content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The paragraph focuses on the board's oversight responsibility and the reporting cadence from management to the board. Since no specific management roles (like CISO) are identified and the board is the primary subject of the oversight description, Board Governance is the most appropriate category.

provider: google


content_category: Risk Management Process

reasoning: The paragraph details the company's internal incident response and escalation procedures, specifically naming the internal teams responsible for these actions. This aligns with Risk Management Process as it describes the company's own internal IR planning and monitoring structure.


reasoning: The paragraph describes the company's internal Enterprise Risk Management (ERM) program and its objectives for handling cybersecurity risks, which aligns with the Risk Management Process category. It contains no specific names, dates, or frameworks, making it generic boilerplate.


reasoning: The paragraph identifies the Audit and Risk Committee as the primary body for cybersecurity oversight, which places it in Board Governance. Because the committee title explicitly includes 'Risk', it qualifies as a named non-generic committee according to the codebook (which distinguishes 'Risk Committee' from the standard 'Audit Committee'), making the disclosure Firm-Specific.


content_category: Management Role

reasoning: The paragraph focuses entirely on the qualifications, tenure, and responsibilities of the CDIO, who is the grammatical subject. It meets the Quantified-Verifiable threshold by providing two hard facts: a specific date (January 2022) and a specific number (20 years of experience).


reasoning: The paragraph identifies the specific management role (Head of IT department) responsible for cybersecurity oversight and details the reporting hierarchy through the CEO to the Audit Committee. This aligns with the Management Role category, which focuses on the identification and reporting lines of those managing cyber risk.


reasoning: The paragraph describes the company's internal cybersecurity risk management activities, including assessments, audits, incident response planning, and training programs. It is classified as Generic Boilerplate because all mentioned activities (penetration testing, training, audits) are listed as common practices or generic items in the codebook, and the 'Cyber Incident Response Plan' lacks a unique identifier or acronym to distinguish it from a generic program name.


reasoning: The paragraph focuses on the identification, qualifications, and reporting lines of the CIO, making Management Role the correct category. It reaches the Quantified-Verifiable threshold by including multiple specific numbers/durations (13 years, 40 years, 4 years) which the codebook calibration examples explicitly count as hard verifiable facts.


reasoning: The paragraph is primarily structured around the roles, responsibilities, and specific professional qualifications of the CIO and CISO. While it mentions frameworks and processes, these are presented as components overseen by these specific management roles.


content_category: Third-Party Risk

reasoning: The paragraph focuses exclusively on the company's oversight and qualification process for third-party vendors, which is the definition of Third-Party Risk. It uses generic industry terminology such as 'Risk Dependency Assessment' and 'Critical Vendors' without providing any firm-specific identifiers, named entities, or dates.


reasoning: The grammatical subject of the sentence is 'Management' and the content describes reporting lines to the board, which aligns with the Management Role category. The paragraph contains no specific facts as 'Management', 'Audit Committee', and 'as necessary' are all defined as generic or non-specific in the codebook.


reasoning: The paragraph focuses on the qualifications, tenure, and oversight responsibilities of a specific executive officer, making Management Role the correct category. It reaches the Quantified-Verifiable level because it contains two specific numbers (35 years and 24 years) which, according to the calibration examples, count as hard verifiable facts.


reasoning: The paragraph describes the company's internal risk assessment process and the specific regulatory framework (MLPS) used to stratify IT systems. It is classified as Firm-Specific because it names a specific entity (JiuGe Technology) and a cybersecurity-specific management role (IT Manager).


reasoning: The paragraph describes the company's internal cybersecurity risk management program, its integration with internal functional teams, and its use of third-party services. It is classified as Sector-Adapted because it names a specific industry framework (NIST) but lacks the firm-specific identifiers (like a CISO title or named committee) or verifiable facts required for higher specificity levels.


reasoning: The paragraph primarily focuses on the Audit Committee and Board of Directors' oversight responsibilities and the cadence of reporting they receive. While it details a management reporting chain, the grammatical subjects of the opening sentences and the overall purpose of the paragraph describe the governance structure and escalation to the board.


reasoning: The paragraph describes the functional components of the company's risk management lifecycle, such as identification, assessment, and monitoring, which aligns with the Risk Management Process category. It contains no specific roles, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses exclusively on the oversight of third-party service providers and vendors, which is the central topic. While it mentions a 'Third-Party Risk Management Program,' this is considered a generic program name similar to 'cybersecurity program' or 'incident response plan' under the codebook, and the activities described (due diligence, monitoring) are standard industry practices.


content_category: Strategy Integration

reasoning: The paragraph provides a standalone materiality conclusion regarding the impact of cybersecurity risks and past incidents on the company's financial condition and business operations, which is explicitly categorized under Strategy Integration in the codebook.


reasoning: The paragraph identifies 'Senior management' as the grammatical subject and describes their specific responsibilities in the risk management process. It contains no firm-specific identifiers, named cybersecurity roles, or specific committees beyond the generic Board of Directors.


reasoning: The paragraph describes the company's internal risk management approach, specifically its use of a consultant for monitoring and assessment. The mention of 'over 30 years of experience' is a specific quantified fact that makes the disclosure firm-specific, though it lacks a second hard fact to reach the Quantified-Verifiable level.


reasoning: The paragraph focuses on the internal mechanics of the company's risk management, specifically its integration into the Enterprise Risk Management (ERM) process and the use of penetration testing. While it mentions Audit Committee oversight, the primary subject matter is the operational process and the reporting structure involving management roles.


reasoning: The paragraph identifies the specific management position (Head of IT department) responsible for cybersecurity oversight and details the reporting line to the CEO and Audit Committee. While it mentions risk processes, the focus on the responsible role and its reporting structure makes Management Role the most applicable category.


reasoning: The paragraph describes the company's internal processes for framework oversight, risk identification, and employee training. It lacks any specific cybersecurity leadership roles (like CISO), named frameworks (like NIST), or verifiable facts, as 'Software Engineer' and 'IT Team' are generic titles/departments and training topics are explicitly excluded from specificity counts.


reasoning: The paragraph focuses on the VP of IT as the primary subject, detailing their specific role, oversight responsibilities, and professional qualifications. It meets the Quantified-Verifiable threshold by including a specific number (over 20 years of experience) and two named academic qualifications (degrees), which align with the calibration example regarding years of experience and certifications.


reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities and the cadence of reporting it receives, making Board Governance the correct category. It is classified as Firm-Specific because it identifies a specific functional group ('cybersecurity and data privacy leadership team') responsible for reporting to the board, which aligns with the codebook's inclusion of specific team compositions as firm-specific facts.


reasoning: The paragraph focuses on the business's dependence on its IT platform and the strategic importance of cybersecurity to its operations, which aligns with the 'Business/financial impact' component of Strategy Integration. It serves as a high-level recognition of risk rather than a description of specific internal risk management processes or governance oversight.


reasoning: The paragraph describes the foundational structure and execution of the company's cybersecurity risk management program, specifically how it is integrated into its external management model. While it mentions a third-party IT provider, the central topic is the company's own process for managing risk given its lack of employees.


reasoning: The paragraph identifies the CEO as the primary individual responsible for reporting to the Audit Committee. Following the codebook's specific instruction to assign 'Management Role' when a management role is the grammatical subject, this category is the most appropriate.


reasoning: The paragraph describes the company's internal risk management posture, specifically its lack of internal cybersecurity personnel and processes and its reliance on third parties. While it mentions management reporting to the board, the central theme is the company's internal risk assessment and lack of infrastructure.


reasoning: The paragraph focuses on the qualifications and professional backgrounds of the CIO and VP of Information Security. It meets the Quantified-Verifiable threshold by providing multiple hard facts, including specific years of experience and a named professional certification (CISSP), matching the provided calibration examples.


reasoning: The paragraph describes the company's internal processes for identifying and mitigating risks through its enterprise risk management (ERM) framework. The mention of a specific 'enterprise risk management committee' is explicitly listed in the codebook as a firm-specific fact, distinguishing it from generic boilerplate.


reasoning: The paragraph describes the company's internal risk management processes, including vulnerability scanning and framework adoption, while identifying a specific agreement and a named third-party entity (Harley-Davidson) that supports these processes.


reasoning: The paragraph identifies the Chief Executive Officer as the grammatical subject overseeing the program and incident response, which aligns with the Management Role category. It is classified as Firm-Specific because it provides a detailed, non-generic composition of the cross-functional incident response team, including specific departments like 'mining operations' and 'software engineering'.


reasoning: The paragraph provides a standalone materiality conclusion regarding the potential financial and operational impacts of a cyberattack, which falls under Strategy Integration according to the category tiebreakers.


reasoning: The paragraph describes the company's internal security measures, including firewalls, antivirus software, and backup procedures, which are core components of a Risk Management Process. Although it provides descriptive detail about using magnetic tapes and an internal cloud, it does not include any named products, specific dates, cybersecurity-specific roles, or named standards required to move beyond Generic Boilerplate.


reasoning: The paragraph describes the scope of the company's risk management environment by identifying the types of sensitive data (IP, PII, clinical trial data) and IT systems it must protect. It serves as a substantive introduction to the company's internal risk management focus rather than being purely administrative or non-cybersecurity content.


reasoning: The paragraph describes the company's internal organizational structure for assessing and managing cybersecurity risks, specifically how it utilizes a services agreement with an affiliate and the role of its subsidiary. This falls under Risk Management Process as it details the company's own internal approach to risk management.


reasoning: The paragraph describes the company's internal security controls, monitoring activities, and defense strategies, which aligns with Risk Management Process. It is classified as Firm-Specific because it identifies a specific cross-functional team composition (information security, technology, IT, and operations) responsible for the program's execution.


reasoning: The paragraph describes the integration of cybersecurity into the company's broader risk management framework, which is a hallmark of the Risk Management Process category. While it mentions the Board of Directors, the Board is not the primary subject of the paragraph, and the mention is a brief oversight reference rather than a description of governance activities.


reasoning: The paragraph describes the company's internal processes for system monitoring, security enhancements, and employee training, which falls under Risk Management Process. It is Firm-Specific because it identifies the specific internal organizational unit ('Information Systems Security department') responsible for these functions, which constitutes a specific detail about the company's organizational structure.


reasoning: The paragraph's grammatical subjects are the IT Engineer and the Cybersecurity Council, focusing on their roles, composition, and reporting lines. This aligns with the Management Role category, as it describes the specific management-level entities responsible for the program's execution.


content_category: None/Other

reasoning: The paragraph serves primarily as a cross-reference to the company's risk factor disclosures in Item 1A and contains no substantive cybersecurity disclosure or specific details.


reasoning: The paragraph provides a standalone materiality conclusion regarding the impact of cybersecurity threats and past incidents on the company's financial condition and business strategy, which falls under Strategy Integration according to the category tiebreakers.


reasoning: The paragraph describes the company's internal risk assessment activities, framework adoption, and monitoring tools like a risk register, which are core components of a Risk Management Process. It is classified as Sector-Adapted because it names a specific recognized framework (NIST CSF) but lacks the unique identifiers, cybersecurity-specific roles, or hard verifiable facts required for higher specificity levels.


reasoning: The primary focus of the paragraph is the evaluation of third-party service providers and the security requirements imposed on them, which the codebook explicitly directs to Third-Party Risk. The mention of the Board and Audit Committee is a secondary governance statement that does not override the central topic of vendor oversight.


reasoning: The paragraph describes the company's internal risk management program and its integration into the broader enterprise risk management (ERM) framework. It qualifies as Firm-Specific because it identifies a specific team composition (cybersecurity and data privacy professionals) involved in oversight, which meets the codebook criteria for specific departmental compositions.


reasoning: The paragraph's primary function is to identify the specific management roles and organizational structure responsible for cybersecurity, including the Vice President of Cybersecurity, CTO, CIO, and a specialized Chief Legal, Privacy and Compliance Officer. While it lists various risk management activities, these are framed as the specific duties and methods of the identified management team.


reasoning: The paragraph identifies the specific management role responsible for the cybersecurity program and details their professional qualifications, which is the primary focus of the Management Role category. It is Firm-Specific because it includes a cybersecurity-specific title and a specific duration of experience, but it fails to reach the Quantified-Verifiable level because named roles are excluded from the hard fact count, leaving only one verifiable fact (the years of experience).


reasoning: The paragraph is a generic forward-looking risk disclaimer that outlines potential business impacts (sales, production, cash flows) in a hypothetical sense. It lacks substantive disclosure regarding the company's actual cybersecurity strategy, governance, or risk management processes, fitting the 'None/Other' category for non-substantive disclaimers.


reasoning: The paragraph identifies the Board and Audit Committee as the primary subjects responsible for overseeing cybersecurity risk and receiving reports, which aligns with the Board Governance category. The disclosure is classified as Generic Boilerplate because the entities mentioned (Advisor, Sub-Advisor, Dealer Manager) are standard operational components of an externally managed REIT and function as company self-references rather than specific cybersecurity roles or teams, and 'incident response plan' is explicitly excluded from being a specific fact.