reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including risk assessments and third-party oversight, with no specific details or verifiable facts provided.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes internal processes for cybersecurity oversight and incident response, including reporting lines and escalation protocols, which aligns with risk management rather than focusing solely on board or management roles.

provider: xiaomi

stage: benchmark


content_category: Board Governance

reasoning: The paragraph describes board and audit committee oversight of cybersecurity risks, with the board as the grammatical subject, fitting Board Governance. It contains no verifiable facts, named standards, or unique details, making it Generic Boilerplate.


reasoning: The paragraph describes internal cybersecurity training and awareness processes, such as new hire training and phishing tests, with only generic mentions of oversight by management and the Board, lacking any company-specific details.


content_category: Strategy Integration

reasoning: The paragraph ends with a standalone materiality conclusion stating no material impact from cybersecurity risks, which is a core element of Strategy Integration, and the preceding risk management description is generic with no specific details about processes or third parties.


reasoning: The paragraph describes the company's internal security governance structure for evaluating and addressing cyber risk, which aligns with Risk Management Process. It contains no specific dates, named entities, or verifiable details, making it Generic Boilerplate.


reasoning: The paragraph describes the company's own cybersecurity risk management processes, including threat assessment, monitoring, and incident response planning, but contains no specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: This paragraph is a cross-reference to Risk Factors discussing the materiality of cybersecurity risks, which falls under Strategy Integration as it involves materiality assessments without describing specific incidents or processes, and it contains no verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the Sponsor's internal cybersecurity risk management processes, including implementing a plan and aligning with industry standards, with no mention of specific incidents, roles, or verifiable details.


content_category: None/Other

reasoning: The paragraph describes a financial error and material weakness in internal controls over financial reporting, which is not related to cybersecurity disclosures and falls outside the scope of cybersecurity categories.


reasoning: This paragraph discusses SEC disclosure rules and regulatory requirements without providing any substantive information about EAWD's own cybersecurity practices, incidents, or governance, so it is classified as non-substantive content.


reasoning: The paragraph provides a materiality conclusion stating that cybersecurity threats have not materially affected the company, which aligns with Strategy Integration, and it contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


content_category: Management Role

reasoning: The paragraph identifies specific management roles (Chief Business Officer, Chief Accounting Officer, Head of Legal) and their cybersecurity responsibilities, with the grammatical subject being these roles, fitting the Management Role category. The named Cybersecurity Risk Management Committee provides a firm-specific fact, elevating specificity beyond generic boilerplate.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, such as policies, tools, and audits, with no focus on governance, roles, incidents, or strategy. It contains only generic descriptions of common practices without any named entities, dates, or quantifiable data.


content_category: Incident Disclosure

reasoning: The paragraph describes a real cybersecurity incident with specific timing (fourth quarter of fiscal 2025), response actions, and operational impact, which directly aligns with the Incident Disclosure category.


reasoning: The paragraph contains a materiality assessment stating no cybersecurity incidents have materially affected the company, which aligns with Strategy Integration per tiebreakers. It uses generic boilerplate language with no verifiable facts or company-specific details.


reasoning: The paragraph focuses on the company's internal processes for evaluating cybersecurity risks and reporting to the board, with the CTO and BDT & MSD as specific entities involved in these activities.


specificity_confidence: medium

reasoning: The paragraph describes a past cyberattack with specific timeline, operational impact, data exfiltration, and response actions, fitting Incident Disclosure. The specific date (September 30, 2022) makes it Firm-Specific, but no other hard verifiable facts are present.


reasoning: The paragraph focuses on the information security team's day-to-day responsibilities, monitoring, and escalation processes, which are core elements of internal risk management. It mentions third parties and insurance only as components, with no specific details or unique facts.


reasoning: The paragraph describes internal processes for incident reporting and advisory oversight on cybersecurity risks, with specific roles and committee composition indicating firm-specific details.


reasoning: The paragraph describes the company's general cybersecurity risk management processes and threat landscape without referencing specific incidents, roles, frameworks, or verifiable details, aligning with generic boilerplate language.


reasoning: This paragraph is a standalone materiality assessment stating that cybersecurity risks have not materially affected the company and includes a forward-looking disclaimer about potential material impacts, which aligns with Strategy Integration.


reasoning: The paragraph describes the company's general approach to assessing and managing cybersecurity risks, which aligns with internal risk management processes, and contains no specific details such as dates, frameworks, or roles, making it generic boilerplate.


reasoning: The paragraph primarily identifies the Principal Accounting Officer as responsible for cybersecurity and details reporting lines, fitting Management Role, and includes verifiable facts such as specific fiscal years and a percentage for committee independence.


reasoning: The paragraph focuses on the CFO's role in providing updates to the Board, which is a management function in cybersecurity governance. It includes specific internal roles (DIT and DIS) that are unique to the company, making it firm-specific.


reasoning: The paragraph centers on the Committee's oversight activities and reporting lines to the Board, with the CTO as management reporting to the Committee, fitting Board Governance. The specific title 'Chief Technology Officer' makes it Firm-Specific.


reasoning: The paragraph details a specific cybersecurity incident involving CDK, including exact dates, named systems, and operational impact, fitting the Incident Disclosure category with multiple verifiable facts.


reasoning: The paragraph is a forward-looking risk disclaimer discussing potential cybersecurity incidents and their impacts, with no reference to actual events, governance, or processes, and it cross-references Risk Factors, fitting the 'None/Other' category for non-substantive disclosure.


reasoning: The paragraph focuses on management roles and responsibilities for cybersecurity, with executive officers led by a third-party consultant, fitting the Management Role category. It contains no specific dates, amounts, named entities, or frameworks, making it generic boilerplate.


reasoning: The paragraph details the company's own internal cybersecurity risk management processes, such as incident response plans and risk assessments, but contains no specific, verifiable facts unique to the company, making it generic boilerplate.


reasoning: The paragraph centers on Board oversight through a management committee reporting to the Board and providing educational sessions, fitting the Board Governance category.


reasoning: The paragraph centers on the CISO's qualifications and the Senior VP's background, highlighting management roles and their expertise rather than board oversight or internal processes.


reasoning: The paragraph focuses on the company's internal processes for security testing and framework alignment, with no reference to board oversight, management roles, or actual incidents, making it Risk Management Process. It names recognized standards (NIST and PCI DSS) but contains no firm-specific details, so specificity is Sector-Adapted.


reasoning: The paragraph describes the VP of IT's personal background, qualifications, and certifications, which aligns with Management Role. It contains two hard verifiable facts: a specific duration of experience and a named certification, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the company's cybersecurity risk management program with generic components like risk assessments, a security team, and incident response planning, focusing on internal processes without any specific or verifiable details.


reasoning: The paragraph focuses on the Audit Committee's oversight of cybersecurity risks, with the CISO presenting to them, which is a board governance activity. It includes the specific cybersecurity role of CISO, making it Firm-Specific.


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


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, including integration into the risk management program and reliance on recognized frameworks, with Board oversight mentioned as a component but not the primary subject.


reasoning: The paragraph primarily states that cybersecurity risks have not materially affected the company and includes a cross-reference to risk factors, which aligns with Strategy Integration as it focuses on business impact and materiality assessments without describing specific incidents.


reasoning: The paragraph primarily identifies the CISO and their qualifications, which aligns with Management Role, while board oversight is included as part of the reporting structure but not the main focus.


reasoning: The paragraph describes the company's internal cybersecurity risk management framework and processes, such as threat assessment, countermeasures, and employee training, which fits the 'Risk Management Process' category. It lacks focus on board governance, management roles, or actual incident details.


reasoning: The paragraph describes the management team supervising cybersecurity risk efforts, which aligns with internal risk management processes. It contains no specific details such as named roles, frameworks, dates, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes management's hypothetical actions in reporting cybersecurity incidents to the Audit Committee and Board, which is part of the company's internal risk management processes, but it contains no specific details or verifiable facts.


reasoning: The paragraph states that no cybersecurity incidents have materially affected the company and cross-references risk factors, which aligns with Strategy Integration as it focuses on materiality assessment without describing an incident. It contains no specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph centers on the CISO's reporting activities to management and board committees, fitting Management Role, and includes specific titles and a named committee for Firm-Specific specificity.


reasoning: The paragraph describes the company's internal cybersecurity program, assessments, and controls, with management roles mentioned as part of the process implementation, fitting Risk Management Process. Specific cybersecurity roles like CISO, CTO, and CIO are identified, making it Firm-Specific.


reasoning: The paragraph contains a materiality disclaimer stating risks have not materially affected the business and includes a cross-reference to risk factors, which aligns with Strategy Integration. It lacks any specific dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph centers on the Vice President of Informatics as a management role, highlighting their qualifications and oversight of cybersecurity processes, which fits the Management Role category.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including the IS Program and incident response plan, with the CISO's role and experience as specific details supporting the process description.


reasoning: The paragraph focuses on the reporting line and qualifications of the VP, which is about management roles and not cybersecurity processes.


reasoning: The paragraph describes the team's role in overseeing cybersecurity risk management processes, including supervising personnel and reporting, which aligns with Risk Management Process rather than focusing solely on the individual's credentials.


reasoning: The paragraph primarily details the CIO's role, qualifications, reporting lines, and support structure, with board oversight mentioned only briefly, making Management Role the most applicable category.


reasoning: The paragraph describes the audit committee's oversight of cyber risk, including receiving reports from AGM's CSO or CISO, which aligns with board governance. It contains specific facts like the named entity AGM and cybersecurity-specific titles, making it firm-specific.


reasoning: The paragraph focuses on management roles (VP of IT and CFO) with detailed qualifications and reporting lines, which aligns with the Management Role category. It contains two verifiable numerical facts (years of experience), meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as risk assessments and security controls, without referencing any specific roles, incidents, frameworks, or verifiable details.


reasoning: The paragraph provides a materiality conclusion and discusses insurance coverage for cybersecurity incidents without describing specific events, which aligns with Strategy Integration.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, such as training, incident response planning, and vulnerability management, with a specific team composition, but does not describe actual incidents or board oversight.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as risk assessments and incident response planning, which aligns with the Risk Management Process category, and it contains no specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses on management roles, detailing the Vice President, Global Cybersecurity's qualifications, reporting lines, and a named committee he chairs, which aligns with the 'Management Role' category.


reasoning: The paragraph provides a materiality conclusion regarding cybersecurity threats and cross-references risk factors, which aligns with Strategy Integration per tiebreaker rules. The language is generic boilerplate with no verifiable facts or named standards.


reasoning: The paragraph focuses on Ameren's internal enterprise risk management process for cybersecurity, with the risk management steering committee as a named oversight body, making it firm-specific.


category_confidence: medium

reasoning: The paragraph describes the company's internal processes for evaluating third-party service providers and the board's oversight role, which are core elements of cybersecurity risk management. It contains no specific dates, names, or verifiable facts, making it generic boilerplate applicable to many companies.


reasoning: The paragraph focuses on the COO's responsibility to report cybersecurity updates to the board and audit committee, which is a management reporting line. It includes a specific date ('beginning in 2024'), qualifying it as Firm-Specific.


reasoning: The paragraph describes the company's internal processes for security awareness training and customer education, which are part of cybersecurity risk management, with no specific details or references to incidents, governance, or strategy.


reasoning: The paragraph focuses on a specific management role and their qualifications, making it about management oversight rather than general processes. It includes firm-specific details such as a unique job title and years of experience, which are not generic boilerplate.


reasoning: The paragraph details two actual cybersecurity incidents with specific dates, scope of disruption, and response actions, which aligns with the Incident Disclosure category. The presence of two specific dates (December 2021 and March 2024) meets the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's internal risk management processes, including the formation of a specific committee and routine security testing, which are core operational activities without incident details or board focus.


reasoning: The paragraph identifies specific management roles (CISO and Chief Insurance Officer) and their responsibilities, with emphasis on the CISO's qualifications and tenure, fitting the Management Role category. It contains firm-specific details like cybersecurity-specific titles and a named internal steering group.


reasoning: The paragraph includes a materiality disclaimer stating no cybersecurity incidents have materially affected the company, which aligns with Strategy Integration, and it specifies unique management roles involved in incident reporting, making it firm-specific.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risks, including the establishment of a Security Steering Group with specific management roles, which aligns with Risk Management Process rather than focusing solely on board oversight or individual qualifications.


reasoning: The paragraph focuses on the CISO's qualifications, reporting structure, and the management-led Cybersecurity Governance Council, with Board oversight mentioned only briefly, making Management Role the primary category.


reasoning: The paragraph primarily provides a materiality conclusion on cybersecurity threats, which is a core element of strategy integration, and contains no specific facts, frameworks, or verifiable details, making it generic boilerplate.


reasoning: The paragraph focuses on the internal oversight process through a named management committee and specific cybersecurity roles, detailing governance activities rather than individual qualifications or board-level oversight.


reasoning: The paragraph focuses on identifying the CISO, their responsibilities, reporting lines, and qualifications, which aligns with the Management Role category. It includes specific verifiable facts such as years of experience and named certifications, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph focuses on the CyTOC and Board receiving updates and overseeing cybersecurity risks, with management as information providers, making Board Governance the primary category. It includes firm-specific entities like CISO and CyTOC, but no quantifiable details.


reasoning: The paragraph describes the company's internal cybersecurity processes, such as monitoring, detection, prevention, and adherence to regulations and standards, with no focus on specific incidents, roles, or board oversight details.


reasoning: The paragraph describes the company's internal training programs and integration processes for acquired companies, which falls under risk management, and lacks any specific dates, names, or verifiable details, making it generic.


reasoning: The paragraph describes the company's business focus and contains no cybersecurity-related content, such as governance, risk management, or incidents, so it falls under None/Other.


reasoning: The paragraph centers on the Board and its committees overseeing cybersecurity risk, with specific details such as delegation since 2022 and the CISO's reporting role, indicating firm-specific governance structure.


content_category: Third-Party Risk

reasoning: The paragraph centrally discusses cybersecurity risks associated with third-party vendors, making Third-Party Risk the appropriate category. It contains no specific dates, names, or verifiable facts, so it is generic boilerplate.


reasoning: The paragraph focuses on the company's program for managing cybersecurity risks from third-party service providers, making 'Third-Party Risk' the appropriate category. It lacks specific frameworks, dates, or verifiable details, so it is generic boilerplate.


reasoning: The paragraph describes a specific phishing incident with dates, financial loss, and recovery actions, fitting Incident Disclosure. It contains multiple hard verifiable facts (two exact dates and a dollar amount), qualifying as Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity risk management process, including outsourcing to specific providers and reporting lines, which is focused on function rather than board oversight or incident details.


reasoning: The paragraph focuses on the company's internal cybersecurity processes, including incident response procedures, board oversight, and management coordination, which aligns with risk management rather than a specific incident or personal qualifications.


reasoning: The paragraph focuses on identifying specific management roles (CTO and CISO) with their qualifications and describes a detailed cross-functional team composition, emphasizing who is responsible for cybersecurity processes rather than the processes themselves.


reasoning: The paragraph describes the company's internal Cybersecurity Plan focused on assessing and managing risks through processes like adopting standards and integrating with risk management, fitting Risk Management Process. It names a specific industry standard (NERC CIP), making it Sector-Adapted without unique firm details.


reasoning: The paragraph focuses on the CISO's ongoing education and the cybersecurity team's processes for monitoring and incident response, which are activities central to risk management rather than personal management roles or board oversight.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes led by the Director of Information Technology, describing general activities like monitoring and threat assessment without any specific verifiable facts or named standards.


reasoning: The paragraph centers on the Board and Audit Committee's oversight responsibilities and reporting cadences from management roles, which aligns with Board Governance. It includes specific cybersecurity titles (CISO, CTO) and a named committee (Enterprise Risk Management Committee), making it Firm-Specific.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, including controls, standards adoption, and oversight, without detailing board governance, management roles, or incidents. It names recognized frameworks like PCI DSS and CIS, but contains no unique firm-specific details.


reasoning: The paragraph describes a real cybersecurity incident with specific details about the vendor, product, and timeline, including the exploit, data accessed, and response actions.


reasoning: The paragraph primarily describes the qualifications and responsibilities of the Chief Security Officer and Information Security team members, with only a brief mention of board-level oversight, aligning with Management Role. It includes specific titles and a named committee, making it Firm-Specific.


reasoning: The paragraph explicitly states the company is a SPAC with no operations and no cybersecurity program, which is non-substantive and falls under None/Other per the tiebreaker for shell companies.


reasoning: The paragraph centers on the Board's oversight function and delegation of cybersecurity risk to management roles, fitting Board Governance. It lacks any named entities, dates, or unique details, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on the VP of Information Technology's qualifications and reporting lines, which aligns with the Management Role category. It includes firm-specific details like the job title and years of experience, but lacks multiple hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph explicitly states the company has no cybersecurity risk management program or formal processes, which fits the 'None/Other' category for SPACs or shell companies with no substantive disclosure.


reasoning: The paragraph focuses on the Board's active oversight of cybersecurity as part of risk management, and it names recognized frameworks (ISO, NIST) but lacks company-specific details.


reasoning: The paragraph describes the company's use of cybersecurity tools and a third-party SOC, which are components of its internal risk management processes. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate applicable to many companies.


reasoning: The paragraph focuses centrally on vendor oversight processes, such as risk assessments and contract terms, but contains no specific dates, named entities, or verifiable details, making it generic boilerplate.


reasoning: The paragraph details the company's internal governance structures and processes for cybersecurity oversight, including specific management-level committees and roles, which falls under risk management processes rather than board governance or individual role focus.


reasoning: The paragraph is purely a cross-reference to risk factors in Item 1A and contains no substantive disclosure about cybersecurity governance, processes, or incidents.


reasoning: The paragraph explicitly states the company is a SPAC with no operations and no cybersecurity program, which aligns with the tiebreaker for shell companies, making it non-substantive and falling under None/Other.


reasoning: The paragraph describes the company's internal incident response plans and processes, which is a core risk management activity, without referencing actual incidents or specific board oversight. It contains no verifiable facts, named entities, or unique details, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on specific management roles (Senior Director, CFO, General Counsel) responsible for cybersecurity, with reporting to the audit committee and board as secondary details, fitting Management Role. It contains firm-specific details like the unique role title and team composition, but no quantified-verifiable facts.


reasoning: The paragraph describes an internal audit process for the Information Security program, which is a component of risk management. It contains no specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes a cybersecurity incident in December 2022, including data extraction and response actions, which aligns with Incident Disclosure. The specific date is a firm-specific fact, but no additional verifiable facts are present.


reasoning: The paragraph focuses on regulatory context and a company-specific materiality conclusion, which aligns with Strategy Integration as it involves materiality assessments and business impact without describing an actual incident.


reasoning: The paragraph describes a specific cybersecurity incident with a date, details of the ransomware attack, and response actions, fitting the Incident Disclosure category.


reasoning: The paragraph focuses on the board's oversight role through the Audit Committee and the reports received from specific management roles, which aligns with Board Governance. It includes firm-specific cybersecurity titles like SRC Director and Chief Information Officer, qualifying as Firm-Specific.


reasoning: The paragraph describes the Company's internal processes for cybersecurity training and communication, 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 focuses on the CIO's qualifications (15 years of experience) and reporting structure, which are attributes of a management role rather than a description of processes.


reasoning: The paragraph describes BNY Mellon's cybersecurity risk management processes, including the CISO-led Information Security Division and its functions, which is central to internal risk management rather than board oversight or incident details.


reasoning: The paragraph describes CTBI's internal incident response plans and escalation procedures, which are core risk management processes. It lacks any specific dates, dollar amounts, named third-party firms, or verifiable facts, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on the company's internal ERM program and oversight processes, with specific details about committee composition and roles, aligning with risk management activities rather than board or management governance in isolation.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and the roles of management in implementing them, with no specific verifiable facts, named standards, or focus on individual qualifications or board oversight details.


reasoning: The paragraph focuses on the company's internal cybersecurity policies and procedures for risk management, including third-party oversight as a component, with no specific details or incidents described.


reasoning: The paragraph describes the company's internal processes for monitoring and managing cybersecurity threats, with the Vice President of Information Technology as the central point, which aligns with risk management functions rather than focusing on the person's qualifications or board oversight.


reasoning: The paragraph focuses on the potential material adverse effect of cybersecurity threats on business strategy and financial condition, which is a materiality assessment typical of Strategy Integration. It contains no specific dates, names, or verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph describes the composition of the ISO Committee, a governance body likely overseeing cybersecurity, with specific executive roles and experience, making it firm-specific and aligned with board/committee oversight.


reasoning: The paragraph identifies specific management roles (chief security officer and chief privacy officer) and their qualifications, aligning with the Management Role category, and contains two hard verifiable facts: cybersecurity-specific titles and a specific number of years of experience.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, such as cross-departmental approaches, software programs, and policies, with no incident disclosure or emphasis on board governance or management roles as the primary subject.


reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity risks and reporting to the Board, fitting Board Governance. It includes two hard verifiable facts: a specific year (2023) and a specific number of meetings (four times), meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes based on named ISO and NIST frameworks, which are recognized standards but lack firm-specific details.


reasoning: The paragraph focuses on the Audit Committee's oversight of cybersecurity risks, including quarterly discussions with the CIO and reporting to the Board, which is a board governance function. The mention of the CIO title provides a firm-specific detail.


reasoning: The paragraph centrally describes processes for managing cybersecurity risks from vendors and third parties, aligning with the Third-Party Risk category, and contains no specific dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph focuses on the Audit Committee's oversight of cybersecurity, which is a board governance function, and mentions specific management roles (CIO/CISO), providing a firm-specific detail.


reasoning: The paragraph focuses on the Board of Directors' oversight of cybersecurity risk, with the Audit Committee mentioned, which aligns with Board Governance. It contains no specific details such as dates, roles, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes the company's own internal processes for managing cybersecurity risks, including various procedures and third-party oversight as a component, which aligns with Risk Management Process. 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 risk assessment and technical controls, with no reference to board oversight, management roles, incidents, or third-party risk, fitting 'Risk Management Process'. It contains no hard verifiable facts, named standards, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph emphasizes board and audit committee oversight of cybersecurity risk management, with management roles and reporting lines integrated into the governance structure.


reasoning: The paragraph describes the company's internal cybersecurity processes, such as investments in IT security, training, defenses, and testing, which aligns with Risk Management Process. There is no focus on board oversight, management roles, incidents, or strategy integration.


reasoning: The paragraph describes a specific cybersecurity incident with details on date, vendor, system, scope, and response actions, fitting Incident Disclosure. It contains multiple verifiable facts including a specific filing date, named third-party firm and product, and quantified data exposure, meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal oversight process for cybersecurity through a named committee and its activities, which aligns with risk management processes rather than board-level governance or individual management roles.


reasoning: The paragraph explicitly describes third-party service providers as key to cybersecurity risk management, with vendor oversight as the central topic, fitting Third-Party Risk. It contains no named entities, dates, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes a security team responsible for managing cybersecurity risk assessment, security controls, and incident response processes, which focuses on internal functions rather than specific individuals or board oversight.


reasoning: The paragraph lists items typically under board oversight of cybersecurity, such as personnel qualifications and strategy, but does not explicitly name the board or provide concrete details, making it generic.


reasoning: The paragraph centers on the CSO's responsibilities and the Executive Committee's assessment of the CSO's expertise, making Management Role the primary category.


reasoning: The paragraph describes the company's cybersecurity program processes, including governance delegation and cross-functional approaches, which are central to internal risk management rather than focusing solely on board oversight or individual roles.


reasoning: The paragraph describes internal processes for reviewing and updating cybersecurity governance documents and strategic plans, with the Information Security team and CISO as key actors, focusing on risk management activities rather than board oversight or incident details.


reasoning: The Audit Committee is the grammatical subject overseeing IT systems and information security, which aligns with Board Governance. The paragraph lacks any specific details like dates, names, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes management's oversight of cybersecurity threat assessment and incident notification procedures, which are internal risk management processes without specific details.


reasoning: The paragraph describes cybersecurity oversight by the audit committee and Board, which is a governance function. It uses generic terms like 'periodic briefings' and 'audit committee' with no specific dates, names, or verifiable details.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including engaging third-party specialists, maintaining a 5-year plan, and assessing cloud suppliers, with no focus on board oversight, specific roles, or actual incidents.


reasoning: The paragraph centers on the board of directors' understanding and oversight of cybersecurity risks, which aligns with Board Governance. It contains no specific dates, roles, frameworks, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's incident response plan and internal processes for addressing cybersecurity risks, which aligns with Risk Management Process. It contains no specific dates, names, or verifiable facts, using generic language applicable to any company.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including risk assessments, monitoring, and third-party oversight, with escalation procedures, making Risk Management Process the primary category.


reasoning: This paragraph is a forward-looking disclaimer about the absence of past material incidents and potential future risks, with no substantive disclosure about cybersecurity governance, processes, or incidents.


reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity risk and the reporting lines from management, which is core to Board Governance.


reasoning: The paragraph describes the company's internal processes for identifying and assessing cybersecurity risks, with specific management roles involved, aligning with Risk Management Process. The mention of 'Chief Compliance Officer' and 'Head of Global Information Technology' provides firm-specific details, making it Firm-Specific.


reasoning: The paragraph centers on the Audit and Examination Committee's oversight of cybersecurity risk management and reporting from the Information Security Officer, which aligns with board governance. The mention of the Information Security Officer provides a firm-specific detail, making the specificity Firm-Specific.


reasoning: The paragraph describes the company's internal cybersecurity program, including risk-based approaches and framework adoption, which aligns with Risk Management Process. It names the NIST Cybersecurity Framework, a recognized standard, but contains no firm-specific details, making it Sector-Adapted.


reasoning: The paragraph describes internal oversight of cybersecurity risk management processes by specific teams, which aligns with Risk Management Process, and it names a unique team composition, making it Firm-Specific.


reasoning: The paragraph focuses on the CISO and CIO as management roles and their responsibilities in briefing the board, making Management Role the appropriate category. It includes cybersecurity-specific titles, which are firm-specific facts.


reasoning: The paragraph focuses on specific management roles (CISO and SVP of IT) with detailed qualifications and responsibilities, including experience duration, which aligns with the Management Role category.


reasoning: The paragraph focuses on the Board's oversight role and delegation to the Audit Committee, with the CFO reporting quarterly, which aligns with Board Governance. It lacks any specific dates, named entities, or verifiable facts, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on management roles (CIO and Director of Information Security) and their qualifications, with specific verifiable facts like years of experience and degrees, making it Quantified-Verifiable.


reasoning: The paragraph includes a materiality conclusion stating that cybersecurity incidents have not materially affected the business, which is the defining feature of Strategy Integration. It contains no specific details about incidents, governance, or processes, and the cross-reference to Risk Factors does not change the classification.


reasoning: The grammatical subject is management roles (Executive Officer and Vice President of Technology) providing briefings to the board, focusing on their action rather than board oversight or specific processes. The paragraph contains no verifiable facts, named entities, or unique details, making it applicable to any company.


reasoning: This paragraph is a cross-reference to the Risk Factors section and does not contain any substantive disclosure about cybersecurity governance, processes, or incidents.


reasoning: The paragraph describes the company's internal cybersecurity processes and measures, fitting Risk Management Process. It contains no specific facts, names, dates, or standards, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity processes, including training, scanning, and encryption, which aligns with risk management. It contains no verifiable facts, named standards, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes Exelon's cybersecurity risk management processes, including threat intelligence, tools, compliance with specific standards, and coordination activities, with the CISO as the leading role, making it focused on internal processes rather than incident disclosure or governance.


reasoning: The paragraph centers on the CTO's qualifications, reporting lines, and responsibilities, fitting the Management Role category, and includes firm-specific details like the CTO title and years of experience.


reasoning: The paragraph describes the company's internal cybersecurity processes, including a named TT&E program and adherence to a specific NIST standard, which aligns with Risk Management Process.


reasoning: The paragraph describes a past cybersecurity incident with specific details about the event (email spoofing in May 2014, detection, and outcome), which aligns with Incident Disclosure. The specific date (May 2014) is a firm-specific fact, but no other verifiable facts are present, making it Firm-Specific.


reasoning: The paragraph centers on the CIO/CISO's qualifications and responsibilities, with the grammatical subject being a management role, and includes firm-specific details like the cybersecurity-specific title and years of experience.


reasoning: This paragraph is a cross-reference to the Risk Factors section and does not contain any substantive cybersecurity disclosure, fitting the 'None/Other' category for non-content.


reasoning: The paragraph centers on the CISO's qualifications, responsibilities, and reporting lines, with specific details like years of experience and the CDO role, making it a management role disclosure rather than board oversight or risk processes.


reasoning: The paragraph emphasizes board oversight and audit committee reporting, with specific details about roles and committee composition, making it focused on governance structure.


reasoning: This paragraph is a pure cross-reference to risk factor disclosures in Item 1A, containing no substantive cybersecurity information, thus classified as None/Other with generic boilerplate specificity.


reasoning: The paragraph describes a cybersecurity incident with stolen BTC, forensic analysis, and response actions, including a specific date and dollar amount that are verifiable hard facts.


reasoning: The paragraph focuses on the qualifications and certifications of the Vice President of Risk Management and related personnel, which is characteristic of the Management Role category, and includes specific titles and credentials unique to this disclosure.


reasoning: The paragraph describes the CISO's role, qualifications, and reporting lines, which are central to management-level cybersecurity oversight, fitting the Management Role category. It contains firm-specific details like the CISO title and experience years, but lacks multiple hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph emphasizes the qualifications and committee participation of specific management roles (chief risk officer and interim CIO), fitting Management Role. The years of experience (15 and 30) are quantifiable hard facts, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph centers on the CIO's identification, qualifications (including specific years of experience), and the management-led Security Council, making Management Role the primary category, with two hard numerical facts supporting Quantified-Verifiable specificity.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, including risk assessment and incident response planning, with no specific incidents or management roles detailed.


reasoning: The paragraph describes hypothetical cybersecurity risks and their generic impacts without referencing any actual incident, specific processes, governance details, or company-specific facts, making it non-substantive forward-looking content.


reasoning: The paragraph centers on the CIO's role, qualifications, and reporting line, with the grammatical subject being the CIO and internal IT team, fitting the Management Role category. It includes the cybersecurity-specific title 'CIO' as a firm-specific fact, but lacks hard verifiable details like dates or amounts, so specificity is Firm-Specific.


reasoning: The paragraph centers on the identification of specific management roles (CISO and CRO) and their reporting lines to the risk committee, detailing how they support board oversight, which aligns with the Management Role category.


reasoning: The paragraph focuses on the internal risk management processes led by the CRO and CISO, including risk assessment and coordination with other functions, which aligns with Risk Management Process. It contains specific roles and program names, making it Firm-Specific.


reasoning: The paragraph describes the company's internal risk assessment process, which is central to risk management. It lacks any specific details, named standards, or verifiable facts, making it generic boilerplate applicable to any company.


reasoning: The paragraph provides a standalone materiality conclusion stating no material cybersecurity events have occurred, which falls under Strategy Integration. It contains no specific facts, frameworks, or unique details, making it Generic Boilerplate.


reasoning: The paragraph focuses on the CIO's responsibilities, tenure, experience, and educational background, which are centered on the management role rather than board oversight or processes.


reasoning: The paragraph focuses on the qualifications, experience, and reporting lines of the CIO and Senior Director, with specific verifiable facts like years of experience and named certifications, aligning with Management Role and Quantified-Verifiable specificity.


reasoning: The paragraph focuses on the company's internal processes for managing cybersecurity incidents, including a specific 36-hour reporting policy, which aligns with Risk Management Process and provides a firm-specific detail.


reasoning: The paragraph focuses on the Bank's internal cybersecurity risk management processes, such as defense-in-depth and integration with ERM, without referencing board oversight, management roles, incidents, or third-party risks. It contains no specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes embedding cybersecurity within enterprise risk management (ERM) strategies to evaluate risks, which is a core internal process for risk assessment and integration, fitting the Risk Management Process category.


reasoning: The paragraph describes the company's incident response plan processes in general terms without any specific details, making it a generic description of internal risk management activities.


reasoning: This paragraph is a standalone materiality conclusion stating no material cybersecurity incidents have occurred, which aligns with Strategy Integration. It contains no specific dates, names, or verifiable facts, making it Generic Boilerplate.


reasoning: This paragraph describes a cybersecurity incident involving stolen BTC, including forensic analysis, control modifications, and a specific financial payment, which directly aligns with the Incident Disclosure category.


reasoning: The paragraph focuses on the absence of material incidents and the potential business impact of cybersecurity threats, which aligns with Strategy Integration as it involves materiality assessment. It lacks any specific details such as dates, names, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for incident response and coordination, including a specific committee and cross-functional team, which fits the Risk Management Process category.


reasoning: The paragraph centers on the CISO's qualifications, experience, and reporting lines, with detailed verifiable facts such as years of experience and specific certifications, making Management Role the primary category.


reasoning: The paragraph is a standalone materiality conclusion stating that cybersecurity risks have not materially affected the company, which aligns with the Strategy Integration category per tiebreakers for materiality disclaimers.


reasoning: The paragraph is a generic statement about cybersecurity risks and potential material impacts without any specific details about governance, processes, or incidents, fitting 'None/Other' as it lacks substantive disclosure.


reasoning: The paragraph primarily describes the Audit Committee and Board's oversight role in cybersecurity risk management, including briefing cadences and engagement, with the CIO's reporting and experience as supplementary details.


reasoning: The paragraph centers on the CTO's role, qualifications, and reporting lines, with the CTO as the grammatical subject, fitting Management Role. It includes firm-specific details like the CTO title, named Risk Committee, and specific educational and experiential facts.


reasoning: The paragraph describes the company's internal cybersecurity organization, controls, and processes, with specific management roles as the grammatical subjects, fitting Risk Management Process. It contains firm-specific facts like the CISO and CIO titles.


reasoning: The paragraph describes the functions and responsibilities of the Information Security Department in managing cybersecurity risk, which aligns with internal risk management processes rather than board oversight, incident disclosure, or other categories.


reasoning: The paragraph describes the delegation of cybersecurity risk management to specific named entities and reliance on Blackstone, focusing on the company's internal process structure rather than board oversight or individual roles.


reasoning: The paragraph focuses on the company's Incident Response Plan (IRP) design, controls, and framework adoption, which are core elements of internal risk management processes. It names the NIST Cybersecurity Framework, a recognized standard, but contains no other firm-specific details.


reasoning: The paragraph focuses on management's responsibilities for cybersecurity implementation and reporting to the Board, with no specific details or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident (MOVEit) with details on the date, scope of affected individuals, and response actions, which aligns with the Incident Disclosure category. It contains multiple verifiable hard facts including a specific date, named product, and quantified impact.


reasoning: The paragraph describes the company's internal security governance structure for evaluating and addressing cyber risk, which aligns with risk management processes; mentions of CFO and Board are generic and not the primary focus.


reasoning: The paragraph focuses on the company's internal risk management assessment process overseen by the CISO, which aligns with Risk Management Process, and it includes a cybersecurity-specific title, making it Firm-Specific.


reasoning: The paragraph primarily describes the CFO's role in directing cybersecurity programs with board reporting, and includes a materiality conclusion referencing the specific year 2024.


reasoning: The paragraph describes a past cybersecurity incident with specific details (date and type), which aligns with Incident Disclosure. It contains a specific date (May 2020), making it Firm-Specific.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as reviews by Internal Audit and maturity assessments against the NIST framework, which aligns with Risk Management Process. It names a recognized standard (NIST) but contains no unique company-specific details, making it Sector-Adapted.


reasoning: This paragraph is a pure cross-reference to risk factors in another section, providing no substantive cybersecurity disclosure, which aligns with the 'None/Other' category for non-cybersecurity content or cross-references.


reasoning: The paragraph centers on the CISO's reporting lines to senior management and escalation to the board, which directly relates to the management role in cybersecurity oversight.


reasoning: The paragraph focuses on the CIO's identification, qualifications, and responsibilities, which aligns with the Management Role category. It contains firm-specific facts such as the cybersecurity-specific title and a specific number of years of experience, making it Firm-Specific.


reasoning: This paragraph discusses cyber risk insurance and potential coverage limitations, which is a strategic financial consideration without describing any incident or specific internal processes.


reasoning: The paragraph describes internal processes for cybersecurity incident management and materiality assessment, led by specific management roles and named teams, without referencing an actual incident or third-party risks.


reasoning: The paragraph focuses on the technology team's internal processes for cybersecurity maturity, such as defining work plans and setting improvement objectives, which aligns with Risk Management Process. It includes firm-specific details like a named role and experience duration, making it Firm-Specific but not Quantified-Verifiable due to the lack of multiple hard verifiable facts.


reasoning: The paragraph describes management's training through briefings to assess and manage cybersecurity risks, which is part of the company's internal risk management processes. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate applicable to any company.


reasoning: The paragraph details the company's internal cybersecurity processes, including technical safeguards, incident response planning, third-party risk management, and employee training, which aligns with Risk Management Process. It is Firm-Specific due to the specific team name, but lacks hard verifiable facts for higher specificity.


reasoning: The paragraph focuses on the oversight role of a specific board committee, the Risk and Compliance Oversight Committee, in cybersecurity matters, which is a firm-specific governance detail.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as assessments and remediation tracking, with no reference to specific incidents, persons, or verifiable details.


reasoning: The paragraph centers on the Chief Technology Officer's identification, qualifications, and reporting lines, with the CTO as the grammatical subject, fitting the Management Role category. It includes firm-specific facts like the CTO's title and years of experience, qualifying it as Firm-Specific.


reasoning: This paragraph describes the company's internal incident response processes, including team structure and testing, which falls under Risk Management Process. It contains specific facts such as the CISO role and detailed departmental composition, making it firm-specific.


reasoning: The paragraph describes internal risk assessments and incident response planning, which are core risk management processes. It contains no specific dates, names, verifiable facts, or named standards, making it generic boilerplate applicable to any company.


reasoning: The paragraph explicitly states the company was a SPAC with no business operations and has not adopted any cybersecurity risk management program or formal processes, which aligns with the tiebreaker for shell companies with no operations, classifying it as None/Other.


reasoning: The paragraph describes the company's internal cybersecurity processes for threat operations and incident response, which falls under Risk Management Process. It contains no specific dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph focuses on the IT Lead's qualifications and experience, which aligns with the Management Role category as it centers on a specific management position rather than board oversight or detailed processes.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including maintaining teams and using third-party experts for assessments, which aligns with Risk Management Process. It contains no specific dates, named entities, or verifiable details, making it generic boilerplate.


reasoning: The paragraph describes the Partnership's engagement of external experts as part of its risk management processes, focusing on general activities like audits and penetration testing, which aligns with internal risk management rather than third-party oversight as the central topic.


reasoning: The paragraph states a materiality conclusion for cybersecurity incidents during a specific year and cross-references risk factors, which aligns with Strategy Integration. The specific date (December 31, 2023) qualifies it as Firm-Specific, though the overall language is boilerplate.


reasoning: This paragraph describes a specific cybersecurity incident involving impersonation and unauthorized Bitcoin transfer, including details on scope (26 BTC, $560,000) and response actions (law enforcement engagement), fitting the Incident Disclosure category.


reasoning: The paragraph describes the company's internal cybersecurity processes, including the incident response team composition and management roles, which are central to risk management rather than focusing on board oversight, incident details, or strategy.


reasoning: The paragraph provides a materiality conclusion regarding cybersecurity risks and references risk factors, which aligns with Strategy Integration as it discusses business impact without describing an incident. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph focuses on the company's internal processes for managing cybersecurity risks, such as incident response planning and oversight by senior executives and an IT service provider, which aligns with Risk Management Process. It lacks specific details like named roles, dates, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident with exact dates, unauthorized access, malware deployment, and data exfiltration, which directly aligns with the Incident Disclosure category.


reasoning: This paragraph describes a cybersecurity incident, including the scope of affected systems and data, response actions such as customer notifications and credit monitoring, and legal proceedings, which aligns with Incident Disclosure. The specific number of impacted consumers makes it Firm-Specific.


reasoning: The paragraph describes oversight of cybersecurity policies and processes by the Cybersecurity Committee and CISO, which aligns with board governance. It includes specific cybersecurity titles and a named committee, making it firm-specific.


reasoning: The paragraph describes the company's internal processes for monitoring and responding to cybersecurity incidents, which aligns with Risk Management Process, and it contains no specific verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident with dates, operational impact, and financial costs, fitting the Incident Disclosure category. It contains multiple hard verifiable facts including specific dates and a dollar amount, making it Quantified-Verifiable.


reasoning: The paragraph focuses on controls and processes for overseeing third-party service providers' cybersecurity risks, such as risk assessments and security requirements, which is the central topic of Third-Party Risk. 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 cybersecurity risk management processes, such as a security council and embedded expert program, which are firm-specific details rather than board oversight or incident disclosure.


reasoning: The paragraph primarily describes the company's internal risk assessment and safeguard monitoring processes, aligning with Risk Management Process, and includes two specific, verifiable facts (years of experience) that meet the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and managing cybersecurity risks through an enterprise-wide information security program, with the CISO mentioned as managing it, which aligns with Risk Management Process rather than focusing on the person's role.


reasoning: The paragraph focuses on the company's cybersecurity program, policies, and framework alignment, which is central to risk management processes, and it names recognized standards (NIST and ISO) without providing unique firm-specific details.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including assessments, technical measures, and employee training, with no focus on board oversight, management roles, or specific incidents.


reasoning: The paragraph provides a materiality conclusion regarding cybersecurity risks and cross-references the Risk Factors section, which aligns with Strategy Integration per the tiebreaker for materiality disclaimers. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph centers on the oversight and assessment of third-party providers to ensure compliance with cybersecurity standards, making vendor risk management the central topic.


reasoning: The paragraph describes a general internal process for access control, which is a core component of cybersecurity risk management, with no specific details about the company.


reasoning: The paragraph provides a materiality conclusion regarding cybersecurity incidents and cross-references risk factors, which aligns with Strategy Integration. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph focuses on the company's internal processes for cybersecurity incident management, including team composition and materiality assessment, which aligns with Risk Management Process. It contains firm-specific details such as cybersecurity-specific roles and a named internal committee.


reasoning: The paragraph describes an actual cybersecurity incident (email spoofing) with specific dates, a dollar amount, and response actions, fitting the Incident Disclosure category. It contains multiple hard verifiable facts (dates and financial amount), meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes general data sensitivity and regulatory obligations (e.g., HIPAA, CCPA) but does not disclose any specific cybersecurity governance, processes, or incidents, fitting 'None/Other' as it lacks substantive cybersecurity disclosure.


reasoning: The paragraph centers on the CIO's qualifications and reporting line to the ISMS Committee, which is a management-level oversight structure, fitting the Management Role category.


reasoning: The paragraph describes internal processes for cybersecurity personnel training, certification, and participation in industry groups, which are core components of risk management activities.


reasoning: The paragraph focuses on a management-level committee overseeing cybersecurity policies and reporting, which is an internal risk management process rather than board governance or individual roles.


reasoning: The paragraph focuses on the Board and Audit Committee providing oversight of cybersecurity risks, with reporting from specific cybersecurity roles (CTO and CISO), fitting Board Governance and Firm-Specific due to named titles.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment and management processes executed by the CSIRT led by a specific management role, with firm-specific details like the Director's title and years of experience.


reasoning: The paragraph is a materiality disclaimer stating that cybersecurity threats have not materially affected the company, which aligns with Strategy Integration. It contains no specific facts and is generic boilerplate language.


reasoning: The paragraph focuses on the materiality assessment of cybersecurity risks and their potential business impact, which aligns with Strategy Integration. It contains no specific details about incidents, processes, or roles, and is generic boilerplate language.


reasoning: The paragraph describes the scope and response actions of a cybersecurity incident, including notifications and services provided, with a specific number of affected consumers, making it an incident disclosure with firm-specific details.


reasoning: The paragraph describes internal committees (OROC and IT Steering Committee) that oversee cybersecurity risk, which is part of the company's risk management processes. It includes specific committee names, departmental compositions, and cybersecurity-specific roles, making it firm-specific.


reasoning: The paragraph centers on the board and Audit Committee's ultimate oversight of cybersecurity risks, detailing their roles and reporting processes, which aligns with Board Governance. It includes firm-specific details like departmental compositions and named roles, making it Firm-Specific.


reasoning: The paragraph describes the company's internal risk management processes, including assessments, audits, and training programs, with no specific dates, named entities, or unique identifiers that would elevate it beyond generic boilerplate.


reasoning: The paragraph describes the company's internal IT risk management process, including risk identification and a risk register, 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 responsibilities of a management committee in overseeing cybersecurity processes, such as setting programs and monitoring risk, which aligns with internal risk management activities. It names specific committees unique to the company, making it Firm-Specific.


reasoning: The paragraph focuses on the company's internal cybersecurity processes, such as incident response planning and risk assessment, with third-party risk mentioned as a component, but contains no verifiable facts or unique details.


reasoning: The paragraph focuses on the Board of Directors overseeing cybersecurity and receiving updates from senior management, which aligns with board governance activities, and it lacks any specific verifiable facts, making it generic boilerplate.


reasoning: This is a standalone materiality conclusion with no incident reference, classified as Strategy Integration per tiebreakers. It contains no verifiable facts or named standards, making it Generic Boilerplate.


reasoning: The paragraph focuses on the Audit Committee and full Board receiving briefings and presentations on cybersecurity, with the Board as the grammatical subject, indicating board oversight. It mentions the CISO, a cybersecurity-specific title, which qualifies as a firm-specific fact.


reasoning: The paragraph describes an actual cybersecurity incident with a specific detection date and detailed response actions, aligning with the Incident Disclosure category.


reasoning: The paragraph focuses on cybersecurity processes such as monitoring, security measures, and incident response planning overseen by management roles, fitting Risk Management Process. The named CISO and CIO roles are specific facts that make it Firm-Specific.


reasoning: The paragraph focuses on the IT Department's internal processes for managing cybersecurity risk, including specific roles and reporting lines, which aligns with Risk Management Process rather than individual management roles or board oversight.


reasoning: The paragraph focuses on the company's internal processes of engaging third-party firms for security engineering, assessments, and audits, which aligns with risk management processes. It contains no specific names, dates, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph is a materiality conclusion stating that cybersecurity risks have not materially affected the company, which aligns with Strategy Integration. It contains no specific facts such as named entities, frameworks, or verifiable details, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal risk management processes, focusing on the Information Security Program's design and activities, with firm-specific details like the CISO role and named oversight committees.


reasoning: The paragraph centrally discusses mitigating cybersecurity risks from third-party service providers through due diligence and contractual terms, with no specific details, verifiable facts, or named standards.


reasoning: The paragraph describes the management roles (ISO, CIO) and team qualifications, focusing on the individuals responsible for cybersecurity, which aligns with Management Role. It contains specific facts like titles, experience duration, and certifications, making it Firm-Specific.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including defenses, monitoring, training, and third-party assessments, with no specific dates, names, or quantifiable facts, making it generic boilerplate applicable to any company.


reasoning: This paragraph is a standalone materiality conclusion with no incident reference, which falls under Strategy Integration per the tiebreakers. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph is a boilerplate materiality disclaimer stating that cybersecurity risks have not materially affected operations but could in the future, with a cross-reference to Risk Factors, which aligns with Strategy Integration. It contains no specific facts, named entities, or verifiable details.


reasoning: The paragraph centers on oversight of third-party service providers for cybersecurity risks, aligning with Third-Party Risk, but contains no specific dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph describes incident response actions (e.g., forensic investigation, SIEM/SOC monitoring) and concludes with a materiality assessment, fitting Incident Disclosure as it focuses on post-incident remediation, though it lacks specific incident details like dates or scope.


reasoning: The paragraph centers on mitigating risks from third-party vendors through a vendor risk management program, including due diligence and contractual requirements, which directly matches the Third-Party Risk category. It lacks any named entities, dates, or unique details, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's approach to assessing and managing cybersecurity risks, which is a core risk management process, but it contains no specific facts, named entities, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: This paragraph is a materiality disclaimer assessing the lack of cybersecurity weaknesses that could affect operations, which aligns with Strategy Integration as it focuses on material impact without describing an incident or specific processes.


reasoning: The paragraph focuses on cybersecurity insurance coverage for costs related to incidents, which is a financial and strategic aspect of cybersecurity management, fitting Strategy Integration. It contains no specific details such as dates, amounts, or named entities, making it generic boilerplate.


reasoning: The paragraph focuses on the company's internal processes for security monitoring, event categorization, and escalation to management and the Board, which aligns with risk management. It lacks any specific dates, names, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on the Audit Committee's oversight of cybersecurity risk and the CISO's reporting line, which is a firm-specific governance structure.


reasoning: The paragraph describes the oversight structure with the board delegating cybersecurity to a management-led committee headed by the CEO, making Management Role the primary category. It contains specific facts like the named CEO and committee, qualifying as Firm-Specific.


reasoning: The paragraph centers on the Board and Audit Committee's oversight delegation and identifies specific cybersecurity management titles, fitting Board Governance with firm-specific organizational details.


reasoning: The paragraph focuses on the board of directors receiving presentations on cybersecurity risks from senior management, which is a clear example of board oversight and governance. It contains no specific dates, roles, frameworks, or verifiable facts, making it generic boilerplate that could apply to any company.


reasoning: The paragraph is a materiality conclusion stating that no cybersecurity incidents have materially affected the company, accompanied by a forward-looking disclaimer and a cross-reference to Risk Factors, which aligns with Strategy Integration per the tiebreakers.


reasoning: The paragraph focuses on the materiality assessment of cybersecurity threats, concluding no material effects since 2017, with a brief mention of specific past incidents to support this conclusion.


reasoning: The paragraph focuses on the company's continual evaluation of cybersecurity risks, which is a core aspect of internal risk management processes. It contains no specific details, frameworks, or verifiable facts, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes through the IT Steering Committee's functions and quarterly reporting to the Risk Management committee, which are firm-specific organizational details.


reasoning: The paragraph describes the company's own internal cybersecurity processes and safeguards, such as training and incident response, with no specific verifiable facts or named standards.


reasoning: The paragraph focuses on the audit committee's cybersecurity sub-committee and its oversight activities, which aligns with Board Governance. It includes specific cybersecurity roles (CIO and CISO), making it Firm-Specific.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks integrated into enterprise risk management, but contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph describes the qualifications, experience, and roles of specific management positions (CISO, CTO, Head of IT Infrastructure), which aligns with the Management Role category.


reasoning: The paragraph's central topic is overseeing cybersecurity risks from third parties like vendors and service providers, which aligns with the Third-Party Risk category. It contains no specific facts such as named frameworks, dates, or entities, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes internal management committees and their processes for cybersecurity risk oversight, such as reviewing controls and monitoring threats, which is central to the company's risk management activities.


reasoning: The paragraph focuses on the roles and responsibilities of the COO and Senior Vice President for Operations in cybersecurity management, which is characteristic of Management Role. It contains no verifiable facts, named standards, or unique details, making it generic boilerplate.


reasoning: The paragraph focuses on a materiality assessment of cybersecurity risks and incidents, which is central to Strategy Integration. It contains two specific, verifiable time periods (fiscal 2025 and fiscal 2026), meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's internal cybersecurity risk management approach and policy implementation, which aligns with the Risk Management Process category. It contains no specific facts, frameworks, or verifiable details, making it generic boilerplate.


reasoning: The paragraph centers on third-party vendor oversight, including onboarding and monitoring processes, which aligns with the Third-Party Risk category.


reasoning: The paragraph primarily delivers a materiality assessment stating that no cybersecurity incidents have materially affected the company, which aligns with Strategy Integration. The reference to risk monitoring processes is generic and does not describe specific internal procedures.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as implementing security technologies and disaster recovery, without focusing on board governance, management roles, or a specific incident. It contains no verifiable facts specific to the company, using only generic language applicable to any organization.


reasoning: The paragraph centers on third-party provider compliance with SSAE audits, indicating vendor oversight, and references a recognized standard without any company-specific details.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including risk assessments, team responsibilities, and incident response planning, with no specific facts or verifiable details.


reasoning: The paragraph describes the company's own internal processes for identifying, assessing, and managing cybersecurity risks, which aligns with Risk Management Process. It contains no specific dates, names, numbers, or standards, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on the functions of a specific internal committee (Engineering Risk Steering Group) in overseeing risk decisions, monitoring controls, and reviewing compliance approaches, which aligns with internal risk management processes rather than board governance or management roles.


reasoning: This paragraph is a standalone materiality conclusion stating no cybersecurity incidents have materially affected the company, which is a boilerplate disclaimer common in SEC filings, with no specific details about incidents, governance, or processes.


reasoning: The paragraph describes the Board of Directors and Audit Committee's oversight of cybersecurity risk management, with no specific details about processes, incidents, or management roles, fitting the Board Governance category.


reasoning: The paragraph describes the company's internal processes for integrating cybersecurity risk into overall risk management, including activities like assessments, audits, and training, which fits the Risk Management Process category. It contains no specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity programs focused on identifying threats and managing risks, which is central to Risk Management Process, and it names the NIST framework but contains no other firm-specific details.


reasoning: The paragraph describes the CISO presenting quarterly reports to the Risk Committee, which is a board-level committee overseeing cybersecurity, indicating board governance and oversight.


reasoning: The paragraph focuses on the company's internal cybersecurity processes and general threat landscape, aligning with risk management, and contains no specific verifiable facts or named standards, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including reporting structures, committee oversight, and integration into enterprise risk management, with specific roles and named committees indicating firm-specific details.


reasoning: The paragraph focuses on potential material adverse effects of cybersecurity incidents on business operations and financial condition, which is a strategic risk assessment. It contains no verifiable facts or unique details, making it generic boilerplate.


reasoning: The paragraph describes a specific past cybersecurity incident (2021 ransomware attack) with details on unauthorized data access and resulting litigation, which aligns with the Incident Disclosure category.


reasoning: The paragraph provides a materiality conclusion about the absence of past cybersecurity incidents and discusses potential future business impacts, which fits Strategy Integration. It contains no specific dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph describes the company's cybersecurity monitoring and scanning processes, which are internal risk management activities, but contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph contains a materiality conclusion about cybersecurity incidents and threats without describing any actual event, which aligns with Strategy Integration per tiebreakers. All statements are generic boilerplate with no specific facts, dates, or named entities.


reasoning: The paragraph is a hypothetical risk statement listing potential consequences of a cybersecurity incident without describing any actual events, processes, or company-specific details, making it a generic forward-looking disclaimer with no substantive disclosure.


reasoning: The paragraph focuses on the potential business and financial impacts of cybersecurity threats, including a materiality conclusion about past incidents, which aligns with Strategy Integration. It contains no specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's use of a specific tool, Coalition Control, for monitoring and detecting cybersecurity risks, which is a core internal risk management process.


reasoning: The paragraph centers on the audit committee receiving updates on cybersecurity oversight, which is a board governance function, and it lacks any specific dates, names, or verifiable facts unique to the company.


reasoning: The paragraph describes the CEO's role in providing briefings to the Audit Committee on cybersecurity risks, which centers on a management function. It lacks any specific dates, named entities, or verifiable details, rendering it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for cybersecurity risk oversight, including management roles overseeing risk management, receiving updates, and implementing an incident response plan, which fits Risk Management Process. It contains no unique facts such as specific dates, names, or numbers, making it generic boilerplate applicable to any company.


reasoning: The paragraph discusses the potential material impact of cybersecurity threats on business strategy and financial condition, which aligns with Strategy Integration. It contains no specific facts, named entities, or verifiable details, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal risk management processes, including a third-party service provider management program and specific departmental involvement in contract reviews, which aligns with Risk Management Process rather than standalone Third-Party Risk due to the focus on internal procedures.


reasoning: The paragraph identifies the CISO and details their qualifications, experience, and supporting team, which centers on management roles rather than processes or oversight. It contains multiple verifiable facts such as years of experience, educational background, and named certifications, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's internal Enterprise Risk Management Program and incident response processes, which are core elements of risk management, and lacks any specific dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph describes the internal process of the Director of Compliance reporting to the Board on cybersecurity risks, which aligns with risk management processes. It lacks any specific dates, names, or verifiable details, making it generic boilerplate.


reasoning: The paragraph focuses on the company's internal processes for cybersecurity incident detection, assessment, and response, which aligns with Risk Management Process. The mention of the VP of IT role provides a firm-specific detail, though no other verifiable facts are present.


reasoning: The paragraph primarily describes the company's internal risk management processes, including testing, assessments, and monitoring, led by a specific management role, with no incident disclosure or financial strategy focus.


reasoning: The paragraph describes the expected oversight role of the Board of Directors and management's quarterly reporting on cybersecurity, which aligns with Board Governance. It is entirely forward-looking and generic, with no specific details, frameworks, or verifiable facts.


reasoning: The paragraph states that no cybersecurity incidents had a material impact and refers to risk factors, which is a materiality assessment under Strategy Integration. The specific date (December 31, 2023) qualifies it as Firm-Specific.


reasoning: The paragraph focuses on management roles and committees overseeing cybersecurity, with specific titles (CTO) and named non-generic committees (ERM and Cybersecurity committees), indicating firm-specific details in a management governance context.


reasoning: The paragraph describes the company's internal cybersecurity program, controls, and procedures based on the NIST framework, which aligns with risk management processes rather than governance, roles, or incidents.


reasoning: The paragraph contains a standalone materiality conclusion and a forward-looking disclaimer, which are characteristic of Strategy Integration, and lacks any specific details such as dates, names, or frameworks, making it Generic Boilerplate.


reasoning: The paragraph focuses on the Audit Committee's oversight of cybersecurity risks and management's quarterly reports to it, which is a standard board governance disclosure without any firm-specific details.


reasoning: The paragraph provides a materiality conclusion for cybersecurity incidents in 2024 without describing any actual event, which fits Strategy Integration, and the specific year makes it Firm-Specific.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes, with oversight responsibilities mentioned as a supporting detail, fitting the Risk Management Process category. It contains no verifiable facts, named standards, or unique details, making it Generic Boilerplate.


reasoning: The paragraph describes committees established by the board for cybersecurity oversight, with specific internal governance structures and reporting lines to the board, fitting 'Board Governance'. It contains named committees and roles, making it firm-specific.


reasoning: The paragraph focuses on the company's internal cybersecurity monitoring and incident response processes, with the InfoSec Director as the lead, aligning with Risk Management Process. It includes specific roles and named entities like FS-ISAC, making it Firm-Specific.


reasoning: The paragraph describes board and committee oversight of cybersecurity risk, which is a standard governance topic without any firm-specific details or verifiable facts.


reasoning: The paragraph describes the company's internal cybersecurity processes, including vulnerability scans and third-party assistance, which aligns with Risk Management Process, and contains no verifiable facts or named standards, making it generic boilerplate.


reasoning: This paragraph is a cross-reference to the Risk Factors section and contains no substantive cybersecurity disclosure, merely listing generic risks without describing processes, incidents, or governance details.


reasoning: The paragraph describes a process to ensure management is informed about cybersecurity posture and risks, which aligns with internal risk management processes. It contains no specific facts, named standards, or verifiable details, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on the company's internal processes for risk assessment, safeguard implementation, and monitoring, with delegation to a specific cybersecurity-related role, fitting Risk Management Process and Firm-Specific due to the named title.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including integration into enterprise risk management and use of the NIST CSF framework, with no focus on board, management roles, incidents, or third parties.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks, including safeguard redesign, implementation, and monitoring, with responsibility assigned to an IT consultant, which aligns with Risk Management Process.


reasoning: The paragraph primarily focuses on the management team's composition, responsibilities, and qualifications for cybersecurity oversight, with specific roles identified, making it Management Role and Firm-Specific.


reasoning: The paragraph states a materiality conclusion for cybersecurity threats in 2024, which is a standalone assessment of business impact without describing an incident, fitting Strategy Integration. The specific date 'In 2024' makes it Firm-Specific, as it is a verifiable fact unique to the company's disclosure.


reasoning: The paragraph focuses on the company's internal cybersecurity processes, including risk integration and incident response planning, with no mention of board oversight, specific management roles, actual incidents, or verifiable details.


reasoning: The paragraph describes the company's internal cybersecurity program processes, such as quarterly reviews and benchmarking to the ISO framework, which aligns with Risk Management Process. It names a recognized standard (ISO) but contains no unique company-specific details, making it Sector-Adapted.


reasoning: The paragraph describes an actual cybersecurity incident with details on unauthorized access, data exfiltration, public release, and response actions, which directly matches the Incident Disclosure category.


reasoning: The paragraph primarily provides a materiality assessment of cybersecurity risks, stating no material impact from past incidents but potential future impact, which aligns with Strategy Integration. It contains no specific verifiable facts, frameworks, or unique details, making it Generic Boilerplate.


reasoning: The paragraph describes management-led cybersecurity risk assessment and mitigation processes, with the third-party partner's experience duration as a specific firm detail, aligning with Risk Management Process.


reasoning: The paragraph's central topic is the cybersecurity risks arising from third-party service providers and the company's monitoring of those risks, which directly aligns with the Third-Party Risk category.


reasoning: The paragraph focuses on the CISO's qualifications, experience, and reporting structure, with specific dates and tenure details, making it centered on management roles rather than board oversight or processes.


reasoning: The paragraph describes the company's internal cybersecurity policies and incident response processes, which are generic and lack specific, verifiable details such as dates, names, or quantifiable facts.


reasoning: The paragraph describes a generic process for monitoring IT systems and handling incident identification, which aligns with internal risk management procedures. It contains no specific details, names, or verifiable facts, making it boilerplate language applicable to any company.


reasoning: The paragraph's central topic is the oversight and management of third-party service providers, including obtaining SOC-1 reports and limiting access, which directly aligns with vendor security oversight.


reasoning: The paragraph primarily describes the company's internal risk management processes, such as management implementing structures and a cybersecurity organization, with no specific verifiable facts or named entities, making it generic boilerplate.


reasoning: The paragraph focuses on management roles (IT Team Director, CFO, CEO, General Counsel) discussing cybersecurity risks and incident reporting, which is centered on management involvement rather than processes or board oversight.


reasoning: The paragraph primarily describes the company's internal risk management processes, including vulnerability assessments and enterprise risk assessments, which are overseen by the CISO, aligning with the Risk Management Process category.


reasoning: The paragraph centers on the board's responsibility for cybersecurity oversight and names specific board members with expertise, fitting Board Governance and Firm-Specific due to unique identifiers.


reasoning: The paragraph identifies the CISO and CTO as key management roles and details their cybersecurity responsibilities, including reporting to the Risk Committee, making management roles the central focus.


reasoning: The paragraph focuses on the company's internal processes for assessing, identifying, and managing cybersecurity risks, with no specific board or management roles as the main subject. It includes one specific date, making it Firm-Specific but not Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity processes, including governance, technical safeguards, incident response, and third-party risk management, which is central to Risk Management Process. It is Firm-Specific due to the reference to the specific role of Vice President of Information Technology.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, which is the focus of Risk Management Process. It contains no specific facts, named standards, or verifiable details, making it generic boilerplate.


reasoning: The paragraph details the qualifications and backgrounds of management personnel, with the CISO being a cybersecurity-specific role, making it Firm-Specific under the Management Role category.


reasoning: The paragraph focuses on the Board of Directors' oversight responsibilities, including annual policy review and a board member with specific cybersecurity expertise, which is central to Board Governance.


reasoning: The paragraph focuses on the Board of Directors' oversight responsibility and specifically names the Risk and Information Security Committee as bearing primary responsibility for cybersecurity risk oversight, fitting the Board Governance category with a firm-specific committee detail.


reasoning: The paragraph focuses on the CIO and Vice President of Information Security, detailing their roles and qualifications, which aligns with the Management Role category as it describes the individuals responsible for cybersecurity.


reasoning: The paragraph describes internal cybersecurity training programs and annual insurance purchase, which are common risk management activities, but lacks any specific details like dates, amounts, or named entities.


reasoning: The paragraph describes the company's internal processes for integrating cybersecurity risk management, including collaboration between teams and specific roles, without focusing on board oversight, incident details, or financial impacts.


reasoning: The paragraph describes the company's internal cybersecurity processes, including monitoring, incident response, and employee training, with no specific details, making it a generic description of risk management activities.


reasoning: The paragraph describes the company's internal risk management process by adopting a named cybersecurity framework, which is a standard practice in the sector without unique firm-specific details.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight role in cybersecurity, with management roles mentioned in a reporting capacity, fitting Board Governance. It is Firm-Specific because it identifies a unique management title (Vice President of Strategic Initiatives) involved in cybersecurity oversight, though no hard verifiable facts like dates or amounts are present.


reasoning: The paragraph describes an actual cybersecurity incident involving exfiltration of information and ongoing investigation, fitting the Incident Disclosure category. It lacks any specific dates, names, or verifiable details, making it generic boilerplate.