content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: This paragraph is only a cross-reference to another section discussing cybersecurity-related risks and does not itself describe governance, management, processes, third-party risk, incidents, or strategy impact. Under the rules, pure cross-references belong in None/Other.

provider: openai

stage: benchmark


reasoning: This paragraph only provides general risk context that the company stores and transmits personal information and is a target of attempted cyber threats. It does not describe governance, management roles, cybersecurity processes, third-party oversight, a specific incident, or a materiality/business-impact assessment.


reasoning: This paragraph is primarily a forward-looking limitation/disclaimer about cybersecurity risk and a cross-reference to Risk Factors, rather than a substantive description of governance, management, process, third-party risk, incident details, or strategy impact. It does not describe any actual cybersecurity measure or company-specific fact.


content_category: Strategy Integration

reasoning: The paragraph primarily states a materiality conclusion that no cybersecurity incidents have materially affected or are reasonably likely to materially affect the company’s business, results, or financial condition, which fits Strategy Integration. The remaining content is a cross-reference to risk-factor disclosure rather than a description of governance, management, or risk processes.


category_confidence: medium

reasoning: The paragraph states a general commitment to protect IT assets and data, but it does not describe board oversight, management roles, a cybersecurity process, third-party risk practices, an actual incident, or a business-impact assessment. Because it is high-level and lacks substantive cybersecurity measures or structure, it is best classified as None/Other.


content_category: Board Governance

reasoning: The paragraph primarily describes how cybersecurity information flows to the board and how the board is educated on cybersecurity matters, which is a board oversight function. The VPIT and DIS are firm-specific management roles that make the disclosure more company-specific, but there are no quantified or externally verifiable facts.


reasoning: This paragraph is only a cross-reference incorporating another section by reference and does not itself describe cybersecurity governance, management, process, third-party risk, incident details, or business impact. Under the rules, pure cross-references are classified as None/Other.


reasoning: The paragraph primarily provides a materiality assessment, stating that past cybersecurity incidents have not materially affected the company or its financial position, results, or cash flows. The remaining content is generic risk and investment language plus a cross-reference, which does not outweigh the business-impact conclusion.


reasoning: This paragraph is only a cross-reference to another section for risk discussion and does not itself describe cybersecurity governance, management, processes, third-party risk, incidents, or strategy impact. Under the rules, pure cross-references are classified as None/Other.


content_category: Management Role

specificity_confidence: medium

reasoning: The paragraph primarily explains how management stays informed and monitors cybersecurity matters, which is most directly about management’s role rather than board oversight or a detailed description of the underlying program. It includes cybersecurity-specific concepts like threat intelligence and security-tool alerts, but no firm-unique or externally verifiable facts.


content_category: Third-Party Risk

reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from vendors and service providers, making Third-Party Risk the best fit. Its most distinguishing detail is the named TPRM program, while the rest describes common vendor-risk practices such as due diligence, contractual review, and ongoing monitoring.


reasoning: The paragraph primarily describes an oversight function—reviewing information security examination reports, regulatory communications, and emerging risk issues—which fits board-level cybersecurity governance. It does not provide company-specific roles, named committees, frameworks, or other qualifying details beyond generic oversight language.


content_category: Incident Disclosure

reasoning: The paragraph primarily describes a real cybersecurity event that occurred in 2017 and its nature, which makes Incident Disclosure the best fit. It also includes externally verifiable incident facts, including the year and affected consumer geographies, supporting Quantified-Verifiable specificity.


content_category: Risk Management Process

reasoning: The paragraph primarily describes what the company's cybersecurity program does: risk assessments, security controls, training, incident response planning, and use of external support. Although it includes third-party oversight, that is presented as one component of the broader cybersecurity risk management program rather than the central topic.


reasoning: The paragraph primarily describes how the Board oversees cybersecurity risk through reporting and information flow from management to the Audit Committee and full Board. Although it mentions management participants, its main purpose is to explain board-level oversight structure rather than management organization or operational processes.


reasoning: The paragraph primarily provides a materiality-oriented assessment of cybersecurity's potential and historical impact on the business, including the statement that the company has not experienced any material cyber threats or incidents to date. The rest of the paragraph is forward-looking business-impact language and a cross-reference to risk factors, not a description of governance, management structure, or specific cyber processes.


reasoning: The paragraph primarily explains how the board and its committees oversee cybersecurity, including delegation, reporting, and briefing flows to the full Board. Although management roles are mentioned, they are presented mainly as part of the board oversight structure rather than to describe management organization.


reasoning: The paragraph primarily describes how management is organized to oversee cybersecurity, including leadership roles, team composition, and reporting structure. Although it mentions use of third parties and security activities, those are secondary to the management-organization focus.


reasoning: The paragraph describes the company’s general exposure to cyber threats and why it may be an attractive target, but it does not describe board oversight, management roles, risk management processes, third-party risk controls, a real incident, or a material business-impact assessment. Because it is essentially contextual/speculative risk framing without concrete cybersecurity measures, it fits None/Other.


reasoning: This paragraph primarily describes a real cybersecurity incident, including when it occurred, the operational disruptions it caused, the response taken, and its direct consequences. Although it includes financial impact, the dominant focus is the incident itself and its aftermath.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from third-party service providers, making third-party risk the central topic. It uses cybersecurity-specific vendor risk management language, but does not include named programs, roles, firms, dates, or other firm-specific verifiable details.


reasoning: The paragraph primarily describes how management is organized to handle cybersecurity through a named management steering committee, its composition, its interaction with the CISO, and its incident-response responsibilities. Although it mentions escalation to the Audit Committee and Board, the main focus is the management-level structure and role rather than board oversight.


reasoning: The paragraph primarily states the company's conclusion that it is not aware of any material cybersecurity incidents impacting the company, which is a materiality/business-impact assessment. The remaining content is largely generic risk language about possible threats and a cross-reference to risk factors, rather than a description of governance, management, or operational processes.


reasoning: The paragraph primarily describes how the board and its committees oversee cybersecurity risk, including delegation to the Risk Management Committee and Cybersecurity and Technology Subcommittee and reporting up from management. Although it mentions management reports and exercises, the dominant focus is the board oversight structure.


reasoning: The paragraph’s most concrete disclosure is the board’s oversight structure, specifically that the Board acts through a Cybersecurity Committee to oversee cybersecurity programs and risk management. Although it also mentions the company’s cybersecurity framework and a materiality conclusion about past incidents, those points are secondary to the governance description.


reasoning: The paragraph primarily describes a real cybersecurity incident, including when it was disclosed, the company’s response, operational disruption, and recovery timeline, which makes Incident Disclosure the best fit. Although it also includes financial impact and a materiality statement, those details are presented in the context of describing the incident itself.


reasoning: This paragraph primarily identifies which management roles are responsible for cybersecurity risk assessment and management, making it about management organization rather than board oversight or process details. The inclusion of specific senior cybersecurity/technology roles makes it firm-specific.


reasoning: The paragraph’s most decisive disclosure is the Item 106-style conclusion that, as of the stated date, the company is not aware of cybersecurity incidents that have materially affected or are reasonably likely to materially affect the business, results, or financial condition. Although it also references oversight and protective measures, those are high-level background to the materiality assessment.


reasoning: The paragraph primarily describes the company's incident response process—containment, remediation, recovery, use of forensic/incident-response support, disclosure engagement, and plan maintenance. Although it mentions notifying the board or audit committee, that oversight reference is secondary to the operational response workflow.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk arising from external third parties, focusing on vendor vetting, approval, inventory, and risk mitigation before and during engagement. Although it ends with a materiality conclusion, most of the paragraph is centered on third-party oversight rather than business impact.


reasoning: The paragraph primarily explains how cybersecurity information flows to the board and senior governing bodies through the CISO, making it chiefly about oversight structure. Although it mentions the CISO's leadership role, the emphasis is on board and leadership engagement in cybersecurity oversight rather than management qualifications or program mechanics.


reasoning: The paragraph primarily describes how cybersecurity information flows to the Board and senior governing bodies through regular CISO engagement and board-level exercises, which is board oversight. Although it names the CISO, the main purpose is the governance structure rather than management qualifications or program activities.


reasoning: The paragraph primarily gives a materiality assessment about whether cybersecurity incidents have affected or are likely to affect the business or financial condition, which fits Strategy Integration under the materiality rule. It does not describe governance, management organization, or risk-management activities.


reasoning: This paragraph is a cross-reference to Item 1A risk factors rather than a substantive cybersecurity disclosure. It does not describe governance, management, processes, third-party risk, an actual incident, or a concrete business-impact assessment.


reasoning: The paragraph primarily describes what the company's cybersecurity program does to identify, assess, and manage cyber risk, including threat types, technical controls, training, third-party assessments, and response procedures. It is not mainly about board oversight or management roles.


reasoning: The paragraph primarily describes how cybersecurity information flows to the board and how the board and its committees oversee cybersecurity, which is board governance. Although management roles are mentioned, they are included mainly to explain the board reporting and oversight structure.


reasoning: The paragraph primarily describes the oversight and escalation chain for cybersecurity matters, culminating in elevation to the Board's Audit Committee, which makes it a board-governance disclosure. Its specificity is driven by firm-specific organizational details, including the CISO role and the named Cybersecurity Executive Steering Body.


reasoning: The paragraph primarily describes how the Board oversees cybersecurity risk, including its role in enterprise risk management, management reporting to the Board, and escalation of significant incidents. Although it mentions third-party testing, the main focus is the Board’s oversight structure rather than the cybersecurity program itself.


reasoning: The paragraph primarily describes the board oversight structure for cybersecurity, including delegation to a board committee and reporting flow up to the full Board. Its main purpose is governance oversight rather than management operations or risk process details.


reasoning: The paragraph primarily describes what the company's cybersecurity program does: monitoring, detection, response, and testing activities. Its focus is on operational security processes and tools rather than board oversight, management roles, or third-party vendor risk.


reasoning: The paragraph primarily explains how IBM's cybersecurity management function is organized, including the roles, teams, and reporting structure led by E&TS and the CISO. Although it mentions third-party supplier risk and product vulnerabilities, those are described as responsibilities within the management structure rather than the central topic.


reasoning: The paragraph primarily describes how cybersecurity oversight is exercised by the Board and Audit Committee, including the reporting path from management to the Board. The Vice President, Information Systems and Technology is a firm-specific management role, but the paragraph’s main purpose is governance oversight rather than management organization.


reasoning: The paragraph primarily states the company’s assessment that cybersecurity risks and incidents have not had a material adverse effect to date, which is a business-impact/materiality conclusion. Although it mentions threat sources and response activities, those details are secondary to the materiality statement.


reasoning: The paragraph primarily explains how the board-level oversight chain works for cybersecurity, especially how the Audit Committee receives information and monitors cyber risk. Although it mentions management activity, the main purpose is describing board oversight and reporting flow.


reasoning: The paragraph primarily describes an operational cybersecurity activity—reviewing and drilling on a response plan—rather than board oversight or management qualifications. Its only qualifying specific detail is the named Emergency Incident Response Team, which makes the disclosure firm-specific.


reasoning: The paragraph primarily states management’s conclusion about whether cybersecurity incidents have materially affected the company and discusses potential financial exposure and insurance coverage, which fits Strategy Integration. It does not describe a specific incident, governance structure, or cybersecurity process in substantive detail.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from vendors and partners, making third-party risk the central topic. It describes vendor vetting and ongoing monitoring for compliance with security standards, but does not provide firm-unique or externally verifiable details.


reasoning: The paragraph primarily describes how the company's cybersecurity program detects and analyzes incidents, including monitoring, investigation, and severity assessment activities. It focuses on operational incident-handling processes rather than board oversight, management qualifications, or third-party vendor governance as the central topic.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity breaches have not materially affected the company’s business strategy, results of operations, or financial condition to date. The rest is largely speculative risk language and cross-references to Item 1A rather than describing governance, management, or operational cybersecurity processes.


reasoning: This paragraph does not describe a substantive cybersecurity governance structure, management role, or risk management process; it mainly states that the trust has no active operations, no customers, and no personal or credit data. For a no-operations entity like this, the disclosure is contextual rather than a meaningful cybersecurity program description.


reasoning: The paragraph primarily provides a materiality assessment, stating that the company is not aware of any cybersecurity incidents that have materially affected or are reasonably likely to materially affect its business, results, or financial condition. The remaining sentence is only a cross-reference to risk factors, so Strategy Integration is the best fit.


reasoning: The paragraph primarily describes an actual cybersecurity incident, including when it occurred, what happened, and its operational effects, which makes Incident Disclosure the best fit. Although it also mentions remediation steps and ongoing threat exposure, those are secondary to the event narrative.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk arising from third-party service providers, including assessments, reassessments, and contractual security requirements. Its focus is vendor oversight rather than the company’s broader internal cybersecurity program.


reasoning: The paragraph primarily describes operational cybersecurity activities: implementing tools and processes to identify, contain, and remediate incidents, using consultants, conducting phishing tests, and employee training. Although it mentions the information security team and CSO, those roles are in service of describing the cybersecurity program’s day-to-day processes rather than management structure.


reasoning: The paragraph mainly provides background context about the company's reliance on technology systems, third-party applications, and sensitive data, but it does not describe oversight, management roles, a cybersecurity process, vendor risk management practices, an actual incident, or a business-impact assessment. Because it lacks a substantive cybersecurity disclosure, None/Other is the best fit.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk arising from vendors and supply chain relationships, making Third-Party Risk the best fit. Although it briefly mentions cyber insurance, the dominant focus is on vendor screening, ranking, rescreening, and sourcing restrictions.


reasoning: The paragraph primarily provides a materiality-style assessment that the company did not experience a material cybersecurity incident, which falls under Strategy Integration rather than describing an actual incident or a cybersecurity process. The rest is forward-looking caution and a cross-reference, not substantive governance or program detail.


reasoning: The paragraph primarily describes what the Trust’s cybersecurity measures do, including workstation isolation, password/passphrase protections, and two-factor or independent authorizations. Although it mentions banks, service providers, and vendors, third-party oversight is not the central topic.


reasoning: The paragraph primarily describes the oversight chain for cybersecurity risk—risks are reviewed by the ERM Committee and then reported to the Audit Committee—so board governance is the best fit. Although it also mentions risk assessment and third-party reviews, those points are secondary to the governance structure being described.


reasoning: The paragraph primarily answers whether cybersecurity threats have materially affected or are reasonably likely to affect the company's business strategy, results of operations, or financial condition, which is a Strategy Integration assessment. The remaining statements about updating an information security plan and making investments are general and secondary.


reasoning: The paragraph primarily explains how the company evaluates cybersecurity risk from third-party service providers before onboarding them, making vendor-related risk management the central topic. While it includes cybersecurity process language such as onboarding-related risk assessments and impact evaluation, it does not provide firm-unique or externally verifiable details.


reasoning: The paragraph primarily describes what the cybersecurity program does: the technical safeguards and assessment activities used to protect systems and manage vulnerabilities. Its focus is on operational security measures rather than board oversight, management roles, or third-party/vendor risk.


reasoning: The paragraph primarily describes how the Board oversees cybersecurity through delegation to the Audit Committee, reporting from management, and escalation of findings to the full Board. Although it also mentions program evaluation and third-party risk assessments, those points are presented as information flowing into the Board oversight structure rather than as the main focus.


reasoning: The paragraph primarily describes how the Board, through the Audit Committee, oversees cybersecurity and receives information from management, which makes Board Governance the best fit. Its most company-specific fact is the involvement of a CISO in the reporting chain, while the rest is largely standard oversight language.


reasoning: The paragraph primarily states management's conclusion that cybersecurity issues have not materially affected the company's business strategy, operations, or financial condition, which is a materiality/business-impact assessment. It does not describe governance, management structure, or any actual cybersecurity processes.


reasoning: The paragraph is centrally about how the company manages cybersecurity risks posed by suppliers and other third parties, including monitoring, assessments, and contractual protections. Its focus is vendor oversight rather than the company’s broader internal cybersecurity program.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from third-party service providers, making Third-Party Risk the best fit. It describes vendor-related assessments in generic terms without named firms, systems, frameworks, roles, or other company-specific details.


reasoning: The paragraph primarily explains how management is organized to handle cybersecurity incidents, including reporting lines, escalation responsibilities, and the membership of the Crisis Response Team. Although it mentions operational steps, the main focus is on who within management does what during incident escalation and disclosure review.


reasoning: The paragraph primarily gives a materiality-oriented business impact assessment, stating that prior cybersecurity threats have not materially affected the company's business strategy, results of operations, or financial condition. The rest is largely generic cautionary language about potential future impacts and a cross-reference to risk factors.


reasoning: The paragraph primarily describes what the company's cybersecurity program does to identify, assess, and mitigate cyber risk, including monitoring, software updates, access controls, and infrastructure changes. Its focus is on operational cybersecurity measures rather than board oversight, management roles, third-party vendor oversight, or a specific incident.


reasoning: The paragraph primarily provides a materiality-oriented assessment that the company has not experienced a cybersecurity threat or incident resulting in a material adverse impact as of the filing date, which fits Strategy Integration under the materiality rule. The remaining discussion is mostly forward-looking risk and impact language rather than a concrete description of governance, management structure, or a specific cybersecurity program.


reasoning: The paragraph primarily describes which management roles are accountable for cybersecurity and how responsibility is assigned within management, which makes it a management-organization disclosure rather than a program-process description. Although it mentions a risk-based approach and controls, the main focus is on the CIO and CISO's responsibilities.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from third-party service providers, including due diligence, onboarding review, contract renewal review, and incident follow-up. Although it is specific to vendor cyber oversight, it relies on generic risk-management language and does not include firm-unique, named, or externally verifiable facts.


reasoning: The paragraph primarily provides a materiality assessment that cybersecurity risks have not materially affected the business or results of operations to date, which falls under Strategy Integration. The remaining content is speculative future-risk language and a cross-reference to risk factors, not process or governance detail.


reasoning: The paragraph is primarily about how the Board and its committee oversee cybersecurity, including what information they receive and how incidents are escalated upward. Although management roles are mentioned, they are described mainly as part of the Board’s oversight structure rather than as standalone management organization.


reasoning: The paragraph primarily describes operational cybersecurity measures and activities, including incident response planning, security monitoring, insider threat protections, plan updates, exercises, and employee awareness training. Its focus is on what the cybersecurity program does rather than on board oversight or management roles.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats and prior incidents have not materially affected the company’s business strategy, results of operations, or financial condition. It does not describe governance, management structure, or operational cybersecurity processes.


reasoning: The paragraph primarily describes what the cybersecurity program does operationally: protective technologies, threat intelligence, training, and risk mitigation activities. Although third-party service providers are mentioned, vendor risk is not the central topic; the focus remains the company's overall cybersecurity program.


reasoning: The paragraph primarily describes what VF's cybersecurity program does: securing information, detecting and responding to incidents, training personnel, managing third-party cyber risk, and maintaining an incident response plan. Although it includes management qualifications and a brief third-party risk reference, the dominant focus is the operation of the cybersecurity risk management program.


reasoning: This paragraph primarily describes an actual cybersecurity incident, including when it occurred and its consequences, so it is Incident Disclosure. The February 2023 timing is a concrete, externally checkable event fact, which supports Quantified-Verifiable specificity.


reasoning: The paragraph primarily describes actual cybersecurity incidents that occurred, including the nature of the unauthorized access and a concrete example involving a vendor incident. Although it ends with a materiality conclusion, the dominant focus is what happened, so Incident Disclosure is the best fit.


reasoning: The paragraph primarily describes what the cybersecurity program does: its control approach, review process, policies, and operational measures such as vulnerability scanning, penetration testing, MFA, training, and incident exercises. Although third-party risk is included as one component, the overall focus is the company’s broader cybersecurity risk management program.


reasoning: The paragraph primarily explains how the Company manages cybersecurity risk from third-party service providers, making third-party risk the central topic. Its use of SOC 1 audits reflects cybersecurity/compliance domain knowledge, but it does not provide firm-unique roles, committees, or verifiable quantified details.


reasoning: The paragraph primarily explains that cybersecurity governance supports alignment with business objectives and regulatory requirements, which most directly relates to how cybersecurity connects to the business. It does not describe board oversight, management roles, or concrete cybersecurity processes in enough detail to fit those categories better.


reasoning: Although the paragraph names management roles and teams, it primarily describes how the cybersecurity program operates: monitoring, detection, escalation, mitigation, remediation, and severity evaluation of threats and incidents. The named internal functions and teams (DTI, CDT, Incident Response team) make the disclosure company-specific.


reasoning: This paragraph is primarily a generalized discussion of cyber threats and industry risk environment, not a description of the company's governance, management structure, risk management process, third-party oversight, incident, or business-impact assessment. It is speculative and boilerplate rather than substantive cybersecurity disclosure.


reasoning: The paragraph primarily provides a cross-reference to another section and only states in generic terms that cybersecurity risk is part of enterprise risk management. It does not substantively describe board oversight, management roles, risk processes, third-party risk, an incident, or business impact.


reasoning: The paragraph primarily describes an actual cybersecurity incident, including its timing, nature, response, operational recovery, and stated impact. Although it also includes materiality and remediation statements, the real-event disclosure is the dominant focus.


reasoning: The paragraph primarily explains which management leaders are responsible for cybersecurity-related functions, how they report, and what experience and qualifications they bring. Although it mentions updates to the Board's Risk Committee, the focus is management organization and leadership expertise rather than board oversight.


reasoning: The paragraph primarily describes management-level committee structure, leadership, composition, and reporting lines for cybersecurity and related governance. It is not focused on board oversight or on the operational cybersecurity program itself, so Management Role is the best fit.


reasoning: The paragraph primarily states a conclusion about whether cybersecurity incidents have materially affected the company’s business, operations, or reputation, which fits Strategy Integration under the materiality rule. The remaining language is generalized commitment and vigilance language rather than a description of governance, management structure, or specific cyber processes.


reasoning: The paragraph primarily gives a materiality-oriented assessment of how cybersecurity threats could affect the business and states that no material cybersecurity incidents were experienced in the last three fiscal years, which fits Strategy Integration under the SEC materiality framing. Its content is largely cross-referential and boilerplate, with no qualifying firm-specific cybersecurity facts such as named roles, committees, frameworks, systems, dates, vendors, or quantified details.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk from vendors by imposing security, insurance, and incident-reporting requirements on third-party providers. It is not about the company's internal security program generally, but about controls applied to external service providers.


reasoning: The paragraph primarily describes what the cybersecurity program does to protect systems and data, including technical controls and employee training, which makes it a Risk Management Process disclosure. It is Firm-Specific because it includes a named internal program and concrete program elements, but no externally verifiable quantified fact.


reasoning: The paragraph primarily provides a materiality assessment, stating that past cybersecurity incidents have not materially affected the company and that certain threats are reasonably likely to materially affect business strategy, results, or financial condition. That makes Strategy Integration the best fit under the SEC materiality rule, despite the largely boilerplate wording.


reasoning: The paragraph primarily describes the company’s cybersecurity program in functional terms—policies, procedures, and systems designed to identify and address cybersecurity risks—rather than board oversight or management structure. Its use of information-security concepts such as confidentiality, integrity, and availability gives it some cybersecurity-specific vocabulary, but it does not include firm-specific or verifiable details.


reasoning: The paragraph primarily describes the oversight and reporting structure for cybersecurity, with the CISO briefing RCSC on cyber risk topics and incidents. That makes it chiefly about governance rather than the operational cybersecurity program itself.


reasoning: The paragraph primarily describes which management leaders oversee cybersecurity and their qualifications, so it is about management organization rather than the underlying security program. It includes specific leadership titles and a quantified experience claim of over 20 years, which makes it externally verifiable.


reasoning: The paragraph primarily describes what the cybersecurity program does—using threat intelligence, internal tools, network monitoring, and vulnerability scanning to identify and manage risk. Although it mentions the Enterprise Cybersecurity team and certifications, those management details are secondary to the operational risk-management activities.


reasoning: The paragraph primarily describes how the board, through its Risk Committee, oversees cybersecurity risk and receives information from management. While it includes some risk-management activities, its main purpose is to explain the board oversight structure and reporting flow.


reasoning: The paragraph primarily describes the existence and purpose of the company's cybersecurity risk management program as part of managing cyber risk, which fits Risk Management Process. It does not meaningfully describe board oversight, management structure, a real incident, or vendor oversight as the central topic.


reasoning: The paragraph primarily describes a real cybersecurity incident, including its disclosure date and the ongoing investigation into its scope. Although it also includes a materiality assessment, the incident narrative is the central focus.


reasoning: The paragraph primarily states management's conclusion that cybersecurity threats and prior incidents have not materially affected, and are not reasonably likely to materially affect, the company's business, results, or financial condition, which is a materiality/business-impact assessment. The remaining language is speculative risk language and a cross-reference, not a description of governance or risk management processes.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks from vendors and other third parties, making third-party oversight the central topic. It describes vendor cyber assessments and contractual incident-notification requirements, which are cybersecurity-specific practices but do not include firm-unique or externally verifiable facts.


reasoning: The paragraph is centrally about how the company evaluates and oversees cybersecurity risks posed by vendors and service providers, which squarely fits Third-Party Risk. Its most specific detail is the named Vendor Management Committee (and Vendor Management team), making it more company-specific than generic process boilerplate.


reasoning: This paragraph primarily describes a real cybersecurity event, including its source, affected data, response, and operational impact, so it is best classified as Incident Disclosure. It includes verifiable facts tied to the widely known MOVEit Transfer incident and the named firm Progress Software Corporation.


reasoning: The paragraph primarily provides a materiality assessment that cybersecurity incidents have not been material to the company's operations or financial condition to date, which fits Strategy Integration under the SEC materiality rule. The rest of the paragraph is generic risk framing and a cross-reference to risk factors rather than describing governance, management, or risk-management processes.


reasoning: The paragraph primarily gives a materiality-oriented assessment that cybersecurity threats, if realized, are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which fits Strategy Integration. It does not describe governance, management roles, or concrete cybersecurity processes, and the remaining language is forward-looking cautionary and cross-referential.


reasoning: The paragraph primarily provides a materiality assessment, stating that the company is not aware of any cybersecurity breaches that materially affected or are reasonably likely to materially affect its business, results, or financial condition. The cross-reference to Item 1A is secondary and does not change the paragraph’s main purpose.


reasoning: The paragraph is primarily about how the company manages cybersecurity risk from suppliers, vendors, and other third parties by imposing contractual security and data-use requirements. Its focus is third-party oversight rather than the company’s internal cybersecurity program or board/management structure.


reasoning: The paragraph primarily frames cybersecurity in terms of business impact and exposure, including the conclusion that the company has not been materially impacted by cyber incidents. Although it discusses third-party exposure and some risk-management activity, the dominant purpose is assessing how cybersecurity threats could affect the company.


reasoning: This paragraph primarily describes management's organizational responsibility for cybersecurity by identifying the CISO as the responsible leader and summarizing his qualifications. The focus is on who manages the program and what experience qualifies him, rather than on board oversight or detailed program activities.


reasoning: The paragraph primarily describes how the Audit Committee oversees cybersecurity through direct engagement with management and receipt of cybersecurity reporting. While it mentions program activities like audits and assessments, those details are presented in service of explaining board-level oversight.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks posed by third-party service providers, making vendor oversight the central topic. It describes general pre-engagement and periodic assessments, but does not provide cybersecurity-specific tools, frameworks, named programs, or other qualifying specific facts.


reasoning: The paragraph primarily explains which management roles are responsible for cybersecurity and describes their experience and reporting structure, which fits Management Role. It includes a quantified, externally checkable claim that both leaders have over 20 years of cybersecurity oversight experience, making it Quantified-Verifiable.


reasoning: This paragraph does not describe any actual cybersecurity governance, management role, or risk management process; it only states general dependence on secure transaction processing and hypothetical consequences of failures or breaches. The reference to third-party vendors is incidental and not a substantive discussion of third-party risk management.


reasoning: The paragraph primarily explains how management is organized to oversee cybersecurity, identifying the responsible manager, reporting line, and that leader’s experience. Although it mentions program responsibilities, those details are framed through the management leader’s role rather than describing the broader cybersecurity process itself.


reasoning: The paragraph primarily provides a materiality and business-impact assessment, stating that cybersecurity threats and incidents have not materially affected results to date while noting effects on business strategy and the potential for future material adverse effects. Its focus is on business/financial impact rather than governance, management structure, or operational cybersecurity processes.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from vendors and service providers, including due diligence and ongoing review of suppliers. Although it ends with a materiality-related clause, the substantive content is centered on third-party cybersecurity oversight.


reasoning: The paragraph primarily describes how board-level committees oversee cybersecurity-related matters and coordinate review responsibilities, which is board oversight structure. It does not provide qualifying firm-specific or verifiable facts beyond generic board committee functions.


reasoning: The paragraph primarily explains which management roles lead cybersecurity and why those individuals are qualified, making it a management-organization disclosure rather than a process description. It also includes verifiable specifics such as named leadership roles, over 25 years of experience, and named professional certifications.


reasoning: The paragraph primarily describes what the company’s cybersecurity program does: protecting information, assessing and managing cyber risks, addressing third-party risk, and identifying and responding to incidents. Although the CSO is mentioned, the focus is on program activities rather than management qualifications or board oversight.


reasoning: The paragraph primarily describes how the Board and its Audit Committee oversee cybersecurity, including the flow of reporting from management to the Board. Although it mentions management participation, the focus is the Board oversight structure rather than management organization or program activities.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk from vendors and other service providers, including selection criteria, contractual obligations, and review of provider cybersecurity practices. Although it contains no firm-unique details, it uses cybersecurity-specific third-party risk management concepts beyond generic business-risk boilerplate.


reasoning: The paragraph primarily describes a real cybersecurity incident involving Change Healthcare, including timing, response actions, operational effects, and investigative findings. Although it ends with a materiality conclusion, the dominant focus is what happened and how the company responded.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from vendors and service providers, making third-party risk the central topic. Although it ends with a materiality-oriented sentence, most of the paragraph focuses on vendor due diligence and ongoing supplier monitoring.


reasoning: This paragraph primarily describes a real cybersecurity incident involving Change Healthcare, including timing, response actions, and operational effects, which makes Incident Disclosure the best fit. Although it also includes a materiality conclusion, the dominant focus is the actual event and the company's response.


reasoning: The paragraph primarily explains how the Board oversees cybersecurity risk through reports, presentations, incident escalation, and interactions with management, which makes it a board oversight disclosure. It also includes firm-specific organizational details such as the CIO, Vice President of Information Security, and the Information Technology Senior Leadership Team.


reasoning: The paragraph primarily provides management’s assessment of whether cybersecurity threats and incidents have materially affected the company’s business, results, financial condition, and strategy, which squarely fits Strategy Integration. Although it mentions insurance coverage and security measures, those points are framed in support of the materiality/impact discussion rather than describing the cybersecurity program itself.


reasoning: The paragraph primarily describes how the Board of Directors oversees cybersecurity risk, including direct oversight and information flowing through quarterly updates. Although it mentions the CIO's responsibility, the main focus is the board-level oversight structure.


reasoning: The paragraph primarily describes how the Board and its Audit Committee oversee cybersecurity risk through management reporting and committee-to-board escalation. Although management is mentioned, the focus is the board-level oversight structure rather than management’s internal organization or the operational cybersecurity program.


reasoning: The paragraph primarily describes how the board, through the Audit Committee, oversees cybersecurity and information technology risk, which is a board oversight function. It does not provide firm-specific cybersecurity roles, committees, tools, or verifiable details beyond generic governance language.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks posed by vendors, service providers, and business partners, making third-party risk the central topic. While it describes concrete practices like security assessments and remediation tracking, it does not include firm-unique names, roles, or verifiable facts.


reasoning: The paragraph primarily provides a materiality assessment that cybersecurity threats have not materially affected and are not reasonably likely to materially affect the company's business strategy, financial condition, or results of operations, which fits Strategy Integration. The cross-reference to Risk Factors is secondary and does not change the primary purpose.


reasoning: The paragraph primarily describes who in management is responsible for cybersecurity and why that person is qualified, focusing on role, reporting relationships, and experience rather than the operational details of the cybersecurity program. It therefore fits Management Role, and the inclusion of quantified experience and named prior employers makes it Quantified-Verifiable.


reasoning: The paragraph primarily gives a materiality and business-impact assessment of cybersecurity threats, which fits Strategy Integration under the SEC Item 106(b)(2) framework. Although it references a real incident, it does not describe the incident's nature, scope, or response in enough detail to make Incident Disclosure the primary category.


reasoning: This paragraph does not provide substantive cybersecurity disclosure itself; it merely cross-references the Risk Factors section for discussion of potential material effects. Under the rules, cross-referential language of this kind is classified as None/Other rather than Strategy Integration.


reasoning: The paragraph primarily describes what the company's cybersecurity program does to prepare for and respond to incidents, including maintaining and testing an incident response plan. It does not focus on board oversight, management qualifications, third-party vendor risk, or a specific incident.


reasoning: This paragraph primarily describes how the board oversees cybersecurity through its committee structure and management reporting flows, which is board-level governance. Its specificity is driven by firm-unique governance details, especially the named Corporate Risk Committee and the CIO/CISO reporting relationship.


reasoning: The paragraph primarily describes a component of the company's cybersecurity program—using external assessors and consultants for threat evaluation, forensic reviews, and security assessments—so it is about what the program does. Although third parties are mentioned, they are hired to support the company's internal security activities rather than being vendors whose risks are being managed.


reasoning: This paragraph primarily discloses a real cybersecurity incident—its nature (ransomware), timing (2021), and outcome—so Incident Disclosure is the best fit. Although it also comments on material impact and accelerated IT initiatives, those details are presented in the context of describing the incident.


reasoning: The paragraph primarily describes the governance and oversight structure for cybersecurity risk, linking management committees and leadership up to the Board of Directors. Although it mentions management processes, the dominant purpose is explaining how cybersecurity risk is escalated, reviewed, and overseen.


reasoning: The paragraph primarily describes how the board is informed about and oversees cybersecurity through direct briefings and education, which is board-level oversight. Its main focus is not management operations or program activities, but the board’s governance structure and information flow.


reasoning: The paragraph’s primary purpose is to assess business impact and materiality, stating that prior incidents, including the August 2023 incident, have not materially affected the company. Although it references a real incident, the dominant disclosure is the conclusion about lack of material effect on the business.


reasoning: The paragraph primarily describes what the company's cybersecurity program does: its framework alignment, threat detection and escalation, security controls, monitoring, training, and continuous improvement. Although management is mentioned, the focus is on operational cybersecurity measures rather than management structure or board oversight.


reasoning: The paragraph primarily gives the company's materiality assessment that cybersecurity threats and prior incidents had not materially affected business strategy, operations, or financial condition, which fits Strategy Integration. The dated conclusion is specific to Microchip, but it is not an externally verifiable cybersecurity fact of the type needed for Quantified-Verifiable.


reasoning: This paragraph does not itself provide substantive cybersecurity disclosure; it only cross-references risk factor disclosures elsewhere in the filing. Under the rules, a pointer to another section for materiality discussion is classified as None/Other.


reasoning: This paragraph is a general introductory statement about the importance of cybersecurity and the purpose of the disclosure, without describing any actual governance, management role, risk process, third-party oversight, incident, or strategy impact. It therefore does not provide substantive cybersecurity disclosure.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk arising from third-party service providers by requiring them to implement appropriate security measures and by assessing their security frameworks. It is not about Tredegar’s internal program generally, but about oversight of vendor security controls.


reasoning: The paragraph primarily describes how management is organized to handle cybersecurity, focusing on the CIO’s role, experience, and the supporting cybersecurity team’s qualifications. Although it mentions control frameworks and solutions, the dominant content is management leadership and credentials rather than the cybersecurity process itself.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from third-party service providers, including onboarding diligence, contractual/security requirements, and reviews of hosted applications. While it includes concrete security practices and references SOC 2 and ISO 27001, it does not provide firm-unique leadership, named internal programs, or externally verifiable company-specific facts.


reasoning: The paragraph primarily provides a materiality assessment, stating that the company has had no material cybersecurity incidents to date and that cyber threats could materially affect business outcomes. The rest is generic cautionary language and a cross-reference to risk factors.


reasoning: The paragraph primarily describes how management is organized to oversee cybersecurity, including the specific management team, its membership, and its responsibilities in incident response and communications. Although the Board and Audit Committee are mentioned as recipients of communications, the focus is on management structure rather than board oversight.


reasoning: The paragraph primarily describes how the company manages cybersecurity risk arising from acquisition targets, including security due diligence, testing, remediation expectations, and contractual protections. Its focus is third-party-related risk management rather than the broader internal cybersecurity program.


reasoning: The paragraph is primarily about management organization and leadership, describing the CSO's responsibilities, reporting role, tenure, and qualifications. It does not focus on board oversight or the underlying cybersecurity processes themselves.


reasoning: The paragraph primarily explains management’s cybersecurity leadership structure, including the senior security officer’s role, reporting line, and qualifications. Although it references incident response and protective policies, those activities are framed through the responsibilities of a specific executive, making management organization the main focus.


reasoning: The paragraph primarily describes management’s cybersecurity organization through the CISO’s qualifications and the composition of the team. Although it also mentions incident response and reporting, the dominant focus is who leads the function and how management is structured to handle cybersecurity.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from third-party service providers, making Third-Party Risk the best fit. While much of the language is process-oriented, the identified participating teams provide a company-specific organizational detail that raises it above generic or purely domain-level disclosure.


reasoning: The paragraph primarily provides the company's materiality assessment that no known cybersecurity threats or incidents had a material impact in the last fiscal year and that certain ongoing risks could reasonably likely materially affect it. That makes it a business-impact/materiality statement rather than a description of governance, management, or operational cybersecurity processes.


reasoning: The paragraph primarily addresses cybersecurity materiality assessment and its effect on the company's business strategy, results of operations, and financial condition, including the conclusion that no such material effect has been identified. Although it mentions an incident response team, that serves as context for the materiality determination rather than being the main focus.


reasoning: The paragraph primarily explains how management is organized for cybersecurity by identifying the CISO's responsibilities, qualifications, and reporting line. Although it mentions board-level review and some program activities, the dominant focus is the CISO's role and management structure.


reasoning: The paragraph primarily describes how management is organized to oversee cybersecurity, focusing on leadership roles, reporting lines, and the qualifications of the Director of IT Infrastructure and Security and the Vice President of Information Technology. Although it briefly mentions cybersecurity responsibilities, the core content is about who leads the function and what qualifies them to do so.


reasoning: The paragraph primarily describes what the company's cybersecurity program does: the frameworks it draws from and the operational measures it uses for prevention, detection, response, training, testing, and resilience. Although it mentions third-party risk and cyber insurance, those are subordinate elements within the broader cybersecurity risk management program.


reasoning: This paragraph primarily describes management organization and responsibility for cybersecurity through the CIO/CSO structure and the CIO’s qualifications. It is not mainly about board oversight or the cybersecurity program itself, so Management Role is the best fit.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from vendors and service providers, making third-party oversight the central topic. It describes cyber-focused due diligence, third-party security risk assessments, and monitoring of provider incidents, but does not include firm-unique or externally verifiable details.


reasoning: The paragraph primarily explains how management is organized and qualified to oversee cybersecurity, focusing on ISC membership and the experience of specific management roles. Its main purpose is not describing the cybersecurity program itself, but who in management is responsible and what expertise they bring.


reasoning: The paragraph is primarily about how the company evaluates and manages cybersecurity risks from third-party vendors, making vendor oversight the central topic. It describes cyber-specific third-party due diligence concepts, but does not include firm-unique roles, committees, named firms, or verifiable facts.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from vendors and service providers, making third-party oversight the central topic. It describes generic practices like third-party risk assessments, requesting security information, and monitoring provider incidents, without firm-specific roles, named programs, or verifiable details.


reasoning: This paragraph describes a generic enterprise risk management role and does not specifically address cybersecurity oversight, management, or processes. Because it lacks substantive cyber-specific content, it fits None/Other.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from third-party service providers, making third-party oversight the central topic. It uses cybersecurity- and vendor-risk-specific language, but does not provide named committees, senior cyber roles, quantified details, or other firm-unique facts that would raise specificity further.


reasoning: This paragraph is a hypothetical risk statement about what a cybersecurity attack could do, not a description of governance, management, processes, third-party risk, strategy assessment, or an actual incident. It is boilerplate speculative language with no substantive cybersecurity program disclosure.


reasoning: This paragraph is only a cross-reference directing the reader to Item 1A for discussion of cybersecurity risks, rather than providing substantive disclosure about governance, management, processes, third-party risk, incidents, or strategy impact. Under the rules, pure cross-references are classified as None/Other.


reasoning: The paragraph primarily provides a materiality-oriented assessment of cybersecurity's actual and potential effect on the company, including the statement that it has not experienced recent material incidents and that future incidents could materially affect business strategy, results, or financial condition. The rest is general cautionary language and a cross-reference, not a description of governance, management, or risk processes.


reasoning: This paragraph primarily describes how the board oversees cybersecurity, including committee-level oversight and escalation in the event of a material incident. Its most distinctive company-specific detail is the named Cybersecurity Sub-Committee of the Board of Directors.


reasoning: This paragraph is an executive biography describing Mr. Smith’s business roles, career history, and appointment dates, not cybersecurity governance, management, risk processes, incidents, third-party risk, or strategy impact. Because it contains no substantive cybersecurity disclosure, it falls under None/Other.


reasoning: This paragraph primarily describes a real cybersecurity event, including when it was discovered, what data was affected, what systems were involved, and the notification response. Although a vendor is involved, the main purpose is to disclose the incident itself rather than explain the company’s third-party risk management approach.


reasoning: This paragraph is primarily a forward-looking risk disclaimer about potential adverse effects of cybersecurity failures or breaches, rather than a substantive description of governance, management, processes, third-party oversight, incident facts, or business-impact assessment conclusions. Its references to cybersecurity processes are generic and the paragraph’s main purpose is cautionary boilerplate.


reasoning: This paragraph is biographical information about the Senior Vice President and Chief Human Resources Officer and does not describe cybersecurity governance, management, processes, third-party risk, incidents, or strategy impact. It is therefore outside the substantive cybersecurity disclosure categories.


reasoning: The paragraph primarily provides the company's conclusion about whether cybersecurity threats or prior incidents have materially affected, or are reasonably likely to materially affect, its business strategy, results of operations, or financial condition, which fits Strategy Integration. The remaining language is cautionary and cross-referential rather than describing governance, management, or specific cybersecurity processes.


reasoning: Although the paragraph mentions the SVP IT, its main focus is on what the cybersecurity program does: monitoring systems, identifying vulnerabilities, and executing an incident response plan. Under the person-removal test, substantial program activity remains, so Risk Management Process is the best fit.


reasoning: The paragraph primarily describes how cybersecurity risk is assessed and incorporated into the company’s broader risk management process, especially through ERM integration and annual evaluations. Although it mentions board oversight via the Audit Committee, that is secondary to the description of the risk management process itself.


reasoning: This paragraph primarily describes a real cybersecurity event, including its timing, affected systems, investigation findings, and outcome, which makes it an incident disclosure. Although it notes the incident was not material, that statement is secondary to the event narrative.


reasoning: The paragraph primarily describes management's organizational responsibility for cybersecurity, including the CIO's role and oversight of internal personnel and external consultants. It focuses more on who is responsible and their qualifications than on the operational details of the cybersecurity program itself.


reasoning: The paragraph primarily describes the board’s oversight of cybersecurity and IT/data security risks, including the board’s receipt of briefings and the allocation of review responsibility within the governance structure. Although it also mentions internal reporting participants and an employee portal, those details are secondary to the board-level oversight description.


reasoning: This paragraph describes a real cybersecurity incident involving AMCA, including when the company was notified and the resulting litigation and regulatory inquiries. Its focus is the occurrence and aftermath of that event, making Incident Disclosure the best fit.


reasoning: The paragraph primarily describes an oversight structure in which a committee informs management and the Board about cybersecurity risk identification and controls, which is a board-governance function. Its specificity comes from firm-specific organizational and program details, especially the named Incident Management and Information Security Plan.


reasoning: The paragraph primarily describes how the company’s cybersecurity program operates by using external specialists for incident response, cyber assessments, and infrastructure support. Although it mentions evaluating and monitoring service providers, third-party risk is not the central topic; the focus is on supplementing internal cybersecurity capabilities.


reasoning: This paragraph primarily describes how management is organized to handle cybersecurity by detailing the responsibilities, experience, and qualifications of the CRO, CIO, and CISO. While it mentions cybersecurity activities, the focus is on who these leaders are and what roles they play rather than on the underlying cybersecurity program itself.


reasoning: The paragraph primarily describes, at a high level, that the company maintains systems and programs to mitigate cybersecurity incidents and continually updates them, which fits the cybersecurity risk management process category. However, it provides no concrete process details and mostly consists of broad risk language and a cross-reference to risk factors.


reasoning: The paragraph primarily assesses whether cybersecurity-related events have affected the company’s business and operations, including the statement that it has not experienced any material adverse events from a security breach or cyber-attack. It does not describe governance, management structure, or a substantive cybersecurity process.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from vendors and service providers, making third-party oversight the central topic. It describes vendor cybersecurity reviews, contractual safeguards, and consideration of third-party risk in response planning, which is more specific than generic risk boilerplate.


reasoning: The paragraph primarily describes a management-level committee and its responsibilities in incident response and escalation. Although it mentions reporting to the Audit Committee and Board, the main focus is the role of the Cyber ERM Committee rather than board oversight itself.


reasoning: This paragraph describes actions taken in response to an actual cybersecurity incident, including interactions with law enforcement, regulators, litigation, and customer remediation measures. Its primary purpose is to explain incident aftermath and response rather than general risk management or business impact.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks posed by vendors and service providers, including requiring security controls and assessing compliance. Although it mentions threat intelligence services, the central topic is oversight of third parties that handle the company's information.


reasoning: The paragraph primarily explains how management is organized to handle cybersecurity by describing the IT Security Team’s responsibilities, the Head of Global IT’s experience, and the team’s qualifications. Although it mentions acquisition-related diligence, that is presented as part of management’s role rather than as a standalone third-party risk program description.


reasoning: The paragraph primarily explains the company's cybersecurity oversight structure through a three-lines-of-defense model that explicitly includes board-level oversight bodies, making board governance the central topic. It is firm-specific because it identifies company-specific roles and organizational bodies such as the CTO, CRO, Technology Leadership Centre, Risk Committee, and Controlling Department.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from vendors and third-party platforms, making third-party risk the central topic. It includes cyber-specific vendor oversight practices such as contractual obligations, monitoring, and review of SOC Reports, but does not provide firm-unique or externally verifiable details.


reasoning: The paragraph primarily explains how cybersecurity risk is incorporated into the company's ERM and audit-planning processes, which is a description of risk management activity rather than board oversight or management qualifications. Although the Audit Committee is mentioned, the central point is the process for evaluating and using cyber risk in enterprise risk assessment.


reasoning: The paragraph primarily gives a company-level materiality/status assessment—stating that no material cybersecurity incidents had occurred as of a specific date—which fits Strategy Integration under the SEC materiality rule. The remaining discussion is largely risk and insurance context rather than describing governance, management structure, or operational security processes.


reasoning: This paragraph primarily describes a real cybersecurity incident, including when it occurred, what happened, the response taken, and the operational effects. Although it also mentions lack of material financial impact, the incident narrative is the dominant purpose.