reasoning: The paragraph provides generic introductory context about the company's reliance on IT systems and data, without describing any substantive cybersecurity measures, governance, or strategy.


content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: The paragraph consists entirely of hypothetical risk factor language without describing any actual cybersecurity measures, processes, or assessments, placing it in None/Other. It lacks any domain-specific terminology, firm-specific details, or verifiable facts, resulting in Generic Boilerplate specificity.

provider: google

stage: benchmark


content_category: Board Governance

fact: Technology Committee of our Board

fact: Information Security Policy

reasoning: The paragraph describes the Board of Directors' and the Technology Committee's oversight responsibilities regarding the information security program, making it Board Governance. The mention of the 'Technology Committee of our Board' and 'Information Security Policy' elevates the specificity to Firm-Specific.


content_category: Strategy Integration

reasoning: The paragraph makes a negative assertion regarding the historical occurrence of cybersecurity incidents, which falls under Strategy Integration. The language is entirely generic and lacks any domain-specific terminology, firm-specific details, or verifiable facts.


reasoning: The paragraph primarily explains the company's current lack of a formal cybersecurity program following an acquisition and references SEC transition guidance, lacking substantive cybersecurity disclosure.


content_category: Incident Disclosure

fact: DNS

fact: data exfiltration

reasoning: The paragraph describes a specific, historical cybersecurity incident, including its timeline, impact, and containment, making it an Incident Disclosure. The inclusion of a specific date ('May 2025') makes it Quantified-Verifiable.


content_category: Risk Management Process

fact: IASME Cyber Essentials framework

type: framework

fact: UK government Cyber Security NCSC

fact: NIST framework

reasoning: The paragraph describes the company's risk assessment methodology and framework adoption, placing it in Risk Management Process. It includes specific cybersecurity frameworks like IASME Cyber Essentials, ISO 27001, and NIST, making it Domain-Adapted.


reasoning: The paragraph consists of introductory boilerplate defining cybersecurity threats and expressing a general commitment to security, without detailing any specific processes, governance structures, or actual impacts.


content_category: Management Role

reasoning: The paragraph primarily describes the responsibilities of the management team in overseeing cybersecurity and coordinating with external IT specialists, fitting the Management Role category. The text relies entirely on generic business and risk management terminology without any specific domain terms, named roles, or verifiable facts, resulting in a Generic Boilerplate specificity level.


reasoning: The paragraph describes the overarching goals and focus of the company's information security program, aligning it with Risk Management Process. The use of the foundational cybersecurity concept 'confidentiality, integrity, and availability' (the CIA triad) elevates the specificity to Domain-Adapted.


reasoning: The paragraph solely discusses external regulatory requirements (SEC rules and banking agency oversight) and provides a cross-reference to another section, containing no substantive cybersecurity disclosures about the company's own program.


reasoning: The paragraph describes the use of third-party consultants and technology as part of the company's cybersecurity program, which falls under Risk Management Process. The language is entirely generic without specific domain terms, firm-specific details, or verifiable facts.


reasoning: The paragraph primarily describes the board and audit committee's oversight of cybersecurity risks and the reporting structure from management, fitting Board Governance. Specificity is Firm-Specific due to the mention of the vice president of information technology services leading the program.


fact: email spoofing

reasoning: The paragraph describes a specific historical cybersecurity incident, including its nature, detection, and impact, making it Incident Disclosure. The inclusion of a specific date (May 2014) makes it Quantified-Verifiable.


fact: ransomware

fact: encrypt systems

reasoning: The paragraph explicitly states a conclusion about the material impact of past cybersecurity incidents on the company's business strategy and financial condition, placing it in Strategy Integration. The specificity is Domain-Adapted due to the use of cybersecurity-specific threat terminology like 'ransomware' and 'encrypt systems'.


fact: Information Technology Committee

fact: Chief Information Security Officer (CISO)

fact: penetration test

reasoning: The paragraph describes the board's oversight structure, including the Information Technology Committee and reporting from the CISO, making it Board Governance. Specificity is Firm-Specific due to the named committee and CISO role.


fact: Steering Committee

category_confidence: medium

reasoning: The paragraph primarily describes the responsibilities and oversight activities of a specific management-level group (the Steering Committee) in monitoring the cybersecurity program. The mention of the specific 'Steering Committee' elevates the specificity to Firm-Specific.


reasoning: The paragraph is a purely introductory boilerplate statement that does not describe any substantive cybersecurity measures, processes, or governance structures, warranting a None/Other classification.


fact: Cyber Risk Committee

fact: CIO

fact: more than twenty years of experience

type: quantified

fact: since 2007

fact: virtual Chief Information Security Officer

reasoning: The paragraph primarily details management's organizational structure for cybersecurity, including the Cyber Risk Committee and the CIO's responsibilities and qualifications. It reaches Quantified-Verifiable specificity by stating the CIO has more than twenty years of experience and has held the role since 2007.


reasoning: The paragraph consists of generic, forward-looking statements about potential cybersecurity threats and their possible material adverse effects without describing any actual cybersecurity processes, governance, or strategy integration, thus falling into None/Other.


fact: Chief Information Security Officer

reasoning: The paragraph details a specific, actual email spoofing incident, including its timeline, financial impact, and remediation steps, making it an Incident Disclosure. It contains multiple verifiable facts such as specific dates, times, and a precise dollar amount lost.


content_category: Third-Party Risk

reasoning: The paragraph focuses exclusively on the oversight and evaluation of third-party service providers, making it Third-Party Risk. It includes the domain-specific term 'System and Organization Controls reports' (SOC reports), elevating the specificity to Domain-Adapted.


fact: penetration testing

fact: vulnerability scanning

reasoning: The paragraph describes the company's cybersecurity program activities, specifically training, testing, and vulnerability remediation, placing it in Risk Management Process. The specificity is Domain-Adapted due to the use of cybersecurity-specific terms like penetration testing and vulnerability scanning.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity incidents on the company's business strategy and financial condition, which falls under Strategy Integration. It contains only generic boilerplate language and a cross-reference to risk factors, lacking any domain-specific, firm-specific, or verifiable facts.


reasoning: The paragraph briefly describes the board and management's intention to meet periodically to assess the situation, which falls under board oversight, though it lacks any specific details.


fact: Cybersecurity Committee

fact: senior IT executive

fact: ten years of cybersecurity experience

fact: thirty-five years of experience in various technology domains

reasoning: The paragraph describes management's role in overseeing cybersecurity, including specific committees and executive qualifications. The specificity is Quantified-Verifiable due to the exact years of experience provided for the senior IT executive.


fact: Head of Information Technology for Latin America

fact: 25 years of experience

reasoning: The paragraph describes the qualifications and responsibilities of a specific management role overseeing cybersecurity, fitting the Management Role category. It includes a verifiable quantified fact (25 years of experience) which elevates the specificity to Quantified-Verifiable.


reasoning: The paragraph is entirely a cross-reference to the Risk Factors section in Item 1A, containing no substantive cybersecurity disclosure, and thus falls under None/Other with Generic Boilerplate specificity.


fact: Head of Resources Management

fact: CCO

fact: more than 20 years directly assessing and managing our cyber information technology

fact: more than 30 years of overall experience as a CPA

fact: more than 15 years managing information technology systems

reasoning: The paragraph primarily details the roles, responsibilities, and specific career experience of management personnel overseeing cybersecurity. It contains multiple verifiable claims regarding the exact years of experience and professional certifications (CPA) of these individuals.


reasoning: The paragraph discusses the company's cyber risk insurance and potential financial losses, which falls under Strategy Integration. It contains only generic boilerplate language with no specific details or domain terminology.


fact: December 13, 2023

fact: November 20, 2023

fact: malware that is not self-propagating

fact: exfiltrated

reasoning: The paragraph explicitly describes the timeline, nature, and scope of a specific past cybersecurity incident, placing it squarely in Incident Disclosure. The inclusion of exact dates for the investigation completion and last confirmed unauthorized activity makes the disclosure Quantified-Verifiable.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks and incidents on the company's business strategy and financial condition, placing it in Strategy Integration. It contains only negative assertions and a cross-reference, lacking any specific cybersecurity facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the Board of Directors and Audit Committee's oversight responsibilities for cybersecurity risk, placing it in Board Governance. It contains only generic boilerplate language with no domain-specific terminology, firm-specific details, or verifiable metrics.


fact: ransomware attack

reasoning: The paragraph explicitly describes a past cybersecurity incident (a May 2020 ransomware attack) and its ongoing legal impacts, fitting the Incident Disclosure category. The inclusion of a specific date for the attack makes it Quantified-Verifiable.


fact: CISO

fact: joined Workday in 2010

fact: served as our CISO since April 2018

fact: more than 15 years of experience

fact: degree in information systems management

reasoning: The paragraph focuses entirely on the CISO's responsibilities, tenure, and qualifications, which clearly falls under Management Role. It achieves Quantified-Verifiable specificity by including specific, checkable dates (joined in 2010, CISO since April 2018) and a quantified lower bound of experience (more than 15 years).


fact: 24/7 SIEM/SOC monitoring

fact: SIEM/SOC

fact: DNS

fact: forensic investigation

reasoning: The paragraph is classified as Incident Disclosure because it primarily details the remediation steps, forensic investigation, and operational recovery following a specific cybersecurity incident, with the incident frame dominating the brief materiality conclusion. The specificity is Firm-Specific due to the organizational claim of establishing '24/7' monitoring operations.


fact: threat intelligence

reasoning: The paragraph primarily describes the composition and oversight activities of the executive leadership team regarding cybersecurity, fitting the Management Role category. It includes domain terminology like 'threat intelligence', making it Domain-Adapted.


fact: August 2021

fact: January 2023

reasoning: The paragraph primarily discusses the financial and legal impacts of past cybersecurity incidents, including costs and cyber liability insurance, fitting Strategy Integration. It includes specific, verifiable dates of these incidents (August 2021 and January 2023), elevating the specificity to Quantified-Verifiable.


fact: ISIRP

fact: System and Organization Control reports

reasoning: The paragraph focuses entirely on the oversight and management of third-party cybersecurity risks, including vendor due diligence, contractual covenants, and ongoing monitoring. Specificity is Firm-Specific due to the reference to the company's specific 'ISIRP' program.


reasoning: The paragraph is a generic introductory statement about the company's commitment to security and contains no substantive cybersecurity disclosure.


fact: Chief Information Security Officer

reasoning: The paragraph describes the overall governance and oversight structure of the cybersecurity program, spanning from the risk framework to the CISO and up to the Audit Committee. The specificity is Firm-Specific because it explicitly names the Chief Information Security Officer role.


reasoning: The paragraph describes the Board of Directors' oversight of cybersecurity risk and its delegation to the Audit Committee, which falls under Board Governance. The language consists entirely of generic boilerplate without any domain-specific terminology, firm-specific details, or verifiable metrics.


fact: Risk Management Committee of the Board of Directors

fact: Annual IT Program Status Report

fact: Vulnerability Reports

reasoning: The paragraph describes the oversight responsibilities of the Board's Risk Management Committee, including the specific reports it reviews, which clearly falls under Board Governance. The inclusion of specific internal report titles like the 'Annual IT Program Status Report' and 'Quarterly Internal Vulnerability Reports' makes the disclosure Firm-Specific.


reasoning: The paragraph explicitly states conclusions regarding the material impact of cybersecurity incidents and risks on the company's strategy and financial condition, fitting the Strategy Integration category. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph explicitly states a conclusion regarding whether cybersecurity risks have materially affected or are reasonably likely to materially affect the company's business strategy and financial condition, which falls under Strategy Integration. The text consists entirely of generic materiality assessments, boilerplate risk language, and cross-references, containing no specific cybersecurity facts.


reasoning: The paragraph focuses exclusively on the company's approach to managing cybersecurity risks associated with third-party vendors and systems, making it a clear fit for Third-Party Risk. The language used is entirely generic and lacks any specific domain terminology, firm-specific details, or verifiable facts.


fact: posture and intelligence reviews

reasoning: The paragraph focuses exclusively on managing cybersecurity risks associated with third-party vendors, including vendor evaluations and embedding controls in SLAs. The specificity is Domain-Adapted due to the use of specialized terms like open-source intelligence risk assessments.


fact: management committee on cybersecurity

reasoning: The paragraph primarily describes the responsibilities and reporting structure of management-level roles, specifically the Senior Director and Head of Information Technology and the management committee on cybersecurity. The specificity is Firm-Specific due to the naming of these specific management roles and committees.


reasoning: The paragraph focuses exclusively on the oversight of third-party service providers and the contractual requirements imposed on them to manage cybersecurity risks. It contains only generic descriptions of these processes without any domain-specific terminology or firm-specific details.


reasoning: The paragraph is a generic introductory statement about the company's reliance on technology and third-party systems, containing no substantive cybersecurity measures, processes, or governance details.


fact: December 13, 2023

fact: November 20, 2023

fact: malware that is not self-propagating

fact: exfiltrated

reasoning: The paragraph details the timeline, scope, and findings of a specific cybersecurity incident, making it Incident Disclosure. It includes verifiable dates (December 13, 2023, and November 20, 2023) for the investigation and unauthorized activity, elevating the specificity to Quantified-Verifiable.


fact: Chief Technology Officer (CTO)

fact: Chief Information Security Officer (CISO)

fact: vulnerability assessments

reasoning: The paragraph describes the Board and Audit Committee's oversight of cybersecurity risks and the reporting cadence from management, fitting Board Governance. Specificity is Firm-Specific due to the explicit mention of the CTO and CISO roles.


fact: Chief Technology Officer

fact: Executive Vice President – Operations

fact: technology services team

reasoning: The paragraph describes the reporting structure and qualifications of management roles responsible for cybersecurity, specifically the CTO and EVP of Operations. It is classified as Firm-Specific due to the inclusion of specific executive titles and reporting lines.


reasoning: The paragraph is a pure cross-reference to the risk factors section (Item 1A) regarding the material effects of cybersecurity threats, containing no substantive cybersecurity disclosure itself.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks and incidents on the company's business strategy and financial condition, fitting the Strategy Integration category. It contains only generic boilerplate language with no domain-specific terminology, firm-specific details, or verifiable facts.


fact: Prudential's CISO

fact: CIO

fact: Operational Risk Management

reasoning: The paragraph describes the Board's oversight of cybersecurity risks, including periodic updates from specific management roles (CISO, CIO, Operational Risk Management), making it Board Governance. The specificity is Firm-Specific due to the mention of specific roles and teams providing updates to the Board.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of past cybersecurity incidents on the company's business strategy and financial condition, which falls under Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph primarily provides a materiality assessment concluding that cybersecurity risks and incidents have not materially affected the company's business strategy or financial condition, classifying it as Strategy Integration. The language is entirely generic with no specific domain terms, firm-specific details, or verifiable facts.


reasoning: The paragraph makes a negative assertion regarding the absence of material cybersecurity incidents, which falls under Strategy Integration. It contains no domain-specific terminology, firm-specific details, or externally verifiable facts, making it generic boilerplate.


fact: penetration testing

fact: managed detection and response services

fact: intrusion prevention and detection applications

reasoning: The paragraph is split between using third parties for internal security and managing third-party vendor risk, with the latter comprising the majority of the text. It includes domain-specific terminology like penetration testing and managed detection and response, but lacks firm-specific or verifiable facts.


reasoning: The paragraph makes a negative assertion regarding the historical material impact of cybersecurity incidents on operations and financial performance, which falls under Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph is a cross-reference to the Risk Factors section and contains generic boilerplate language about potential impacts of security breaches, lacking substantive cybersecurity program details.


reasoning: The paragraph explicitly describes management's role, responsibilities, and expertise in overseeing cybersecurity risks, placing it in the Management Role category. It relies entirely on generic corporate titles (COO, CCO) and standard risk management phrasing, lacking domain-specific terminology or firm-unique details.


fact: ransomware

fact: phishing attacks

fact: malware

reasoning: The paragraph primarily describes the company's general risk management processes, specifically monitoring networks to prevent and detect threats, while also including standard risk factor disclaimers. The specificity is Domain-Adapted due to the inclusion of specific cybersecurity threat types like ransomware and phishing.


reasoning: The paragraph consists entirely of forward-looking boilerplate warning about the potential impacts of hypothetical future cybersecurity incidents, without describing any substantive cybersecurity measures.


fact: executive incident team

fact: incident management team

fact: identifying, protecting from, detecting, responding to, and recovering from

reasoning: The paragraph primarily describes the company's incident response procedures, escalation paths, and testing exercises, which falls under Risk Management Process. It reaches Firm-Specific specificity by naming specific internal teams like the executive incident team.


reasoning: The paragraph makes a negative assertion regarding past cybersecurity incidents, which falls under Strategy Integration. It contains only generic risk statements and process descriptions without any domain-specific terminology, firm-specific details, or verifiable facts.


fact: National Institute of Standards and Technology Cybersecurity Framework (NIST CSF)

reasoning: The paragraph is classified as Risk Management Process because it describes the framework used to design and assess the company's cybersecurity program. The specificity is Domain-Adapted due to the mention of the NIST CSF, which demonstrates domain knowledge but is explicitly framed as a guide rather than a verifiable certification.


fact: CISO

reasoning: The paragraph primarily describes the Board and Audit Committee's oversight of cybersecurity risks, including reporting cadences and education. It is Firm-Specific due to the explicit mention of the CISO role.


reasoning: The paragraph explicitly states conclusions regarding the material impact of cybersecurity risks and incidents on the company's business strategy and financial condition, fitting the Strategy Integration category. It contains only boilerplate materiality assessments and cross-references, lacking any specific domain, firm-specific, or verifiable facts.


fact: layered security model

reasoning: The paragraph describes the company's information security program and its integration into the overall enterprise risk management program, which falls under Risk Management Process. The specificity is Domain-Adapted because it uses established cybersecurity concepts like the CIA triad (confidentiality, integrity, and availability) and layered security models.


fact: Executive Vice President of Technology

fact: over 16 years of experience

reasoning: The paragraph contains an explicit conclusion about the material impact of cybersecurity risks on the company (both backward-looking and forward-looking), making it Strategy Integration, while also detailing the specific management role and verifiable experience level of the executive responsible for oversight.


fact: During 2024

fact: early 2025

reasoning: The paragraph describes the company's risk management activities, specifically engaging third parties to conduct cyber risk assessments and upgrading the network. The specificity is Quantified-Verifiable due to the specific dates (2024, early 2025) associated with these assessments.


fact: over 30 years of industry experience

fact: joined Visa in November 2015

fact: Zero Trust Architecture

fact: VisaNet

fact: President of Technology

fact: joined Visa in November 2013

fact: over 30 years of experience

reasoning: The paragraph details the qualifications, tenure, and responsibilities of the CISO and President of Technology, fitting the Management Role category. Specificity is Quantified-Verifiable due to the inclusion of specific hire dates (November 2015, November 2013) and quantified years of experience (over 30 years).


reasoning: The paragraph explicitly states a conclusion regarding the material impact of prior cybersecurity incidents on the company's financial condition, which falls under Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business strategy and financial condition, placing it in Strategy Integration. It contains only generic boilerplate language and negative assertions without any specific domain terms or verifiable facts.


reasoning: The paragraph describes the board's oversight structure for cybersecurity, specifically delegating responsibility to the Risk Committee of the Board. It contains only generic governance language and standard board committee names, lacking specific domain terminology or firm-unique facts.


fact: Third Party Program

reasoning: The paragraph explicitly discusses the management of third-party risks. Specificity is Firm-Specific due to the reference to the company's specifically named 'Third Party Program'.


fact: October 28, 2023

fact: mid-December 2023

fact: $1.5 million of expenses

reasoning: The paragraph details the financial and operational impacts of a specific cybersecurity incident, including a $1.5 million expense, and concludes with a materiality assessment regarding business strategy and financial condition, aligning with Strategy Integration. The specificity is Quantified-Verifiable due to the inclusion of specific dates and exact financial figures.


fact: Information Security Departments

fact: service organization controls reports

reasoning: The paragraph focuses entirely on the company's third-party service provider management program and how vendor cybersecurity risks are assessed. Specificity is Firm-Specific due to the mention of the Information Security Department.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity threats on the company's business strategy and financial condition, aligning with Strategy Integration. It contains only generic boilerplate language with no domain-specific terms, firm-specific cybersecurity details, or verifiable facts.


reasoning: The paragraph details the financial and operational impacts of a specific cybersecurity incident, including a $1.5 million expense, and concludes with a formal materiality assessment regarding business strategy and financial condition.


fact: CISO

fact: Executive Steering Committee

fact: Executive Vice President, Engineering

fact: Senior Director, IT

reasoning: The paragraph primarily details the management-level organizational structure, including the CISO and the specific composition of the Executive Steering Committee, making it Management Role. The specificity is Firm-Specific due to the naming of specific management roles and committees involved in cybersecurity oversight.


reasoning: The paragraph describes the company's general efforts to develop its cybersecurity processes and response plan using external advisors, which falls under Risk Management Process. The language is entirely generic with no specific domain terms, firm-specific details, or verifiable facts.


fact: vulnerability scanning

fact: PCI DSS

fact: penetration testing

reasoning: The paragraph details specific cybersecurity assessment activities, such as vulnerability scanning and penetration testing, which fall under the risk management process. The specificity is Domain-Adapted due to the use of specialized cybersecurity terms and frameworks like PCI DSS and penetration testing.


reasoning: The paragraph is purely a cross-reference to a risk factor section regarding potential material impacts, containing no substantive cybersecurity program details.


fact: vulnerability assessments

fact: threat environment

reasoning: The paragraph describes the Board and Audit Committee's oversight of cybersecurity risks and their reporting cadence with management, fitting Board Governance. Specificity is Domain-Adapted due to the inclusion of cybersecurity-specific terms like vulnerability assessments.


fact: Chief Information Security Officer ("CISO")

fact: Chief Information Officer ("CIO")

fact: Information Security Department

fact: internal Technology and Operations Committee

fact: Management Committee

reasoning: The paragraph is classified as Management Role because it exclusively details the organizational structure, leadership roles (CISO, CIO), reporting lines, and management-level committees responsible for cybersecurity. The specificity is Firm-Specific due to the naming of specific internal roles, departments, and management committees.


reasoning: The paragraph is a pure cross-reference to the Risk Factors section and contains no substantive cybersecurity disclosure.


reasoning: The paragraph discusses the material impact of past cybersecurity challenges and the maintenance of a cyber liability insurance policy, both of which fall under Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable metrics, making it generic boilerplate.


reasoning: The paragraph primarily describes the Board's oversight of cybersecurity risks and the reporting structure from management to the Board. It is Firm-Specific due to the mention of the CISO role.


reasoning: The paragraph describes the Board of Directors' oversight of cybersecurity risk and the assisting role of the Audit Committee, placing it squarely in Board Governance. The language is entirely generic, lacking any domain-specific terminology, firm-unique details, or verifiable metrics.


reasoning: The paragraph describes employee training and awareness initiatives, which are core components of the risk management process. The language is entirely generic, lacking any domain-specific terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph describes employee security awareness training and the integration of cybersecurity into the enterprise risk management framework, which are core elements of the risk management process. The language is high-level and lacks specific domain terminology, firm-specific details, or verifiable metrics, resulting in a Generic Boilerplate classification.


reasoning: The paragraph explicitly focuses on the company's reliance on third-party service providers and its program to manage the associated cybersecurity risks. The language used is entirely generic and lacks any specific domain terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph explicitly focuses on the company's reliance on third-party service providers and its program to manage associated cybersecurity risks. The language is entirely generic, lacking specific domain terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph consists entirely of generic, forward-looking risk disclaimers about potential future breaches and their hypothetical material adverse effects, lacking substantive disclosure of actual cybersecurity measures or assessments.


fact: since the second half of 2021

reasoning: The paragraph primarily describes management's role by detailing the CFO's responsibility for overseeing the cybersecurity program, his lack of technical background, and his reliance on outside IT support. The specificity is Quantified-Verifiable because it provides a specific, verifiable timeframe (second half of 2021) for when the CFO assumed this oversight role.


reasoning: The paragraph explicitly states a conclusion about the lack of material impact from cybersecurity incidents on the company's business strategy and financial condition, fitting the Strategy Integration category. It contains only negative assertions and reporting periods, lacking any domain-specific, firm-specific, or verifiable cybersecurity facts.


fact: continuous system monitoring

fact: threat detection

reasoning: The paragraph describes the activities of the cybersecurity program, including system monitoring, threat detection, and third-party assessments, making it Risk Management Process. The specificity is Domain-Adapted due to the use of cybersecurity-specific terms like 'continuous system monitoring' and 'threat detection'.


fact: Chief Information Security Officer (CISO)

reasoning: The paragraph focuses on management's organizational structure by identifying the CISO and outlining their responsibilities. The specificity is Firm-Specific due to the explicit mention of the CISO role.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business strategy and financial condition, and mentions cyber insurance, placing it in Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph provides a high-level overview of the Fund's cybersecurity risk management processes, noting its reliance on the Adviser's cybersecurity program. The language consists entirely of generic boilerplate without any domain-specific terminology or firm-specific details.


reasoning: The paragraph explicitly focuses on assessing and managing cybersecurity threats associated with third-party service providers. The language is entirely generic, lacking any specific domain terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph is a generic, forward-looking risk disclaimer about potential system failures and does not describe any substantive cybersecurity processes, governance, or actual incidents.


reasoning: The paragraph describes the company's incident response and recovery planning and testing, which falls under the risk management process. The language is entirely generic and lacks any domain-specific terminology, firm-specific details, or verifiable metrics.


fact: threat assessments

reasoning: The paragraph describes the use of external consultants to evaluate and test the company's internal cybersecurity systems, which falls under Risk Management Process. The specificity is Domain-Adapted due to the mention of specific practices like threat assessments.


reasoning: The paragraph describes the use of third-party experts to assess internal cybersecurity controls, which falls under the risk management process. The language is entirely generic with no domain-specific terminology or firm-specific details.


fact: InfoSec Director

fact: eRISC committee

fact: CTO

reasoning: The paragraph describes the reporting chain and information flow from the InfoSec Director to the eRISC committee, executive management, and the Board, which falls under Board Governance. The specificity is Firm-Specific due to the mention of the named 'eRISC committee' and specific roles like the InfoSec Director and CTO.


fact: CISO

fact: more than 20 years of experience

fact: RACC

fact: CRO

reasoning: The paragraph primarily describes the governance reporting chain, detailing how the CISO and CRO report to and are overseen by the RACC. It achieves Quantified-Verifiable specificity by stating the CISO has a verifiable lower bound of more than 20 years of experience.


reasoning: The paragraph consists entirely of generic, forward-looking risk disclaimers without describing any actual cybersecurity measures, processes, or assessments.


fact: Chief Technology Officer

fact: Technology Leadership Centre

fact: Chief Risk Officer

fact: Risk Committee of the board of directors

fact: Controlling Department

reasoning: The paragraph describes the overarching cybersecurity governance structure using a three lines of defense model that integrates management roles and board committees. Specificity is Firm-Specific due to the naming of specific internal entities like the Technology Leadership Centre and specific executive roles.


reasoning: The paragraph primarily details how the board oversees cybersecurity, specifically describing the oversight responsibilities of the Advisory Committee of the Board of Managers and its reporting cadence. The specificity is Firm-Specific due to the identification of the specific committee structure handling this oversight.


reasoning: The paragraph focuses exclusively on the oversight of third-party service providers and suppliers through a vendor management program, fitting the Third-Party Risk category. The language is generic and lacks specific cybersecurity domain terms, firm-specific details, or verifiable metrics.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's financial position and operations, which falls under Strategy Integration. It contains only generic boilerplate language and cross-references without any specific cybersecurity details.


fact: do not carry a separate cybersecurity commercial insurance policy

reasoning: The paragraph explicitly discusses the material impact of cybersecurity incidents on the business strategy and financial condition, and notes the absence of a dedicated cybersecurity insurance policy, aligning with Strategy Integration.


reasoning: The paragraph focuses entirely on the requirements imposed on third-party service providers regarding security measures and breach reporting, placing it in Third-Party Risk. The language is entirely generic and lacks any specific domain terminology, firm-specific details, or verifiable metrics.


fact: penetration testing

fact: offensive testing

fact: cyber phishing tests

reasoning: The paragraph outlines the components of the cybersecurity program, including testing, third-party due diligence, incident response, and employee training, which falls under Risk Management Process. The specificity is Domain-Adapted due to the use of cybersecurity-specific terms like penetration testing and cyber phishing tests.


reasoning: The paragraph describes management's responsibility, specifically identifying the CEO as the primary figure responsible for managing cybersecurity threats under Audit Committee oversight. It contains only generic roles and boilerplate language, lacking any domain-specific terminology or firm-unique details.


reasoning: The paragraph details the responsibilities of management figures (CFO and Head of IT) in overseeing the cybersecurity program. It contains no domain-specific terminology or firm-specific facts, as 'Head of IT' is considered a generic title without a security qualifier.


reasoning: The paragraph primarily describes the board's oversight structure, specifically noting the lack of scheduled reporting to the board regarding cybersecurity. It contains no domain-specific terminology, firm-specific details, or verifiable metrics, making it generic boilerplate.


reasoning: The paragraph primarily discusses the company's reliance on a third-party accounting firm for its financial records and how management evaluates the cybersecurity protections of its service providers, which falls under Third-Party Risk. The language used is entirely generic, lacking any specific domain terminology, named roles, or verifiable facts.


fact: Chief Information Security Officer (CISO)

fact: since 2015

fact: application security

fact: intrusion detection

fact: complex threat modeling

fact: RCOC

reasoning: The paragraph focuses on the CISO's qualifications, team structure, and reporting responsibilities, fitting the Management Role category. It includes a verifiable fact regarding the CISO's tenure (since 2015), elevating the specificity to Quantified-Verifiable.


reasoning: The paragraph focuses exclusively on the company's approach to managing third-party cybersecurity risks, including vendor assessments and contractual requirements. The language is entirely generic, lacking any specific domain terminology, firm-specific details, or verifiable metrics.


fact: World Gold Council

reasoning: The paragraph describes how the Board of Directors oversees cybersecurity risks by receiving reports from the Sponsor's officers and the World Gold Council, making it Board Governance. The mention of the 'World Gold Council' is a verifiable named entity, elevating the specificity to Quantified-Verifiable.


fact: offsite backup storage

reasoning: The paragraph outlines the components of the company's cybersecurity risk management program, including risk assessments, backups, and training, placing it in Risk Management Process. The mention of 'offsite backup storage' provides domain-specific terminology, elevating the specificity to Domain-Adapted.


fact: National Institute of Standards and Technology Cybersecurity Framework (NIST CSF)

reasoning: The paragraph describes the framework used to design and assess the cybersecurity program, which falls under Risk Management Process. It mentions alignment with the NIST CSF, which is a domain-specific framework, but explicitly disclaims meeting verifiable technical standards, making it Domain-Adapted.


fact: incident detection, containment, response and remediation

fact: security incident response plan

reasoning: The paragraph outlines the company's procedures for handling cybersecurity incidents, which is a core component of the Risk Management Process. The specificity is Domain-Adapted because it uses specific cybersecurity incident response lifecycle terminology such as 'containment' and 'remediation'.


fact: Cybersecurity Steering Committee

fact: CISO

fact: one director is the President of a major cybersecurity services provider

reasoning: The paragraph primarily describes the flow of cybersecurity information to the Board of Directors and details the board's expertise, making it Board Governance. It reaches Quantified-Verifiable specificity because it states a verifiable fact about a board member's external employment as President of a cybersecurity services provider.


fact: CIO

fact: CIO's team

reasoning: The paragraph primarily describes the roles and responsibilities of management, specifically the CIO and their team, in implementing the cybersecurity program and reporting to the Board. The specificity is Firm-Specific due to the identification of the CIO as the key management role responsible for cybersecurity.


fact: malware

fact: viruses

reasoning: The paragraph provides general background information on the global cybersecurity threat landscape and common attack vectors, without describing the company's specific processes, governance, or incidents.


fact: ransomware attack

fact: class action lawsuit

reasoning: The paragraph primarily describes a specific historical cybersecurity incident (a 2021 ransomware attack) and its resulting legal consequences, making it Incident Disclosure. The specificity is Quantified-Verifiable due to the specific year of the attack and the verifiable existence of a class action lawsuit.


reasoning: The paragraph broadly describes the company's process of reviewing and updating systems and using third-party consultants to review attacks, which falls under risk management processes, though it relies entirely on generic boilerplate language.


fact: Chief Information Security Officer

fact: Chief Technology Officer

fact: Chief Operations Officer

fact: over 25 years' experience

reasoning: The paragraph focuses on the roles, reporting structure, and qualifications of management (CISO, CTO, COO), making it Management Role. It includes a verifiable claim regarding the CISO's 'over 25 years' experience', elevating the specificity to Quantified-Verifiable.


fact: risk management, legal, information technology, and compliance personnel of the Adviser

fact: Chief Compliance Officer (" CCO ")

reasoning: The paragraph primarily addresses how the company oversees cybersecurity risks associated with its third-party suppliers and vendors. It is classified as Firm-Specific because it details the specific departmental composition (risk management, legal, IT, and compliance personnel of the Adviser) responsible for this oversight.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity threats on the company's business strategy and financial condition, placing it in Strategy Integration. It contains only negative assertions and boilerplate disclaimers, resulting in Generic Boilerplate specificity.


fact: threat actor

reasoning: The paragraph describes a specific, actual cybersecurity incident, including its detection date and response actions, making it Incident Disclosure. The inclusion of the exact date (July 10, 2024) makes it Quantified-Verifiable.


reasoning: The paragraph introduces the company's cybersecurity risk management program and its risk assessment process, fitting the Risk Management Process category. It contains only generic language that fails the ERM test, resulting in Generic Boilerplate specificity.


reasoning: The paragraph explicitly focuses on the management of third-party risk, specifically detailing the due diligence and oversight of vendors and service providers. The language is entirely generic and lacks any domain-specific terminology or firm-specific details, resulting in a Generic Boilerplate specificity.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks and incidents on the company's business strategy and financial condition, aligning with Strategy Integration. It contains only generic SEC boilerplate language and negative assertions, resulting in a Generic Boilerplate specificity level.


fact: confidentiality, integrity and availability

reasoning: The paragraph introduces the company's cybersecurity risk management processes, fitting the Risk Management Process category. It includes the domain-specific concept of the CIA triad (confidentiality, integrity, and availability), making it Domain-Adapted.


reasoning: The paragraph concludes with a negative assertion regarding the occurrence of cybersecurity incidents in 2024, which classifies as Strategy Integration. The text contains only generic commitments and a non-verifiable negative assertion, resulting in Generic Boilerplate specificity.


fact: firewalls

fact: anti-malware functionality

fact: access controls

reasoning: The paragraph primarily describes the technical safeguards and third-party evaluations used in the company's cybersecurity program, which falls under Risk Management Process. The specificity is Domain-Adapted due to the use of specific cybersecurity terminology like firewalls, intrusion prevention and detection systems, and anti-malware functionality.


fact: vulnerability and patch management processes

fact: phishing tests

reasoning: The paragraph describes the activities, tools, and procedures that make up the company's cybersecurity program, clearly falling under Risk Management Process. The specificity is Domain-Adapted because it uses specialized cybersecurity terminology like intrusion detection and prevention systems, patch management, and phishing tests, but lacks firm-specific or externally verifiable details.


fact: October 3, 2024

reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity incidents on the company's financial condition and business strategy, aligning with the Strategy Integration category, while also containing a verifiable date of a specific incident.


fact: Bimini

reasoning: The paragraph primarily explains the company's risk management process by detailing its reliance on its external manager's information systems and cybersecurity processes. The specificity is Quantified-Verifiable because it explicitly names the external manager entity, Bimini, which is an externally verifiable fact.


fact: threat intelligence

fact: tactics, techniques, and procedures

fact: phishing exercises

fact: cybersecurity incident response plan ("CIRP")

reasoning: The paragraph details various components of the company's cybersecurity program, including threat intelligence, employee training, monitoring, and incident response, placing it in Risk Management Process. The specificity is Firm-Specific due to the inclusion of the specific internal acronym 'CIRP' for their incident response plan.


reasoning: The paragraph describes the reporting of cybersecurity risks and incidents from management to a board committee, which falls under Board Governance. The language is entirely generic with no specific domain terms, firm-specific details, or verifiable metrics.


reasoning: The paragraph consists entirely of a generic disclaimer about threat severity and a cross-reference to the Risk Factors section, containing no substantive cybersecurity disclosure.


reasoning: The paragraph merely lists generic types of cybersecurity risks and references SEC regulations without describing any actual cybersecurity measures, processes, or governance structures.


fact: interrupted manufacturing at our domestic plants and delayed order fulfillment for our retail network and delay of some wholesale shipments

reasoning: The paragraph describes the operational impact and recovery timeline of a specific cybersecurity incident, placing it in Incident Disclosure. The specificity is Firm-Specific due to the detailed description of the incident's impact on the company's manufacturing, retail, and wholesale operations.


fact: chief information security officer

reasoning: The paragraph describes the reporting structure and frequency of cybersecurity updates from the CISO to the Audit Committee, which falls under Board Governance. The explicit mention of the 'chief information security officer' role elevates the specificity to Firm-Specific.


reasoning: The paragraph outlines the general components of the company's cybersecurity risk management program, including risk assessments, training, and incident response. It lacks specific domain terminology, firm-specific details, or verifiable metrics, making it generic boilerplate.


reasoning: The paragraph provides a high-level, concluding summary of the company's cybersecurity program components (assessments, certifications, reporting structure) without providing substantive details, making it generic boilerplate.


reasoning: The paragraph explicitly discusses the Board's oversight role and the board members' lack of relevant expertise, which falls squarely under Board Governance. The language used is entirely generic without any domain-specific terminology, firm-specific details, or verifiable metrics.


fact: encryption and authentication technology

fact: threat intelligence service providers

fact: penetration testing firms

fact: Response, eradication and recovery

reasoning: The paragraph describes the use of third-party services and tools as components of the company's cybersecurity risk management program, fitting the Risk Management Process category. It includes domain-specific terminology like penetration testing and threat intelligence, but lacks firm-specific or verifiable details.


reasoning: The paragraph describes the oversight responsibilities of the Board of Directors and the audit committee regarding cybersecurity risks, placing it squarely in Board Governance. The language relies entirely on generic governance terms and cadences without any domain-specific terminology or firm-unique details, resulting in a Generic Boilerplate specificity.


reasoning: The paragraph is solely a cross-reference to the Risk Factors section and contains no substantive cybersecurity disclosure.


reasoning: The paragraph discusses the potential impact of cybersecurity risks and makes a negative assertion about experiencing incidents, which falls under Strategy Integration. It contains only generic risk language and a reporting-anchored negative assertion, resulting in Generic Boilerplate specificity.


fact: continuous monitoring

fact: investigation and remediation

reasoning: The paragraph primarily describes the use of third-party services and tools to support the company's internal cybersecurity risk management processes, with a secondary mention of vendor risk management. It includes domain terminology like 'continuous monitoring' but lacks firm-specific or verifiable details.


fact: forensic analysis

fact: Master's degree in Cybersecurity

reasoning: The paragraph focuses on the qualifications and experience of the cybersecurity leadership team, placing it in Management Role. It includes verifiable facts such as 'over 23 years of combined Cybersecurity experience' and a 'Master's degree in Cybersecurity', elevating the specificity to Quantified-Verifiable.


reasoning: The paragraph explicitly states a conclusion about the historical financial and operational impact of cybersecurity incidents, which falls under Strategy Integration. It contains only negative assertions and speculative boilerplate, lacking any domain-specific, firm-specific, or verifiable facts.


reasoning: The paragraph is a pure cross-reference directing the reader to the Risk Factors section in Item 1A, containing no substantive cybersecurity disclosures.


fact: tabletop exercises simulating potential cyber threats

reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity threats and incidents on the organization, which falls under Strategy Integration. The specificity is Domain-Adapted due to the mention of cyber threat tabletop exercises.


fact: National Institute of Standards and Technology ("NIST")

fact: International Organization for Standardization ("ISO")

fact: confidentiality, integrity, and availability

reasoning: The paragraph describes the company's risk assessment methodology and framework adoption, which falls under Risk Management Process. It includes domain-specific terminology like NIST, ISO, and the CIA triad, but lacks firm-specific or externally verifiable details, making it Domain-Adapted.


reasoning: The paragraph consists of generic boilerplate language, definitions of cybersecurity threats, and a cross-reference to the Risk Factors section, without detailing specific cybersecurity processes, governance, or actual impacts.


reasoning: The paragraph is entirely a cross-reference to the Risk Factors section and contains no substantive cybersecurity disclosures.


fact: SVP, Engineering

fact: VP, Technology & CISO

reasoning: The paragraph details the specific management roles (SVP, Engineering and VP, Technology & CISO) responsible for cybersecurity and describes their career experience, fitting the Management Role category. Specificity is Firm-Specific due to the exact executive titles provided.


reasoning: The paragraph focuses exclusively on the company's approach to managing cybersecurity risks associated with third parties, vendors, and service providers. It contains only generic language that could apply to any enterprise risk management program, resulting in a Generic Boilerplate specificity.


reasoning: The paragraph primarily discusses how third-party cyber risks are managed at the leadership level, specifically through a quarterly executive summary used for decisions on third-party engagements. The specificity is Firm-Specific due to the mention of the specific 'virtual Chief Information Security Officer (vCISO)' role.


reasoning: The paragraph describes the company's general processes for managing cybersecurity risks, including safeguards and the use of external consultants, placing it in Risk Management Process. The language is entirely generic and lacks any specific domain terminology, firm-specific details, or verifiable facts.


fact: GC Advisors

fact: threat landscape

reasoning: The paragraph describes the Board's oversight role and the flow of information from the CFO and CCO to the Board, placing it in Board Governance. The mention of the specific advisor entity 'GC Advisors' elevates the specificity to Firm-Specific.


reasoning: The paragraph provides general background information on the company's reliance on IT systems and software, lacking any substantive discussion of cybersecurity.


fact: Chief Information Officer

fact: Information Security Officer

fact: combined over 35 years of IT management experience

reasoning: The paragraph primarily details the responsibilities and qualifications of management roles (CIO and ISO), making it Management Role. It reaches Quantified-Verifiable specificity by stating a verifiable lower bound for the combined years of experience of these officers.


reasoning: The paragraph focuses entirely on the risks associated with third-party service providers and the company's limited ability to monitor their cybersecurity practices. It contains only generic boilerplate language without any specific domain terms, firm-specific details, or verifiable facts.


reasoning: The paragraph is entirely a cross-reference directing the reader to the Risk Factors section in Item 1A, containing no substantive cybersecurity program disclosure.


fact: hardening our environment, systems and infrastructure

reasoning: The paragraph primarily describes the company's risk management activities, including internal audits, system hardening, and employee training. The use of the cybersecurity-specific concept 'hardening' elevates the specificity to Domain-Adapted.


reasoning: The paragraph primarily describes the board's role in evaluating investments, overseeing compliance, and ensuring legal counsel for cybersecurity issues, making it Board Governance. The language is generic and lacks domain-specific terminology, firm-specific details, or verifiable facts.


reasoning: The paragraph consists entirely of generic, forward-looking risk factor language about potential hypothetical impacts of cybersecurity incidents, without describing any actual cybersecurity measures or processes.


fact: Cybersecurity Governance Board

reasoning: The paragraph primarily states a conclusion about whether cybersecurity threats have materially affected or are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which falls under Strategy Integration. The mention of the 'Cybersecurity Governance Board' elevates the specificity to Firm-Specific.


reasoning: The paragraph describes the integration of the cybersecurity risk management program into the broader enterprise risk management (ERM) framework, which falls under Risk Management Process. The language is entirely generic and lacks any domain-specific terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph consists entirely of forward-looking disclaimers, speculative risk statements, and a cross-reference to the Risk Factors section, containing no substantive cybersecurity disclosures.


reasoning: The paragraph primarily describes how the Board receives updates on cybersecurity frameworks and material incidents, making it Board Governance. The language is entirely generic with no specific frameworks, verifiable facts, or unique organizational details.


fact: CGNC

reasoning: The paragraph describes the responsibilities of senior management and business units in overseeing day-to-day operations and reporting incidents, fitting the Management Role category. The mention of the 'CGNC' (a specific committee acronym) elevates the specificity to Firm-Specific.


reasoning: The paragraph describes the company's approach to managing its cybersecurity program by outsourcing it to a third-party sub-contractor, which falls under Risk Management Process. The language is entirely generic with no specific domain terms, firm-specific details, or verifiable facts.


fact: Vice President of IT and Digital

fact: CISO

reasoning: The paragraph focuses on the ongoing education and knowledge acquisition of specific management roles (VP of IT and Digital, CISO), placing it in Management Role. Specificity is Firm-Specific due to the explicit naming of these executive titles.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business strategy and financial condition, and discusses cybersecurity insurance, which aligns with Strategy Integration. The language is entirely generic with no specific domain terms, firm-specific details, or verifiable metrics.


reasoning: The paragraph primarily outlines general cybersecurity risks and high-level mitigation measures like disaster recovery and backup systems, fitting the Risk Management Process category. The language consists entirely of generic risk factor boilerplate without any domain-specific terminology, firm-specific details, or verifiable facts.


reasoning: The paragraph primarily describes the company's risk management activities, specifically senior leadership's participation in incident response and the details of the employee security awareness training program. It contains only generic descriptions of these processes without specific domain terminology, firm-specific details, or verifiable metrics.


fact: SOC reports

fact: complementary controls

reasoning: The paragraph primarily discusses the oversight and management of risks associated with third-party service providers, making it Third-Party Risk. The specificity is Domain-Adapted due to the use of cybersecurity-specific terms like 'SOC reports' and 'complementary controls'.


fact: Chief Executive Officer

fact: Chief Financial Officer

fact: Audit Committee

fact: Board of Directors

reasoning: The paragraph primarily describes the roles and responsibilities of senior management (CEO, CFO) in assessing and managing cybersecurity risk, and their lack of direct cybersecurity expertise, making it Management Role. The specific facts listed (CEO, CFO, Audit Committee, Board of Directors) are generic roles/committees that exist at every company, so the specificity remains Generic Boilerplate.


reasoning: The paragraph is solely a cross-reference to the Risk Factors section in Item 1A, which falls under None/Other. Per the rules, None/Other paragraphs are always classified as Generic Boilerplate.


reasoning: The paragraph outlines the governance chain, starting with the Board's oversight responsibility and management's role in assessing risks, making it primarily about Board Governance. It contains only generic boilerplate language with no domain-specific terms, firm-specific roles, or verifiable facts.


fact: 21 CFR 11 (Part 11) compliant

fact: antivirus and antimalware software

reasoning: The paragraph focuses entirely on the company's reliance on and oversight of its Contract Research Organizations (CROs) for cybersecurity, making it Third-Party Risk. It includes a verifiable claim that the CRO's systems are 21 CFR 11 (Part 11) compliant, elevating the specificity to Quantified-Verifiable.


reasoning: The paragraph describes the board's oversight structure, specifically the audit committee's role and how management reports to it, which falls under Board Governance. The language is entirely generic with no domain-specific terminology, firm-specific details, or verifiable metrics.


fact: detect, triage and eradicate

specificity_confidence: medium

reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business strategy and financial condition, and mentions cyber insurance, placing it in Strategy Integration. Specificity is Domain-Adapted due to the use of incident response terminology ('triage and eradicate').


fact: not insured for damages

reasoning: The paragraph discusses the potential material adverse effect of incidents and explicitly states the company lacks cybersecurity insurance, which falls under Strategy Integration. The disclosure that they are not insured for cyber damages is a firm-specific detail regarding their risk transfer posture.


fact: vCIO

fact: MSP's Service Delivery Team

reasoning: The paragraph describes the specific responsibilities and reporting structure of the outsourced vCIO role, fitting the Management Role category. It is Firm-Specific because it identifies the specific organizational structure used by the company, including the vCIO role and the MSP's Service Delivery Team.


reasoning: The paragraph primarily focuses on managing risks associated with third-party service providers, making Third-Party Risk the dominant category despite a brief materiality statement at the end. The specificity is Domain-Adapted due to the use of specialized terms like SOC reports and complementary controls.


fact: protected health information

reasoning: The paragraph focuses entirely on the company's vendor qualification and management program and its reliance on third-party service providers, fitting the Third-Party Risk category. Specificity is Domain-Adapted due to the use of cybersecurity concepts like the CIA triad (confidentiality, integrity, or availability).


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity threats on the company's business strategy and financial condition, placing it in Strategy Integration. The language is entirely generic boilerplate with no specific domain terms, firm-specific details, or verifiable metrics.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's operations and financial results, placing it in Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable facts, resulting in a Generic Boilerplate specificity.


reasoning: The paragraph explicitly states a conclusion about the material impact of past threats on the business and financial condition, which falls under Strategy Integration. It contains only generic risk disclaimers and cross-references without any specific domain terminology or verifiable facts.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity threats on the company's business strategy and financial condition, aligning with Strategy Integration. It contains only generic boilerplate language and negative assertions without any specific domain terms, firm-specific details, or verifiable facts.


fact: active interactions with children's hospitals while assisting with insurance prior approvals

reasoning: The paragraph explicitly states conclusions regarding the material impact of cybersecurity threats on the company's business strategy and financial condition, placing it in Strategy Integration. The specificity is Firm-Specific due to the unique operational detail regarding their interactions with children's hospitals for insurance prior approvals.


reasoning: The paragraph states a conclusion about whether cybersecurity incidents have materially affected or are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which falls under Strategy Integration. It contains no domain terms, firm-specific facts, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph provides a backward-looking assessment that cybersecurity challenges have not materially impaired operations or financial standing, which falls under Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


fact: January 2021

fact: source code and the credentials used to access the information technology systems themselves had been compromised

fact: received a threat to publicly release these materials unless we made a payment

reasoning: The paragraph describes a specific past cybersecurity incident (January 2021), detailing the nature of the attack (compromised source code and credentials, extortion threat) and its potential impact, making it an Incident Disclosure. The inclusion of a specific date (January 2021) and specific details about the incident makes it Quantified-Verifiable.


reasoning: The paragraph is a generic disclaimer about past and future cybersecurity incidents and a cross-reference to the Risk Factors section, containing no substantive details about the company's cybersecurity program, governance, or specific incidents.


reasoning: The paragraph primarily discusses the company's management of third parties, detailing both the use of consultants for internal assessments and the security requirements (certifications, breach reporting) imposed on service providers. The language relies entirely on generic risk management terminology without any domain-specific cybersecurity terms, firm-specific details, or verifiable metrics, resulting in a Generic Boilerplate specificity level.


reasoning: The paragraph is entirely focused on managing cybersecurity risks associated with third-party service providers, including supply chain and contractual requirements, making it Third-Party Risk. The language used is generic and lacks any domain-specific terminology, firm-specific details, or verifiable facts, resulting in a Generic Boilerplate specificity level.


reasoning: The paragraph describes the Board's oversight of cybersecurity risks and delegation to the Audit Committee, fitting Board Governance. It contains only generic boilerplate language with no domain-specific terms, firm-specific roles, or verifiable metrics.


fact: monitor our information systems for potential vulnerabilities

reasoning: The paragraph primarily describes the company's cybersecurity risk management activities, including vulnerability monitoring, use of security tools, and third-party assessments, making it Risk Management Process. Specificity is Domain-Adapted due to the use of cybersecurity-specific concepts like vulnerability monitoring.


reasoning: The paragraph explicitly discusses the materiality of past incidents and the potential financial impact of future threats, aligning with Strategy Integration. It contains no domain-specific terminology, firm-specific details, or externally verifiable facts, making it generic boilerplate.


reasoning: The paragraph makes a negative assertion regarding the occurrence of material cybersecurity incidents and costs, which falls under Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph concludes with a definitive statement that the company has not encountered cybersecurity challenges that have materially impaired its operations or financial standing, which mandates a Strategy Integration classification. The text relies entirely on generic roles and boilerplate risk management language, lacking any domain-specific terminology or verifiable facts.


fact: penetration tests

fact: threat landscape

fact: risk register

reasoning: The paragraph describes the company's cybersecurity program activities, including security controls, risk-based architecture, risk register, and penetration testing, which falls under Risk Management Process. The specificity is Domain-Adapted due to the use of cybersecurity-specific terminology like 'penetration tests' and 'confidentiality, integrity and availability'.


fact: threat intelligence feeds

fact: vulnerability management

reasoning: The paragraph describes the company's incident response, vulnerability management, and training activities, which falls under Risk Management Process. The specificity is Domain-Adapted due to the use of cybersecurity-specific terminology like 'threat intelligence feeds' and 'vulnerability management'.


fact: Chief Information Security Officer (CISO)

fact: over 30 years of experience in cybersecurity

fact: United States Navy

fact: Amgen

fact: Warner Bros

fact: KPMG

fact: Forrester

reasoning: The paragraph is entirely focused on the CISO's responsibilities and career history, placing it squarely in Management Role. The specificity is Quantified-Verifiable due to the specific number of years of experience and the explicitly named former employers (Amgen, Warner Bros, KPMG, Forrester).


fact: IT Committee

fact: Executive Vice President and Chief Accounting Officer ("CAO")

fact: Co-Chief Operating Officer ("COO")

reasoning: The paragraph primarily describes how management informs the Board on cybersecurity risks, the frequency of briefings, and the Board's active participation in strategic decisions, making it Board Governance. The specificity is Firm-Specific due to the naming of the IT Committee and specific executive roles like the Senior Vice President of Information Technology.


reasoning: The paragraph provides a backward-looking assessment that cybersecurity challenges have not materially impaired operations or financial standing, which falls under Strategy Integration. The text contains only generic boilerplate language and negative assertions without any specific domain terms, firm-specific details, or verifiable facts.


reasoning: The paragraph explicitly states a conclusion about the material impact of past cybersecurity incidents (a negative assertion), which falls under Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph explicitly describes the Board's oversight of cybersecurity risk and its delegation to the Audit Committee, fitting the Board Governance category. It contains only generic governance terms without any domain-specific, firm-specific, or verifiable details.


reasoning: The paragraph focuses entirely on the company's processes for managing third-party cybersecurity risks, including vendor due diligence and contractual security requirements. The language used is generic and lacks specific domain terminology, firm-specific details, or verifiable metrics.


fact: ISAT

fact: penetration testing

reasoning: The paragraph describes the use of third-party consultants to support the internal cybersecurity program, which falls under Risk Management Process. The mention of the specific internal team 'ISAT' elevates the specificity to Firm-Specific.


fact: VRM

fact: Information security and related controls (third-party audit)

reasoning: The paragraph focuses entirely on the due diligence process for high-risk and vital vendors, making it Third-Party Risk. The mention of the specific internal team 'VRM' elevates the specificity to Firm-Specific.


fact: ransomware attack

reasoning: The paragraph describes a specific, actual cybersecurity incident (a ransomware attack) including its timeline and remediation, making it Incident Disclosure. The inclusion of specific dates (April 28, 2023, and May 1, 2023) makes the paragraph Quantified-Verifiable.


reasoning: The paragraph describes the Chief Executive Officer's responsibilities for overseeing cybersecurity processes and reporting to the Board, fitting the Management Role category. It lacks any domain-specific terminology, firm-specific details, or verifiable metrics, making it generic boilerplate.


reasoning: The paragraph explicitly states that the company has not yet adopted formal cybersecurity risk management programs or processes, meeting the threshold for None/Other as it lacks substantive cybersecurity measures. As a None/Other paragraph, it defaults to Generic Boilerplate specificity.


fact: Mr. Dennis

fact: since June 2019

fact: founder of a data privacy consulting company

fact: over 20 years of experience

fact: attack vectors and vulnerabilities

reasoning: The paragraph primarily details the qualifications, experience, and responsibilities of the Director of Information Technology, making it a Management Role description. It achieves Quantified-Verifiable specificity by including externally verifiable facts such as his specific start date (June 2019) and a quantified lower bound for his experience (over 20 years).


fact: vulnerability assessments

fact: Chief Information Security Officer

reasoning: The paragraph primarily describes the Audit Committee and Board's oversight of cybersecurity risks, including reporting cadences and topics, making it Board Governance. The mention of the Chief Information Security Officer elevates the specificity to Firm-Specific.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business and financial condition, placing it in Strategy Integration. It contains only generic risk disclaimers and negative assertions without any specific domain terminology, firm-specific details, or verifiable facts.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business strategy and financial condition, which aligns with the Strategy Integration category. It contains no domain-specific terminology, firm-specific details, or externally verifiable facts, as the date provided merely anchors a negative self-assessment.


reasoning: The paragraph primarily discusses the requirements imposed on third-party service providers, including security certifications and breach reporting, which falls under Third-Party Risk. The language used is entirely generic and lacks any domain-specific terminology, firm-specific details, or verifiable metrics, resulting in a Generic Boilerplate specificity level.


reasoning: The paragraph describes the Board's oversight role and the executive officers' day-to-day management responsibilities, fitting the Board Governance category. It contains only generic boilerplate language with no specific domain terms, firm-specific details, or verifiable facts.


fact: Chief Technology Officer

fact: over 15 years of experience

reasoning: The paragraph focuses entirely on management-level responsibilities, detailing the CTO's role, experience, and reporting line to the General Counsel. The specificity is Quantified-Verifiable because it includes a verifiable lower bound for the CTO's experience ('over 15 years').


fact: IT Committee

reasoning: The paragraph primarily describes the activities undertaken to evaluate and improve security infrastructure and policies, which falls under risk management processes. The specificity is Firm-Specific due to the mention of the company's named 'IT Committee'.


fact: Clarium Managed Services, LLC

fact: score of 4.8 on a scale of 0 to 5

reasoning: The paragraph explicitly concludes that cybersecurity incidents have not materially affected the company's business strategy or financial condition, placing it in Strategy Integration. It contains highly verifiable facts, including a named third-party assessor (Clarium Managed Services, LLC) and a specific assessment score (4.8 out of 5).


reasoning: The paragraph makes a negative assertion regarding the material impact of past cybersecurity incidents on the business and financial condition, which falls under Strategy Integration. It contains only generic boilerplate language and cross-references without any specific domain terms or verifiable facts.


fact: CISO

fact: CDO

fact: more than 20 years of executive IT leadership experience

fact: joining MPC in 2021

fact: employed by GE and its subsidiary companies for over 20 years

fact: Senior Vice President and Chief Information Officer of Services for parent company GE in 2017

fact: Vice President and Chief Information Officer of GE Healthcare

fact: Bachelor's degree in Business Administration, Management and Information Systems

reasoning: The paragraph is entirely dedicated to describing the reporting structure (CISO to CDO) and the specific qualifications and career history of the CDO, making it a clear Management Role disclosure. The specificity is Quantified-Verifiable due to numerous externally verifiable facts, including specific years of experience, named previous employers (GE), specific past job titles, and educational degrees.


fact: BNY Mellon

reasoning: The paragraph focuses entirely on how third-party cybersecurity risks are managed, including vendor evaluations and contractual obligations. The specificity is Quantified-Verifiable because it explicitly names the specific entity (BNY Mellon) executing these processes.


fact: service provider oversight committee

reasoning: The paragraph is entirely dedicated to describing the company's oversight and risk management processes for third-party service providers. It is classified as Firm-Specific due to the mention of a dedicated 'service provider oversight committee'.


reasoning: The paragraph makes a negative assertion regarding the occurrence of material cybersecurity incidents and cross-references risk factors related to business strategy and financial condition, fitting Strategy Integration. It contains no domain-specific terminology, firm-specific details, or externally verifiable cybersecurity facts, making it generic boilerplate.


fact: Vendor Management Policy

reasoning: The paragraph is entirely focused on managing cybersecurity risks associated with third-party vendors, including the Vendor Management Policy and specific requirements for vendors based on risk level. The mention of the specific 'Vendor Management Policy' elevates the specificity to Firm-Specific.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity incidents on the company's business strategy and financial condition, placing it in Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


fact: February 2023

fact: ransomware attack

reasoning: The paragraph describes the impact and remediation efforts of a specific, actual cybersecurity incident (the February 2023 ransomware attack), making it Incident Disclosure. The inclusion of a specific date (February 2023) makes it Quantified-Verifiable.


reasoning: The paragraph explicitly states a conclusion about the historical financial and business impact of cybersecurity incidents (or lack thereof), which falls under Strategy Integration. It contains only negative assertions and generic language, resulting in Generic Boilerplate specificity.


fact: threat modeling

fact: vulnerability testing

fact: information security maturity assessments

reasoning: The paragraph primarily describes the activities and processes involved in the company's cybersecurity risk management, including testing, assessments, and third-party reviews. The specificity is Domain-Adapted because it uses cybersecurity-specific terminology like 'threat modeling' and 'vulnerability testing' that pass the ERM test, but lacks firm-specific or verifiable facts.


fact: Risk and Compliance Committee

reasoning: The paragraph details the reporting structure from the CISO to the Risk and Compliance Committee and up to the Board, making it a Board Governance disclosure. It includes firm-specific details such as the CISO role and the Risk and Compliance Committee.


fact: SMIS

fact: Cybersecurity Committee

reasoning: The paragraph primarily describes the flow of cybersecurity information and incident reporting to the Board of Directors and Audit Committee, making it Board Governance. Specificity is Firm-Specific due to the mention of the uniquely named SMIS and the Cybersecurity Committee.


fact: Energy Transfer's Chief Information Officer

fact: more than 35 years of experience

fact: over 50 years of combined experience

fact: 20 years dedicated to cybersecurity

fact: Global Industrial Cyber Security Professional (GICSP)

fact: Certified Information Systems Security Professional (CISSP)

fact: Certified Ethical Hacker (CEH)

fact: USAC's IT department

fact: average of over 25 years of experience

fact: over 10 years of experience in IT security

reasoning: The paragraph is classified as Management Role because it focuses entirely on the leadership structure, qualifications, and experience of the IT and cybersecurity teams at both Energy Transfer and USAC. The specificity is Quantified-Verifiable due to the inclusion of specific, verifiable years of experience and named professional certifications like CISSP, GICSP, and CEH.


fact: February 23, 2023

fact: DISH Network

fact: February 28, 2023

reasoning: The paragraph describes a specific past cybersecurity incident involving DISH Network, including dates, impact, and response actions, making it an Incident Disclosure. The inclusion of specific dates (February 23, 2023, and February 28, 2023) makes the paragraph Quantified-Verifiable.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of past cybersecurity incidents on the company, which falls under Strategy Integration. The language used is entirely generic and lacks any domain-specific terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph primarily describes the roles, responsibilities, and experience of management (CEO and SVP Finance/CFO) in overseeing cybersecurity risks, making it Management Role. The specificity is Firm-Specific due to the specific title 'Senior Vice President, Finance and Chief Financial Officer'.


fact: October 15, 2025

fact: Federal Bureau of Investigation (FBI)

fact: encryption and monitoring software

reasoning: The paragraph describes an actual cybersecurity incident, detailing the timeline, nature of the attack, and the company's response, placing it in Incident Disclosure. It includes verifiable facts such as the specific date of discovery (October 15, 2025) and the involvement of a named external agency (FBI), making it Quantified-Verifiable.


reasoning: The paragraph explicitly states conclusions regarding the material impact of cybersecurity threats on the company's business strategy and financial condition, fitting the Strategy Integration category. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


fact: Head of IT

fact: over twenty years of experience

fact: Master of Science degree in Telecommunications and Computer Networks

fact: Project Management Professional

fact: Certified Scrum Master

fact: IT Infrastructure Library certified

reasoning: The paragraph primarily details the qualifications, reporting structure, and responsibilities of the Head of IT and senior leadership team regarding cybersecurity, making it Management Role. The specificity is Quantified-Verifiable due to the specific years of experience and verifiable certifications/degrees held by the Head of IT.


fact: executives from our Legal, Accounting, Internal Audit and Risk Management, Cybersecurity and Facilities departments

reasoning: The paragraph explicitly details management's organizational structure by describing the establishment, membership, and responsibilities of the Information Security Steering Committee (ISSC), fitting the Management Role category. The specificity is Firm-Specific due to the naming of a specific internal committee and the exact departmental composition of its members.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity incidents on the company's business strategy and financial condition, fitting the Strategy Integration category. It contains only generic boilerplate language, a negative assertion, and a cross-reference, lacking any specific domain terms, firm-specific details, or verifiable facts.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity threats on the company's business strategy and financial condition, placing it in Strategy Integration. It contains only negative assertions and cross-references, lacking any domain-specific, firm-specific, or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph explicitly describes the board's oversight of cybersecurity risk and its delegation to the audit committee, placing it squarely in Board Governance. The language relies entirely on generic corporate governance terms without any domain-specific, firm-specific, or verifiable details.


fact: Chief Information Security Officer ("CISO")

fact: Chief Risk Officer ("CRO")

fact: over 18 years of experience in information technology leadership

fact: eight years of which is experience in leading information security oversight

reasoning: The paragraph primarily describes the roles, reporting lines, and qualifications of management (CISO and CRO), making it Management Role. The specificity is Quantified-Verifiable due to the specific, verifiable numbers regarding the CISO's years of experience.


fact: information security division

fact: third-party risk management unit

reasoning: The paragraph is entirely focused on the processes used to assess and monitor cybersecurity risks associated with third-party service providers. It is Firm-Specific because it names the specific internal units (information security division, third-party risk management unit) responsible for these evaluations.


fact: National Institute of Standards and Technology

fact: Center for Internet Security Controls

reasoning: The paragraph describes the foundation of the company's cybersecurity risk management program, specifically its alignment with industry frameworks, which falls under Risk Management Process. The specificity is Domain-Adapted because it names specific cybersecurity frameworks (NIST, CIS Controls) but does not include firm-specific or verifiable facts.


reasoning: The paragraph is purely a cross-reference pointing to a risk factor heading for information on material impacts, containing no substantive cybersecurity disclosure itself.


fact: June of 2023

fact: email accounts of two of our employees

fact: early September 2023

fact: approximately $25,000

reasoning: The paragraph primarily details a specific historical cybersecurity incident, including its timeline, scope, and financial impact, making it an Incident Disclosure. The specificity is Quantified-Verifiable due to the inclusion of specific dates (June 2023, September 2023), exact employee counts (two), and a specific financial cost ($25,000).


reasoning: The paragraph discusses the company's cyber liability insurance policy, which relates to financial mitigation and strategy integration. The language is generic and lacks specific details about the policy's coverage or limits.


fact: Deutsche Bank Group

fact: DWS

reasoning: The paragraph describes the incident management, reporting processes, and communication protocols used to respond to cyberattacks, which falls under Risk Management Process. The specificity is Firm-Specific due to the explicit naming of the parent/sponsor entities (Deutsche Bank Group and DWS) that manage these processes.


fact: ransomware

fact: denial-of service

reasoning: The paragraph consists of introductory, speculative statements about the threat landscape and potential material adverse effects without describing specific cybersecurity measures, processes, or actual strategy integration, placing it in None/Other. It includes domain-specific threat terms like ransomware and denial-of-service, elevating the specificity to Domain-Adapted.


fact: malware

fact: June 2018

fact: $10 million

reasoning: The paragraph explicitly states a conclusion about the materiality of cybersecurity risks and past incidents on the company's business strategy and financial condition, aligning with the Strategy Integration category. The specificity is Quantified-Verifiable because it includes a specific date (June 2018) and a hard dollar amount ($10 million) related to a past incident.


reasoning: The paragraph is solely a cross-reference to the Risk Factors section of the report, containing no substantive cybersecurity disclosure.


fact: exfiltrated images of video meetings and computer screens

fact: released a portion of this information publicly

fact: demand for a monetary payment

reasoning: The paragraph is entirely dedicated to describing the details, impact, and remediation of a specific, actual cybersecurity incident involving data exfiltration and a ransom demand, making it an Incident Disclosure. The specificity is Firm-Specific because it details the unique characteristics of this company's breach, such as the specific types of data stolen (images of video meetings and computer screens) and the subsequent public release following an unmet ransom demand.


fact: threat intelligence

fact: penetration testing

fact: managed cybersecurity service providers

reasoning: The paragraph describes the use of third-party service providers to support the company's internal risk management processes, classifying it as Risk Management Process. It includes domain-specific terminology like 'threat intelligence' and 'penetration testing', making it Domain-Adapted.


fact: National Security Administration ("NSA")'s Cybersecurity Collaboration Center

fact: Federal Bureau of Investigation ("FBI") InfraGard

fact: Maritime Transportation System Information Sharing and Analysis Center ("MTS-ISAC")

fact: Cyber-Hawaii

reasoning: The paragraph lists external threat intelligence and information-sharing partnerships, which are components of the company's risk management process. The specificity is Quantified-Verifiable because it names specific external organizations and programs (e.g., FBI InfraGard, MTS-ISAC) where participation can be independently verified.


reasoning: The paragraph discusses cybersecurity insurance coverage, which falls under Strategy Integration. The language used consists of standard insurance coverage categories without any specialized domain terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management and the use of third-party specialists for reviews, fitting the Risk Management Process category. The language consists entirely of generic boilerplate without any specific domain terminology, firm-specific details, or verifiable metrics.


fact: Chief Security Officer

fact: more than 20 years

fact: Chief Information Security Officer ("CISO")

reasoning: The paragraph details the qualifications, career history, and supporting team of the Chief Security Officer, placing it squarely in Management Role. The specificity is Quantified-Verifiable because it includes a verifiable lower bound of experience ('more than 20 years').


fact: CSO

reasoning: The paragraph primarily describes the organizational structure and responsibilities of management, specifically the CSO and multidisciplinary teams, in implementing the cybersecurity program. The specificity is Firm-Specific due to the explicit mention of the CSO role.


reasoning: The paragraph describes the cybersecurity program's mechanisms, controls, and reliance on outside advisors to manage risks, fitting the Risk Management Process category. The language is generic and lacks specific domain terms, firm-specific details, or verifiable facts, resulting in a Generic Boilerplate specificity.


fact: Chief Information Security Officer

fact: 25 years of prior experience

fact: Certified Internal Controls Auditor (CICA)

fact: Payment Card Industry Professional (PCIP)

fact: Certified Information Systems Security Professional (CISSP)

fact: Certified Information Systems Auditor (CISA)

fact: Certified in Risk and Information Systems Control (CRISC)

reasoning: The paragraph details the responsibilities, experience, and specific certifications of the Chief Information Security Officer, placing it squarely in Management Role. The inclusion of exact years of experience and specific verifiable certifications (e.g., CISSP, CISA) makes it Quantified-Verifiable.


reasoning: The paragraph describes the existence and general components of the company's incident response plan, which falls under risk management processes. The language is entirely generic and lacks any domain-specific terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph states a conclusion about whether cybersecurity risks are reasonably likely to materially affect the business strategy, results of operations, or financial condition, which aligns with the Strategy Integration category. The language is generic and lacks any domain-specific terminology, firm-specific details, or verifiable facts.


fact: vulnerability assessments

fact: January 2024

reasoning: The paragraph primarily describes the board and audit committee's oversight of cybersecurity risk, including management reporting and board training, making it Board Governance. The specificity is Quantified-Verifiable due to the specific date (January 2024) of the board's cybersecurity training session.


fact: March 2023

fact: $2.7 million of loss

reasoning: The paragraph describes a specific cybersecurity incident (a complex criminal scheme in March 2023 resulting in fraudulent wire transfers), detailing the response, investigation, and financial impact, which clearly falls under Incident Disclosure. The specificity is Quantified-Verifiable due to the specific date (March 2023) and the quantified financial loss ($2.7 million).


reasoning: The paragraph outlines the governance structure for cybersecurity, detailing the Board's oversight role and identifying the CEO and CFO as the responsible management members. The inclusion of a specific date (June 30, 2024) elevates the specificity to Quantified-Verifiable.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business strategy and financial condition, placing it in Strategy Integration. It contains only generic boilerplate language and disclaimers without any specific domain terms, firm-specific details, or verifiable facts.


fact: ISO

fact: Information Security Program

fact: Interagency Guidelines for Safeguarding Customer Information

reasoning: The paragraph describes the reporting structure to the board of directors by the ISO regarding the Information Security Program, making it Board Governance. The mention of the ISO role and the specific Interagency Guidelines elevates the specificity to Firm-Specific.