controls imposed on third parties, making Third-Party Risk the most applicable category. It contains no verifiable facts, named standards, or company-specific details, so it is generic boilerplate.


reasoning: The paragraph focuses on board oversight and committee structure, with the named 'Technology & Cybersecurity Committee' being a firm-specific fact that indicates governance details unique to this company.


reasoning: The paragraph includes a materiality disclaimer stating that cybersecurity risks have not materially affected the company, which aligns with Strategy Integration per the tiebreakers, and it contains no specific verifiable facts such as dates, amounts, or named entities, making it generic boilerplate.


reasoning: The paragraph describes the Board's oversight role in cybersecurity, including quarterly briefings and participation in exercises, but contains no specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the educational backgrounds, years of experience, and previous roles of Apollo's CSO and CISO, which directly pertains to management role identification and qualifications. It contains multiple specific numbers (e.g., 'over 25 years', 'nearly eight years') that are hard verifiable facts, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's internal processes for cybersecurity support and diligence with Affiliates, which aligns with Risk Management Process. It contains no specific dates, names, or quantifiable facts, making it generic boilerplate.