reasoning: The paragraph describes the company's internal cybersecurity monitoring, detection, and incident response processes. Third-party firms are mentioned as components of the internal program (not the central topic), so this is Risk Management Process rather than Third-Party Risk. The specific cross-functional team composition listing eight named departments is a firm-specific fact, but the third-party firms are unnamed ('specialized managed services firm,' 'leading cyber forensics firm'), so there are no QV-eligible hard facts to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph from Victoria's Secret's 10-K filing.

Content: Describes monitoring, detection, incident response procedures, managed services firm, cyber forensics firm, cross-functional teams, escalation procedures.

Category: This is about the company's internal cybersecurity processes - monitoring, detection, incident response. The third-party firms are mentioned as components of the internal program, not as the central topic. → Risk Management Process

Specificity: Let me check facts:
- "specialized managed services firm" - unnamed → NOT list
- "leading cyber forensics firm" - unnamed → NOT list

- Cross-functional team composition includes specific departments: technology, legal, finance, asset protection, customer care, human resources, stores operations and communications → IS list (Firm-Specific)
- No named frameworks, dates, dollar amounts, or named firms/tools

One IS fact identified in the team composition → Firm-Specific (3), with no QV-eligible facts present.

fact: Cross-functional incident response teams include leaders across technology, legal, finance, asset protection, customer care, human resources, stores operations and communications


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company's internal cybersecurity policies/processes and the services delivered by unnamed third-party providers that support the company's own program. Per Rule 3, external parties hired to serve the company's cybersecurity needs are Risk Management Process, not Third-Party Risk (no requirements are imposed ON vendors; the providers are delivering services FOR the company). No named frameworks, firms, tools, roles, dates, or other IS-list facts are present — all entities are generic ('providers', 'cybersecurity providers and consultants') and all practices listed are common/unnamed.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content: Describes internal policies/processes and use of third-party providers for cybersecurity services. The paragraph lists many services these providers deliver.

Category: This is a mix of Risk Management Process and Third-Party Risk. The paragraph describes the company's own policies first, then extensively describes third-party providers and what they do. The central topic shifts to the providers - they are "a key part" of the strategy, and the bulk of the paragraph lists provider-delivered services. But these providers are serving the company's internal program. Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." Also "Internal processes mentioning vendors as one component → Risk Management Process." Here the vendors are more than one component - they seem central.

The key distinction is that these providers are delivering services for the company's own cybersecurity program rather than being managed as vendors with imposed requirements. Since there's no vendor oversight or requirements being set on them, this is fundamentally about the company's outsourced cybersecurity program, not third-party risk management. I'll categorize this as Risk Management Process.

Specificity: No named frameworks, no named firms (just "providers"), no specific dates, no specific tools, no cybersecurity-specific titles. Generic practices listed. No IS-list facts.

→ Generic Boilerplate (1)


content_category: Management Role

category_confidence: medium

specificity_confidence: medium

reasoning: This paragraph introduces management-level committees and positions responsible for cybersecurity risk, with management as the grammatical subject. The named 'Enterprise Risk Management Committee' (ERM Committee) is a non-generic committee per the IS list, making it Firm-Specific. However, the paragraph is fragmentary and low-confidence on category — it could be Risk Management Process, but the focus on 'committees and individual management positions' points to Management Role.

fact: Enterprise Risk Management Committee


reasoning: The paragraph describes the company's internal cybersecurity processes — policies, awareness training, phishing simulations, breach response procedures, and cultural integration of cyber risk. Third parties are mentioned as part of the scope but the central topic is the company's own internal practices. No named frameworks, roles, tools, dates, or other specific facts appear; all activities described (training, mock phishing, policies) are common practices on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes internal cybersecurity practices - policies, training, awareness programs, testing employee responses (phishing simulations), breach response procedures. Also mentions third parties with access but the central topic is the company's own internal processes.

Category: Risk Management Process - describes internal cybersecurity processes, training, policies, testing.

Third-party is mentioned but only as part of the scope, not the central topic.

Specificity: Let me check for specific facts.
- No named frameworks
- No named roles (mentions "top leadership" which is generic)

- No specific dates, numbers, or tools mentioned
- Common practices like training and phishing simulations described in generic language throughout

This is Generic Boilerplate (1).


reasoning: The paragraph's primary communicative purpose is identifying who leads cybersecurity (the CIO), their reporting line to the President/CFO, their meeting cadence with the Audit Committee, and their prior experience in information security and cybersecurity strategy. While the final sentence describes a process (quarterly NIST review by IT experts), the dominant subject throughout is the CIO as a person — their role, reporting structure, and background. CIO is a cybersecurity-specific title on the IS list, making this Firm-Specific; no QV-eligible hard facts (specific dates, dollar amounts, headcounts, named firms/tools/certifications) reach the two-fact threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. CIO leads cybersecurity risk management (named role)
2. CIO reports to President and CFO (reporting line)
3. CIO meets with Audit Committee (governance)
4. Individual's background/experience described
5. IT experts meet quarterly to review NIST framework

Person-vs-function test: The paragraph describes the CIO's reporting lines, their prior experience, and then describes what IT experts do. The CIO is the grammatical subject for much of it, and the paragraph tells us about the person's background. But it also describes processes (quarterly NIST review).

The core focus here is identifying who manages cybersecurity—the CIO—along with their reporting structure and qualifications. Since the CIO is the main grammatical subject and the paragraph emphasizes the management role and its authority, this falls under Management Role. Looking at the specificity markers: CIO appears on the firm's IS list, making it firm-specific; NIST framework is named, which is sector-adapted; while "Audit Committee," "quarterly," "President," and "CFO" are generic references not tied to any list.

For QV-eligible facts, I need hard verifiable data like dates, dollar amounts, headcounts, named third-party firms, products, certifications, or specific years of experience. None of those are present here. The CIO is a named firm-specific role but doesn't meet QV criteria, and NIST is a framework reference that also doesn't qualify. So I'm left with one IS fact—the CIO designation—which makes this Firm-Specific overall.

fact: CIO leads cybersecurity risk management and strategy

fact: NIST framework referenced

type: framework


content_category: Board Governance

reasoning: The Audit Committee (a board committee) is the grammatical subject overseeing cybersecurity risk policies, making this Board Governance. No firm-specific facts are present — 'Audit Committee' and 'Board' are both on the NOT list as generic governance terms, and no named frameworks, roles, dates, or other specific details appear.

thinking:
Classify this paragraph.

The Audit Committee (board committee) is the grammatical subject, reviewing and overseeing cybersecurity policies. This is Board Governance.

Specificity: "Audit Committee" is generic (on the NOT list), "Board" is generic. No named frameworks, no firm-specific facts. → Generic Boilerplate.


content_category: None/Other

reasoning: This paragraph describes general IT infrastructure dependency and notes that third parties (including BD) host or manage systems. It contains no substantive cybersecurity disclosure — no processes, oversight, incidents, or materiality assessment. It is general business context about IT systems, not a cybersecurity risk management, third-party oversight, or any other disclosure category.

thinking:
Classify this paragraph.

The paragraph describes the company's reliance on IT systems and third-party providers. It's general business language about IT infrastructure dependency. It doesn't describe cybersecurity processes, board oversight, management roles, incidents, or strategy.

It mentions third parties but doesn't describe vendor oversight or security requirements imposed on vendors. It's more of a general business context statement.

This is None/Other - it's general business/IT infrastructure language with no substantive cybersecurity disclosure content.


reasoning: The paragraph's primary communicative purpose is describing how the Audit Committee and Board of Directors receive cybersecurity information — the escalation and reporting structure for oversight. While the CISO is the grammatical subject in the first two sentences, the dominant topic is the board-level oversight mechanism (who gets reported to, under what conditions, and via what cadence). Senior management reporting to the Audit Committee and full Board in significant incidents reinforces the board oversight framing. Specificity is Firm-Specific due to the CISO title (cybersecurity-specific role on the IS list); 'Audit Committee' and 'quarterly' are on the NOT list and do not contribute.

thinking:
Let me analyze this paragraph.

The paragraph describes reporting lines from CISO to Audit Committee, and escalation procedures for significant incidents to the Board. The primary actors are the CISO and senior management reporting TO the board/committee. But the main topic is the reporting/escalation structure.

The grammatical subject shifts: "The CISO reports..." then "members of senior management will report... to the Audit Committee and... to the full Board."

This is about the flow of information upward to the board. The board/Audit Committee is the recipient of reports. The CISO is the primary actor in the first two sentences. But the overall purpose is describing oversight structure - how the board gets informed.

I'm trying to determine whether this is about Board Governance or Management Role. The CISO is the primary actor doing the reporting, which suggests Management Role, but the content also touches on how the Board delegates responsibility and receives information, which could be Board Governance. The paragraph seems to straddle both categories since it's fundamentally about the reporting mechanism between management and the board. The real question is whether this is about the board's oversight mechanism or the CISO's role. Removing the CISO title, the paragraph is still fundamentally about how cybersecurity information reaches the board and Audit Committee—that's the oversight structure. The third sentence reinforces this by showing the escalation path for significant incidents directly to senior leadership and the full Board. This is Board Governance, not a description of the CISO's responsibilities. For specificity, CISO is a firm-specific title, while Audit Committee is generic.

fact: CISO reports cybersecurity threats and incidents to the Audit Committee


reasoning: The paragraph's opening frame is ERM integration ('cybersecurity risk management is integrated into the Company's overall risk management plans, systems and processes'), and the content describes internal processes: reporting cadence, report contents, and program evaluation by experts. Management — not the Board — is the grammatical subject throughout; the Board is a passive recipient of reports. No IS-list facts are present: 'monthly' is a generic cadence, 'internal and external experts' are unnamed, and 'Board of Directors' is standard governance language.

thinking:
Let me analyze this paragraph.

Content: Describes regular cybersecurity reporting to the Board, what reports include, and program evaluation by experts with results reported to senior management and Board.

Category: The paragraph is about integration of cyber risk into overall risk management and reporting to the Board. The Board is receiving reports, but management is providing them. The primary action is about the reporting process and program evaluation - this is about the company's internal risk management processes (ERM integration, monitoring, reporting cadence). The grammatical subject is "management" providing reports, and "our program" being evaluated.

Actually, I'm second-guessing the categorization here. The core of this is management delivering cybersecurity reports to the Board on a regular basis, with program evaluations from internal and external experts feeding into those reports. The Board is the recipient being kept informed, but the real substance is about how the cybersecurity program itself is being monitored and evaluated - that's the Risk Management Process angle. Though I could also frame this as Board Governance since it's about Board oversight and briefing. The grammatical subject is clearly "management," not the Board, so the focus is on what management is doing rather than what the Board is doing. I'm going back and forth on this. The paragraph definitely emphasizes Board reporting and oversight, but the opening explicitly frames it around ERM integration. The core content describes internal processes—management evaluates the program, reports findings to the Board monthly. That's fundamentally about how the cybersecurity program operates within the company's risk management structure, not primarily about Board governance mechanisms. I think Risk Management Process is the right fit here. no named firms, no dates, no numbers—this confirms it's Generic Boilerplate with no specific IS-list facts. Though I keep second-guessing myself on whether the communicative purpose of demonstrating board oversight through regular reporting should push this toward Board Governance, the grammatical structure is clear: management is performing the action, not the board, and the framing is about ERM integration. So Risk Management Process is the right call—the paragraph describes how cybersecurity risk management integrates into the broader risk management system through reporting and evaluation processes.


reasoning: The paragraph is about the people — their tenure, years of experience, and how they gained expertise — satisfying the person-vs-function test for Management Role. Multiple specific durations of experience (19 years, 15 years, 16 years, 4 years, 5 years) provide well over two QV-eligible hard facts.

thinking:
Let me analyze this paragraph.

Content: Describes CFO, CCO, and CIO roles - their tenure, experience, and oversight responsibilities. This is about the people - their qualifications, years of experience, tenure in role.

Category: Management Role - the paragraph is about the persons (CFO, CCO, CIO), their experience, tenure, and qualifications. The person-vs-function test: if you remove the people's credentials and experience, there's very little left.

Wait - CFO and CCO are on the "IS NOT" list (generic C-suite). But CIO is on the "IS" list as a cybersecurity-specific title.

Now I'm looking at the specific tenure figures more carefully. The CIO role is what matters here since it's cybersecurity-specific, while the CFO and CCO are just generic executive titles. I'm seeing multiple quantified experience metrics - years as CIO, years in financial services, years in the CCO role - all with specific numbers attached.

fact: CIO (GC Advisors' CIO)

fact: CFO oversight for over four years

type: quantified

fact: CFO more than nineteen years in financial services

fact: CCO more than 15 years in financial services

fact: CIO over five years in role

fact: CIO more than sixteen years in financial services


reasoning: The Vice President of Corporate Development & Administration is the grammatical subject performing the primary action (reporting to the board), making this Management Role per the tiebreaker rules. However, the paragraph describes the reporting function rather than the person's qualifications or background. The VP title is not a cybersecurity-specific role per the IS list (not CISO, CTO, CIO, or VP of IT/Security), 'regular basis' is a generic cadence, and 'board of directors' is standard governance language — no specific facts survive the validation filter.

thinking:
Let me analyze this paragraph.

The grammatical subject is "our Vice President of Corporate Development & Administration" who reports TO the board. The content is about reporting to the board on cybersecurity matters.

Per Rule 2: "Management role reports TO the board" → Management Role. But wait - let me re-read. The paragraph says the VP reports to the board on cybersecurity matters. The primary actor is the VP (management role), and the action is reporting to the board.

Per the decision rules table:
- "CISO reports quarterly to the Board on..." → Management Role (CISO is primary actor)

So this is Management Role since the VP is the grammatical subject performing the action.

But I'm second-guessing myself on whether this is really about the person or the function. The paragraph doesn't mention qualifications or background—it's describing what the VP does, which is report to the board. That's a function or activity, not a person-focused description. And looking at it more carefully, this isn't about a cybersecurity process or tool—it's about organizational structure and reporting lines, about who reports to whom and on what topics.

The VP is the grammatical subject doing the reporting, which points to Management Role. But I need to consider whether the board's oversight role makes this Board Governance instead. The tiebreaker is the grammatical subject: the VP is the primary actor here, not the board, so this should be Management Role.

Now I'm noticing the title itself—"Vice President of Corporate Development & Administration"—isn't cybersecurity-specific at all. It's a general corporate role, not something like CISO, CTO, or CIO.  The cadence is vague ("regular basis"), the governance structure is generic ("board of directors"), and there are no named frameworks, specific dates, or metrics. This all points to Generic Boilerplate.

So my classification is Management Role, Generic Boilerplate.


reasoning: The Audit Committee is the primary subject being briefed on cybersecurity risks, and the CISO's reporting is framed in terms of what the committee receives — making this Board Governance per Rule 2. The CISO title is a cybersecurity-specific role (IS list), elevating specificity to Firm-Specific, but the cadences ('at least annually'), Audit Committee, and listed report topics are all generic, so there is only one IS-list fact and no QV-eligible facts.

thinking:
Let me analyze this paragraph.

The paragraph discusses the Audit Committee being briefed on cybersecurity risks, and the CISO reporting to the Audit Committee. The primary actor/subject is the Audit Committee in the first sentence, and the CISO reporting TO the Audit Committee in the second.

Category: The Audit Committee is the entity being briefed, and the CISO reports to the Audit Committee. Per Rule 2, "Board delegates responsibility" and "board/committee is the grammatical subject" → Board Governance. The CISO is mentioned in context of reporting to the board committee, not describing the person's qualifications. The second sentence describes what the report covers, which is about the briefing content to the committee.

Specificity: The Audit Committee is a generic governance structure, but the CISO is a firm-specific role, making this Firm-Specific. The cadence and topics mentioned are standard practices without quantifiable details, so there's no Quantifiable Value present.

fact: Chief Information Security Officer (CISO) reports to the Audit Committee


reasoning: The paragraph describes the management oversight structure: who comprises the Risk Management Steering Committee, their experience, and how the CFO, GC, and the committee monitor cybersecurity threats and report to the Audit Committee. While monitoring activities are mentioned, the primary communicative purpose is identifying the management roles and committee responsible for cybersecurity oversight and their reporting lines. The Risk Management Steering Committee is a named non-generic committee (IS list), yielding Firm-Specific; CFO, GC, and Audit Committee are all on the NOT list and do not contribute.

thinking:
Let me analyze this paragraph.

The paragraph describes the Risk Management Steering Committee members' experience and how the CFO, GC, and the committee monitor cybersecurity threats and report to the Audit Committee.

Content category: This is about management's role in monitoring cybersecurity. The grammatical subjects are the committee members and the CFO/GC. It describes what they do (monitor, report) and their qualifications (substantial experience).

The person-vs-function test: The paragraph mentions experience of committee members (about the people) but also describes monitoring and reporting activities (about the function). The dominant content seems to be about the monitoring/reporting function, with experience mentioned as context.

But I'm realizing the committee composition and their experience is actually significant here too. Looking at this more carefully, there are really two distinct parts: the committee members' substantial experience, and then what the CFO, GC, and committee actually do—monitoring threats and reporting to the Audit Committee. The second part is clearly about the function, but the first part is about the people themselves, even if it's generic. The grammatical subjects are management roles, and what matters is what they're doing—monitoring and reporting. The fact that they report to the Audit Committee could suggest Board Governance, but management is the subject here, not the board itself.

I keep going back and forth on this. The dominant content is really about management's monitoring and reporting activities, which makes me lean toward Management Role. But when I test it by replacing the people references with "the Company," the sentence still works as a process description—"The Company monitors prevention, detection, mitigation and remediation of cybersecurity threats and incidents in real time, and reports such threats and incidents to the Audit Committee when appropriate." That reads like a Risk Management Process. The paragraph is fundamentally about the management structure and what they do, so I think Management Role is the right classification here.

Looking at the specificity markers: the Risk Management Steering Committee is a named, non-generic committee that appears to be firm-specific, while the CFO, GC, and Audit Committee are all generic roles on the NOT list. The "substantial experience" language is too vague to count as specific. The Risk Management Steering Committee is the only element that might push this toward Firm-Specific, but it's really just a named committee without detailed qualifications or unique characteristics.

The core question is whether this is about the people or the function. The paragraph focuses on monitoring and reporting activities—the management structure and what it does—rather than on individual qualifications or credentials. That points toward Management Role. The function being described is the oversight structure itself, not a specific cybersecurity process or technical control.

I'm settling on Management Role because the paragraph is fundamentally about the governance structure—which roles are involved in monitoring and where they report—rather than about firm-specific details or individual qualifications.

fact: Risk Management Steering Committee (named non-generic committee)


reasoning: The paragraph describes the company's internal process of re-examining systems after risk assessments and continuously evaluating cybersecurity risks—this is about the function, not the person. The 'head of our IT department' is a generic IT title (on the NOT list), CFO is generic C-suite, and no named frameworks, dates, tools, or other specific facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes re-examining systems after risk assessments, and the head of IT reporting to CFO working with management to evaluate cybersecurity risks.

Category: This describes processes (re-examining systems, ensuring safeguards, evaluating risks) with a brief mention of who does it. The person-vs-function test: the paragraph is about what happens after risk assessments and how risks are evaluated. The "head of our IT department" is mentioned as attribution. Remove the role info and it still describes a process. → Risk Management Process.

Wait - "head of our IT department" - is this a cybersecurity-specific title? Looking at the IS list: "CISO, CTO, CIO, VP of IT/Security, Information Security Officer, Director of IT Security..." - "head of our IT department" is more like "Head of IT" which is on the NOT list: "Head of IT", "IT Manager", "Director of IT" are generic IT titles, not cybersecurity-specific.

The reporting structure to the CFO is also generic C-suite, not a cybersecurity-specific indicator. There's no mention of named frameworks, specific methodologies, dates, numbers, or tools—just vague language about re-examining systems and evaluating risks. This is boilerplate language without substantive detail.


content_category: Third-Party Risk

reasoning: The paragraph's central topic is oversight of external parties: engaging a vendor to review the security program, conducting due diligence on third-party providers, and requiring them to meet security standards. While the first sentence touches on the company's own program being reviewed (Risk Management Process), the dominant content is about managing third-party cybersecurity risk. No named firms, frameworks, dates, or other specific facts appear — all entities are unnamed ('independent cybersecurity vendor,' 'third-party service providers').

thinking:
Let me analyze this paragraph.

Content: Talks about an independent cybersecurity vendor reviewing the security program, acknowledges third-party risks, describes due diligence on third-party providers, and requiring them to adhere to security standards.

Category: The central topic is oversight of external parties - vendor due diligence, requiring third parties to meet security standards. This is Third-Party Risk.

Specificity: Let me check for specific facts:
- "The Manager" - generic
- "independent cybersecurity vendor" - unnamed
- "third-party service providers" - generic

- "personally identifiable information" - generic term
- No named frameworks, no dates, no specific numbers, no named firms

This is generic boilerplate with no concrete details or IS-list facts.


reasoning: The paragraph describes the Enterprise Risk Council — a management committee responsible for cybersecurity — its composition (CISO as member, VP Internal Audit as chair, cross-functional employees), and meeting cadence. Per the codebook, 'management committees responsible for cybersecurity' falls under Management Role. While the council's risk management activities are mentioned, the primary content is organizational structure (who is on the committee, who chairs it, how often it meets). Specificity is Firm-Specific: CISO (cybersecurity-specific title) and Enterprise Risk Council (named non-generic committee akin to ERM Committee) are both on the IS list, but neither counts toward QV thresholds.

thinking:
Let me analyze this paragraph.

Content: Describes the CISO as a member of the Enterprise Risk Council, which handles risk identification/assessment/management. Chaired by VP Internal Audit, meets quarterly.

Category: This is about a council/committee structure and its risk management activities. The CISO is mentioned as a member, but the paragraph is about the Enterprise Risk Council's function - risk identification, assessment, management, monitoring. The primary subject is the council and what it does. This is a management-level committee (not board), so it's not Board Governance.

The paragraph focuses on the Enterprise Risk Council as a management committee responsible for cybersecurity, with the CISO's membership and reporting structure through the VP Internal Audit. This fits the Management Role category since it describes a management committee responsible for cybersecurity and its organizational structure. Looking at the specific elements mentioned here: CISO is a named cybersecurity role that counts toward the IS list, and the Enterprise Risk Council is a named non-generic committee that also qualifies. Since named roles and committees don't contribute to the QV score, this paragraph ends up being Firm-Specific at level 3.

fact: CISO is a standing member of the Enterprise Risk Council

fact: Enterprise Risk Council (named management committee)

fact: VP, Internal Audit chairs the council


reasoning: The paragraph describes the company's internal cybersecurity measures organized into technical/physical and organizational safeguards, covering monitoring, encryption, incident response, training, and vendor risk management — all internal process descriptions. Despite being lengthy and detailed in structure, every item listed is a common/generic security practice (vulnerability scans, encryption, access controls, incident response plans, employee training, business continuity). No named frameworks, tools, roles, dates, or firm-specific facts appear.

thinking:
Let me analyze this paragraph.

Content: Describes the company's internal cybersecurity measures - technical, physical, and organizational safeguards. This is clearly about internal processes and controls.

Category: Risk Management Process - describes internal processes, tools, methodologies.

Specificity: Let me check for specific facts:
- No named frameworks (NIST, ISO, etc.)
- No named tools/products
- No named roles (CISO, etc.)
- No dates, dollar amounts, headcounts
- No named third-party firms
- All items are common practices: monitoring, vulnerability scans, encryption, access controls, incident response plans, training, risk assessments, vendor risk management, business continuity

- Everything here is standard industry practice with no company-specific details, so this falls into generic boilerplate.


content_category: Strategy Integration

reasoning: While the paragraph opens with a brief description of the 2024 Cybersecurity Incident (unauthorized activity, operational disruptions, online ordering impact), the dominant content — approximately 70% of the text — addresses financial and business consequences: $3M remediation costs, $11M lost revenue, $10M EBITDA impact, cybersecurity insurance, future cost expectations, and materiality assessments. Per Rule 4 (Incident vs. Strategy), when the financial/business impact discussion dominates over the incident narrative, the paragraph is Strategy Integration. Multiple dollar amounts and specific dates easily exceed the two-fact QV threshold.

thinking:
Let me analyze this paragraph from Krispy Kreme's 10-K filing.

This paragraph describes a cybersecurity incident AND its financial impact. Let me apply the category tiebreakers.

The paragraph covers:
1. Description of what happened (unauthorized activity, operational disruptions, online ordering affected)
2. Financial impact ($3M remediation, $11M lost revenue, $10M EBITDA impact)
3. Cybersecurity insurance mention
4. Materiality assessment
5. Cross-reference to Risk Factors

This is a mixed paragraph. The dominant content is about the financial/business impact of the incident. Let me re-read the tiebreakers:

- "Paragraph DESCRIBES what happened in an incident (dates, access, encryption, scope, response actions) → Incident Disclosure"
- "Paragraph ONLY discusses financial cost, insurance, or materiality of an incident WITHOUT describing the event → Strategy Integration"

This paragraph does both - it describes what happened AND discusses financial impact extensively. The incident description is brief (first few sentences), while the bulk is about financial impact ($3M, $11M, $10M, insurance, future costs). Looking at the dominant category rule, the paragraph starts with incident description but the majority of the text focuses on financial impact, costs, insurance, and materiality, so this should be categorized as Strategy Integration.

Let me break down the content: the opening sentences cover what happened and current status, but sentences three through eight are almost entirely about materiality statements, remediation costs, lost revenue, EBITDA impact, future costs, and cybersecurity insurance. The financial and strategic implications clearly dominate the paragraph's focus, making Strategy Integration the stronger classification despite the incident description at the start.

Now I'm counting the specific, quantifiable facts that would qualify for disclosure: the December 11 date, the fiscal quarter reference, the $3 million remediation figure, and the $11 million revenue loss are all concrete data points that support the financial impact narrative.

fact: December 11, 2024 (8-K filing date)

fact: Fourth quarter of fiscal 2024

fact: Approximately $3 million in remediation expenses

fact: $11 million in lost U.S. segment revenue

fact: $10 million estimated impact on Adjusted EBITDA


reasoning: The paragraph describes the company's risk-based approach and a management-level Cybersecurity Steering Committee, listing its four functional charges (risk oversight, policy review, security initiative assessment, strategic direction). Applying the person-vs-function test: removing the CSO title and Chief Legal Officer reference, the paragraph still describes what the committee does — its processes and mandate — making this Risk Management Process rather than Management Role. The CSO (cybersecurity-specific title) and the uniquely named 'Cybersecurity Steering Committee' are firm-specific facts, but no QV-eligible hard facts (dates, dollar amounts, headcounts, named third-party firms/tools) are present.

thinking:
Let me analyze this paragraph.

Content: Describes a risk-based approach, mentions interim Chief Legal Officer and CSO co-chairing a Cybersecurity Steering Committee, then lists the committee's charges (oversight of security risks, reviewing policies, assessing security initiatives, providing strategic direction).

Category: This is about the company's internal cybersecurity processes and governance structure. The Cybersecurity Steering Committee is a management-level committee. The paragraph describes what the committee does (its functions/charges). The CSO is mentioned but the paragraph is about what the committee does, not about the person. This is Risk Management Process - it describes internal processes, committee functions, and how the company approaches cybersecurity risk management.

The committee is clearly management-level since it's chaired by the interim Chief Legal Officer and CSO rather than board members. The core of the paragraph focuses on the committee's responsibilities and charges rather than just its composition, so this is fundamentally about the function and processes of cybersecurity governance.

Looking at the specificity markers: the CSO is a named cybersecurity role, and the Cybersecurity Steering Committee is a named committee with a specific abbreviation—both are firm-specific facts. The interim Chief Legal Officer is a generic title. There are no quantifiable elements like dates, dollar amounts, headcounts, named vendors, or certifications, so this doesn't qualify for QV. The presence of the CSO and the named committee makes this firm-specific information.

fact: CSO (Chief Security Officer) co-chairs the committee

fact: Cybersecurity Steering Committee ('Steering Committee') — named internal program with unique identifier


reasoning: The paragraph describes the company's internal cybersecurity processes: risk assessments, real-time monitoring, third-party penetration testing, and industry forum participation. Third parties are mentioned as a component serving the company's own program, not as a vendor oversight topic, so this is Risk Management Process. It names FFIEC, FDIC, and UDFI as regulatory frameworks/bodies guiding assessments, which qualifies as Sector-Adapted, but the remaining content (monitoring, penetration testing, industry forums, third-party experts) consists of common practices and unnamed entities that do not reach Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes internal risk assessment processes, monitoring mechanisms, third-party engagements for testing, and industry forum participation.

Category: Risk Management Process - describes the company's internal cybersecurity processes (risk assessments, monitoring, penetration testing, industry forums). Third parties are mentioned as a component of internal processes, not as the central topic of vendor oversight.

Specificity: Let me check for specific facts.
- FFIEC - this is a named regulatory body/standard
- FDIC - named regulator
- UDFI - named regulator

- FFIEC qualifies as Sector-Adapted since it's regulatory guidance similar to a framework reference, while UDFI is firm-specific because it identifies the company's state regulator in Utah. I'm realizing that regulators themselves aren't explicitly listed in either category, so I need to reconsider the classification. FFIEC functions as a recognized regulatory standard for the financial sector, which points toward Sector-Adapted. UDFI is jurisdiction-specific to Utah, but identifying which state regulators apply isn't really a firm-specific characteristic in the codebook's sense—it's more about regulatory jurisdiction. The remaining items like risk assessments, monitoring, and penetration testing are standard industry practices that don't differentiate this company. I'm going back and forth on whether UDFI counts as firm-specific or just sector-adapted context. State regulatory jurisdiction is really just jurisdictional framing rather than something that reveals details about their actual cybersecurity practices, so I'll stick with calling it sector-adapted.

fact: FFIEC regulatory guidance used as basis for risk assessments

fact: FDIC as a named regulator

fact: UDFI (Utah Department of Financial Institutions) as a named state regulator


reasoning: Despite the heading referencing 'Management's Role,' the paragraph's primary communicative purpose is describing how the audit committee maintains informed oversight through quarterly briefings. The bullet points detail what the committee is briefed on, framing the audit committee as the recipient ensuring transparency and informed decision-making. No specific facts from the IS list are present — 'audit committee' is generic governance, 'quarterly' is a generic cadence, and all bullet-point topics are boilerplate categories any company could list.

thinking:
Let me analyze this paragraph carefully.

Content Category: The paragraph is titled "Management's Role Managing Risk" but describes quarterly briefings provided by management TO the audit committee. The content lists what these briefings cover (policies, threats, incidents, investments, compliance).

Who is the primary actor? "Members of management" provide briefings to the audit committee. The paragraph is about what management reports to the board committee - this is about the management's role in communicating upward. But the board/committee is receiving the briefings, and the paragraph describes what topics are covered in those briefings.

This is a borderline Board Governance vs Management Role case.

Management is the grammatical subject providing briefings to the audit committee, which suggests a Management Role classification. But the real focus here is the reporting relationship and communication channel between management and the board, with the committee receiving these reports to make informed decisions. The title emphasizes "Management's Role Managing Risk," and management is clearly the actor driving these briefings, so despite the board oversight element being present, the primary focus is on what management is doing and reporting. with the briefing structure itself—management provides updates on cybersecurity topics to the audit committee. The key question is whether this categorizes as a management role description or a risk management process. Given that the paragraph emphasizes what gets communicated and the oversight mechanism rather than specific management responsibilities or qualifications, I'm leaning toward Risk Management Process, since the substance focuses on the cybersecurity program components being reported on. I'm going back and forth on this, but the core issue is what the paragraph is really communicating. The title says "Management's Role," but the actual content focuses on how the audit committee receives briefings to maintain oversight. Looking at the specifics—"audit committee," "quarterly briefings," generic topics with no named roles or frameworks—this feels like generic boilerplate describing a standard governance mechanism rather than anything substantive about management's actual cybersecurity responsibilities. I'm settling on Board Governance because the primary purpose is explaining how the board stays informed, not detailing management's specific actions or processes.


reasoning: The paragraph primarily describes cybersecurity processes and functions — policy implementation, protection/detection/response oversight, incident monitoring, training programs, and coordination with IT — with the DPIRC as the entity performing them. Applying the person-vs-function test: removing the DPIRC label, the paragraph still describes substantive cybersecurity processes, making this Risk Management Process rather than Management Role. The DPIRC, Enterprise Risk Committee, and CISO are firm-specific facts but none are QV-eligible (no dates, dollar amounts, headcounts, named firms, or named tools), so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes DPIRC responsibilities - implementing/reviewing cybersecurity policies, overseeing protection/detection/response, promoting cybersecurity risk posture, reviewing best practices, strategic direction, training oversight, monitoring incidents through risk program and IR/BCP plans, coordinating with IT departments. Also mentions Enterprise Risk Committee receiving quarterly updates from CISO.

Category: This is primarily about what the DPIRC does - its functions and responsibilities. The DPIRC seems to be a management committee. The paragraph describes processes and oversight activities. The last sentence mentions the Enterprise Risk Committee and CISO.

The key distinction here is that the paragraph focuses on operational functions and processes rather than the committee structure itself. Even though DPIRC is a management body, the content emphasizes what it does—implementing policies, overseeing detection and response capabilities, monitoring incidents—which makes this fundamentally about risk management processes rather than a management role definition. The paragraph describes cybersecurity processes and governance structures, with DPIRC as the performing entity. The key specificity markers are the named committees (DPIRC and Enterprise Risk Committee) and the CISO role, which are all firm-specific but not independently verifiable. There aren't enough hard facts like dates, metrics, or named external entities to qualify for QV eligibility.

fact: DPIRC (named management committee overseeing cybersecurity)

fact: Enterprise Risk Committee

fact: CISO


reasoning: The paragraph is entirely about the person — their expertise, security leadership background, patents, and education. This is Management Role per the person-vs-function test. The cybersecurity-specific title (Chief Security and Cash Operations Officer) and named university (Midwestern State University) are firm-specific facts, but only the named university is QV-eligible; 'multiple patents' lacks a specific count, so only one hard verifiable fact exists, yielding Firm-Specific rather than Quantified-Verifiable.

thinking:
Classify this paragraph about NCR Atleos Corp's Chief Security and Cash Operations Officer.

The paragraph is about the person - their expertise, background, patents, degree. This is Management Role.

Specific facts:
- "Chief Security and Cash Operations Officer" - cybersecurity-specific title (named_role)
- "multiple patents for systems and methods related to information security risk assessment" - other_specific
- "Midwestern State University" - named university in credential context (QV-eligible)

QV check: Named university (QV-eligible) + ... what else? "Multiple patents" is vague. No specific dates, dollar amounts, headcounts, named firms, named tools, named certifications.

I've got the named university as one QV-eligible fact, but "multiple patents" doesn't give me a specific number, and there's nothing else that qualifies—no dates, amounts, or named entities beyond that. That leaves me with just one QV-eligible fact, so this classifies as Firm-Specific.

fact: bachelor's degree from Midwestern State University


reasoning: The paragraph is entirely about the persons filling cybersecurity leadership roles — their years of experience, career backgrounds, and professional certifications. Multiple QV-eligible hard facts: specific years of experience for both CDIO and CISO (25 years each), plus multiple named certifications (CISSP, CISM, CEH, CRISC, PCI DSS ISA).

thinking:
Let me analyze this paragraph.

Content: Describes CDIO's experience (25 years, Fortune 500), CISO's experience (25 years, Fortune 100), and team certifications (CISSP, PCI DSS ISA, CISM, CRISC, CEH).

Category: This is about the persons - their qualifications, experience, credentials. → Management Role

Specificity: Let me count facts.
- CDIO = cybersecurity-specific title? Actually CDIO = Chief Digital and Information Officer. This is somewhat specific. Let me check the IS list...

CIO is listed, so CDIO qualifies as close enough. Looking at the specific credentials and experience: both leaders have over 25 years in their respective roles, and the team holds multiple named certifications including CISSP, CISM, CEH, CRISC, and PCI DSS ISA—that's well over the threshold for qualification-eligible content.

fact: CDIO with over 25 years of executive experience

fact: CISO with over 25 years of industry experience

fact: CDIO (Chief Digital and Information Officer)

fact: CISSP certification

fact: PCI DSS Internal Security Assessor certification

fact: CISM certification

fact: CRISC certification

fact: CEH certification


reasoning: The paragraph describes what the cybersecurity team and Incident Response Team do — overseeing operations, monitoring prevention/detection/mitigation, coordinating incident reporting. The CISO is mentioned as attribution, but the substantive content is about processes, team functions, and reporting workflows. Removing the CISO title, the paragraph still describes the company's incident response program. Firm-Specific due to multiple IS-list facts (CISO, CIO, specific departmental composition of the IRT, named 'Strategy Board' committee) but no two QV-eligible hard facts.

thinking:
Let me analyze this paragraph from PHINIA INC.'s 10-K filing.

Content category: This paragraph describes the cybersecurity team's responsibilities, the Incident Response Team composition, and how they monitor and respond to incidents. The CISO is mentioned but as attribution - the paragraph is about what the team/program does, not about the person's qualifications. This is Risk Management Process.

Wait, let me reconsider. The paragraph describes team composition extensively - "consists of our CISO and other senior leaders from the Company's cybersecurity (composed of information security and technology operations), compliance, legal, financial reporting and other key business and corporate functions." It also describes the Disclosure Committee coordination and reporting chain to Strategy Board, Audit Committee, and Board.

The core focus is on the function and processes - what the cybersecurity team does, how the Incident Response Team operates, their monitoring and response capabilities, and the reporting structure up through the Strategy Board and Audit Committee. Even if I remove the CISO title, the paragraph still clearly describes the operational processes and governance structure, so this is Risk Management Process. The specific team compositions across cybersecurity, compliance, legal, and financial reporting are listed, and the Strategy Board membership is named, which indicates these are disclosure-relevant lists.

fact: CISO leads the cybersecurity team

fact: Incident Response Team composed of cybersecurity (information security and technology operations), compliance, legal, financial reporting and other key business and corporate functions

fact: Strategy Board (consisting of CEO, CFO, General Counsel, CIO and other members of management)

fact: CIO is a member of the Strategy Board


reasoning: The paragraph briefly mentions a past ransomware incident (October 2021) but its primary communicative purpose is the materiality assessment — stating the attack 'had a material adverse impact on our business strategy, results of operations or financial condition.' Per the tiebreaker rule, a brief mention of a past incident combined with a materiality conclusion as the main point yields Strategy Integration. The cross-reference to Risk Factors does not change this classification since a materiality assessment is present. Specificity is Firm-Specific: 'October 2021' is one QV-eligible date, but only one hard verifiable fact, so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph discusses past cybersecurity incidents (ransomware attack in October 2021) and their material impact, then cross-references Risk Factors.

Content category analysis:
- It mentions a past incident (October 2021 ransomware attack) with material adverse impact
- It includes a materiality assessment ("material adverse impact on our business strategy, results of operations or financial condition")
- It cross-references Risk Factors

This is tricky. The paragraph describes a past incident briefly AND makes a materiality assessment. Per the tiebreakers: "Brief mention of a past incident + materiality conclusion as the main point → Strategy Integration." The incident is mentioned but not described in detail (no response actions, no scope details).

The core issue here is that the paragraph's primary focus is establishing the business impact and risk context of the October 2021 ransomware attack, with the materiality assessment serving as the main point rather than incident details. The specificity of the date (October 2021) makes it QV-eligible, though the incident type itself is generic.

fact: October 2021 ransomware attack


reasoning: The Board of Directors is the primary grammatical subject, delegating cybersecurity oversight to the Audit Committee and describing escalation paths — classic board governance framing. No cybersecurity-specific roles (just 'an employee of the Manager'), no named frameworks, no named committees beyond the generic Audit Committee, and no specific dates or numbers, so this is Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Board oversight, delegates to Audit Committee, an employee of the Manager handles day-to-day oversight and escalates to Audit Committee/Board.

Category: The Board is the primary grammatical subject. It describes board oversight, delegation to Audit Committee, and briefly mentions management. The board/committee is the frame. → Board Governance

Specificity: Let me check facts:
- "Board of Directors" — generic (NOT list)
- "Audit Committee" — generic (NOT list)
- "an employee of the Manager" — no named role, generic
- No frameworks, no dates, no named roles (CISO etc.), no specific facts

- This is generic boilerplate with no concrete details or named entities.


reasoning: The paragraph primarily describes the company's internal security program and the array of protective technologies employed (firewalls, IPS, SIEM, MFA, etc.), making it a process/function description. Applying the person-vs-function test: the Chief Security & Cash Operations Officer is mentioned as attribution for who directs the program, but the substantive content is about what the program does and what tools it uses. The tail end discussing Chief Compliance Officer reporting channels to the Board is secondary. Specificity is Firm-Specific due to the unique cybersecurity-specific title ('Chief Security & Cash Operations Officer') and the named internal organization ('Global Information Security'), but the security tools listed are generic categories (not named vendor products), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes:
1. Chief Security & Cash Operations Officer directing the Global Information Security organization
2. The organization's responsibility for implementing/maintaining an info security program
3. Various security tools and methods (firewalls, IPS, DoS detection, anomaly detection, AV/AM, endpoint encryption, EDR, SIEM, identity management, security analytics, MFA, encryption)
4. Chief Risk Officer and Chief Compliance Officer having channels to the Board
5. Chief Compliance Officer overseeing investigations and reporting to Board committees

6. The Chief Security & Cash Operations Officer title is company-specific, so that's an IS list fact, while the tools mentioned are generic industry practices rather than named products, making the core content about the Risk Management Process itself.


reasoning: The paragraph describes the cybersecurity team's functions — overseeing operations, implementing programs, incident monitoring, prevention/detection/mitigation/remediation, and reporting processes. Although CISO is mentioned multiple times, it serves as attribution; the substantive content is about what the team and program do, not the person's credentials or background. Applying the person-vs-function test, the paragraph still makes sense if you replace 'CISO' with 'the Company.' Firm-Specific because it names cybersecurity-specific roles (CISO, CIO), a specific team composition (information security, technology operations, compliance, legal, financial reporting), and a named non-generic committee (Strategy Board with enumerated membership), but lacks two hard verifiable facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools).

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph describes the cybersecurity team's structure and what it does - overseeing operations, implementing programs, incident response coordination, reporting chains. The CISO is mentioned multiple times but as attribution for what the team/program does. Applying the person-vs-function test: if I remove the CISO title, the paragraph still describes the team's functions, processes, and reporting structure. The primary content is about processes and organizational functions, not about who the CISO is as a person.

However, there's significant organizational structure detail here - the composition of the Incident Response Team, the Disclosure Committee, the Strategy Board composition.

Now I'm looking at how the company structures its incident response and reporting workflows. The key specificity question is whether the named committees and their compositions count as IS facts - the Disclosure Committee, Strategy Board with its specific members like the CEO and CFO, and the Incident Response Team's cross-functional makeup all represent internal governance structures that would be considered IS facts.

fact: Incident Response Team composed of CISO and senior leaders from cybersecurity (information security and technology operations), compliance, legal, financial reporting and other key functions

fact: Strategy Board consisting of CEO, CFO, General Counsel, CIO and other members of management

fact: Disclosure Committee involved in incident reporting


reasoning: The paragraph's frame is the Board's responsibility for cyber risk oversight, with the Risk Committee described as part of the governance apparatus — identifying enterprise-level risks and making materiality determinations. While the Risk Committee is a management-level body, its function here is governance and oversight rather than operational cybersecurity processes, and the Board's oversight role anchors the paragraph. The named 'Risk Committee' is a non-generic committee on the IS list, yielding Firm-Specific; no second QV-eligible hard fact is present to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content category: The paragraph starts with Board oversight but then shifts to describing a Risk Committee comprised of senior management. The Risk Committee is a management-level committee, not a board committee. The dominant content is about the Risk Committee's responsibilities.

Wait - "Risk Committee" comprised of members of senior management. This is a management committee, not a board committee. The board is mentioned in the first sentence, but the bulk is about the management Risk Committee.

Actually, let me re-read. "Our Board of Directors is responsible for the Company's cyber risk oversight." - one sentence about the board. Then the rest describes a Risk Committee of senior management.

The paragraph is really describing the governance structure and oversight roles - the Board sets the responsibility, and the Risk Committee (made up of senior management) carries out the actual risk identification, assessment, and management functions. So this is about organizational structure and how oversight responsibilities are distributed. I'm going back and forth on this, but I think the key is that the paragraph frames everything around the Board's responsibility for oversight—the Risk Committee is just the mechanism through which that oversight happens. So this should be categorized as Board Governance, since the primary purpose is disclosing the governance structure, not describing a management process or individual credentials. The Risk Committee's responsibilities center on governance and oversight—determining materiality and establishing the oversight framework—rather than describing how risk management actually operates. Since the Risk Committee appears on the IS list, this lands in Firm-Specific classification under Board Governance.

fact: Risk Committee — a named non-generic management committee


reasoning: The paragraph's primary communicative purpose is describing the company's internal cybersecurity program — processes (risk management, access control, incident response), departmental structure, and annual assessment methodology. The materiality disclaimer at the end is subordinate to the extensive process description. Two named third-party firms (AON, plc and Netdiligence) are QV-eligible hard verifiable facts, meeting the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

This is a lengthy paragraph covering multiple topics. Let me identify the dominant category.

Content: Describes the company's information security program, processes (risk management, access control, anti-virus, etc.), the IT Department and IT Security Department structure, outsourcing of risks, annual assessment process involving AON plc and Netdiligence, and ends with a materiality disclaimer.

The dominant content is about the company's internal cybersecurity processes - risk assessment methodology, vulnerability management, framework/program description. The materiality statement at the end is subordinate.

Category: **Risk Management Process** - the paragraph primarily describes the company's internal processes, tools, and methodologies for managing cybersecurity risk.

Now I'm pulling out the specific facts that matter. The IT Security Department is mentioned as a named internal team, and I can see two third-party firms called out explicitly: AON, plc and Netdiligence, both of which are involved in the annual assessment process. The Human Resources Department also gets a mention for coordination purposes.

So that gives me two QV-eligible facts from the named third-party firms. Looking at the overall structure, though, the paragraph is primarily focused on the risk management process itself—that's the dominant theme here. There's a materiality statement at the end, but the risk management framing is what carries the weight of the content.

fact: AON, plc engaged as cyber insurance broker for benchmarking evaluation

fact: Netdiligence engaged for vulnerability and penetration testing

fact: IT Security Department as named internal cybersecurity department

fact: Coordination with Human Resources Department for training and onboarding


reasoning: The paragraph opens with the Board of Directors authorizing the Audit Committee to oversee cybersecurity risks, framing the entire governance structure. The Risk Committee and CISO reporting details are subordinate to this board-level oversight framework — the Board delegates to Audit Committee, which receives reports from the CISO about risks assessed by the Risk Committee. The Risk Committee (a named non-generic committee) and CISO (cybersecurity-specific title) are firm-specific facts, but no QV-eligible hard facts (dates, dollar amounts, named firms, headcounts) are present.

thinking:
Let me analyze this paragraph carefully.

Content category: This paragraph has mixed signals. Let me break it down:

1. "The Fortrea Audit Committee has been authorized by the Board of Directors to oversee risks from cybersecurity threats." — Board Governance (Audit Committee authorized by Board)
2. "We have established a Risk Committee chaired by the CISO and chartered to determine and execute the processes for the identification, and management of material cybersecurity risks." — This describes a Risk Committee (named non-generic committee) chaired by CISO - this is about organizational structure/management.
3. "The Risk Committee is comprised of cross-functional executive leaders who can assess materiality impact and are accountable for materiality disclosure." — Risk Committee composition

4. "The CISO is responsible for reporting on the state of cybersecurity to the Audit Committee on a quarterly basis, including those risks deemed material by the Risk Committee." — This establishes the reporting chain where the CISO feeds material risks identified by the Risk Committee up to the Audit Committee.

The paragraph starts with Board authorization but then shifts to describing the Risk Committee and CISO's role. The dominant content is about the organizational structure—the Risk Committee, its charter, composition, and the CISO's reporting relationship to the Audit Committee. Per Rule 2, the Board delegates responsibility to the Audit Committee, which then oversees the Risk Committee's work through the CISO's quarterly reports.

The key question is whether this is Board Governance or Management Role. The opening frames Board delegation to the Audit Committee, but the substance describes how the Risk Committee and CISO function within that governance structure. Since there's no discussion of the CISO's credentials or background—only their organizational function and reporting obligations—and since the ultimate authority flows from the Board through the Audit Committee, this reads as Board Governance establishing the oversight framework.

Looking at specificity: Risk Committee and CISO are firm-specific facts, but "cross-functional executive leaders" is too vague, and "quarterly" is just a generic cadence. There are no dates, amounts, headcounts, or named tools—so this lands in Firm-Specific (3).

fact: Risk Committee chaired by the CISO

fact: CISO chairs Risk Committee and reports to Audit Committee


reasoning: The paragraph's primary communicative purpose is describing how the Cybersecurity Program is assessed — by Internal Audit, an independent third-party, and regulators — making it about internal assurance processes rather than board oversight. Board committees (BAC, BOTC, board of trustees) appear as recipients of reports, not as the grammatical subjects performing oversight actions. The BOTC is a named non-generic committee unique to this company's governance structure, pushing specificity to Firm-Specific, but there are not two hard QV-eligible facts (no specific dates, dollar amounts, named third-party firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: Describes how Morgan Stanley's Cybersecurity Program is assessed - by Internal Audit Department (IAD), reported to Audit Committee and BOTC, annual third-party review, and regulatory examination.

Category: This is about risk management processes - specifically assessment/audit of the cybersecurity program. The mention of boards/committees is in the context of reporting results, not about board oversight as the primary topic. The primary topic is the assessment activities themselves. Actually, let me reconsider - the paragraph describes assurance activities, audit, third-party review, and regulatory examination of the program.

The subjects are IAD, third-party, regulators - all assessing the program. This is Risk Management Process (assessment/monitoring of the cybersecurity program). The board committees are recipients of reports, not the primary actors here. Now I'm checking the specific facts - IAD is a named internal department with an abbreviation, and I need to verify whether the committee names like BAC and BOTC are specific enough to count as named entities or if they're too generic.

Looking at BOTC more closely, it appears to be a specific, non-generic committee name that isn't defined in this paragraph, suggesting it's firm-specific. BAC is more generic as an Audit Committee. There aren't enough hard verifiable facts like dates, dollar amounts, or named third-party firms to qualify for QV, so this lands as Firm-Specific based on the named committee reference.

fact: BOTC (Board/Operations Technology Committee — named non-generic committee)

fact: Morgan Stanley Internal Audit Department ('IAD') conducts assurance activities


reasoning: The paragraph defines management's scope of responsibilities and reporting lines (to the Cybersecurity Committee and Board), with the Executive Vice President, Administration as the directing role. While the listed items (identifying risks, coordinating IR, assessing maturity) are functional, the paragraph's primary communicative purpose is to delineate what management is responsible for and to whom it reports — organizational role definition rather than a detailed description of how processes work. The Cybersecurity Committee is a named non-generic committee on the IS list, yielding Firm-Specific; the EVP Administration title is not cybersecurity-specific per the IS list and Board of Directors is generic governance.

thinking:
Let me analyze this paragraph.

The paragraph describes management's responsibilities under the EVP, Administration. Let me apply the person-vs-function test.

The paragraph mentions "Executive Vice President, Administration" as attribution, then lists what management does: identifying risks, coordinating IR, assessing maturity, reporting to committees.

Person-vs-function test: If I remove "Under the direction of the Executive Vice President, Administration," the paragraph still describes management responsibilities (processes/functions). The content is about what management does (functions), not about who the person is (credentials, background, etc.).

The reporting lines to the Cybersecurity Committee and Board of Directors are part of the organizational structure, but the core content focuses on management's functional responsibilities rather than the person's qualifications. This is fundamentally about the role and what it entails—identifying risks, coordinating incident response, assessing maturity—which makes it function-focused despite the structural elements mentioned. Actually, I'm second-guessing myself. The paragraph does describe management's responsibilities and reporting structure, which points to Management Role. The key items listed—identifying and managing risks, coordinating incident response—are responsibilities tied to the role itself, not detailed process steps. And the reporting lines to the Cybersecurity Committee and Board are central to defining the role's scope.

For specificity, "Cybersecurity Committee" is the only firm-specific fact here since it's a named committee on the IS list, giving us one Firm-Specific (3) classification. The Executive Vice President title isn't cybersecurity-specific, and the Board is generic governance, so neither counts.

fact: Cybersecurity Committee


reasoning: This is a cross-reference directing readers to another section of the filing, with no substantive cybersecurity disclosure content. Cross-references are N/O with Specificity 1.


reasoning: This is a cross-reference directing readers to Item 1A Risk Factors for cybersecurity-related risks. It contains no substantive cybersecurity disclosure — it merely points elsewhere. N/O always receives Specificity 1.


reasoning: This is a cross-reference directing readers to Item 1A for cybersecurity risk discussion, with no substantive cybersecurity disclosure. N/O always receives Specificity 1.


reasoning: This paragraph is a disclaimer acknowledging limitations of the cybersecurity program and a cross-reference to Item 1A Risk Factors. It contains no substantive cybersecurity disclosure — no measures, processes, or assessments are described. The language 'could' style speculation plus cross-reference maps to N/O. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: This paragraph describes a general commitment to protecting IT assets and data, which loosely answers 'what does the cybersecurity program do?' but contains no specific processes, tools, or measures. It uses entirely generic business language with no domain terminology, firm-specific facts, or verifiable claims, placing it at Level 1.


reasoning: The paragraph centrally answers 'How are third-party cyber risks managed?' describing vendor vetting, monitoring, and compliance with security standards — making TP the clear category. Despite being about third-party risk management, the language is entirely generic ('vetting,' 'regular monitoring,' 'security standards') with no domain terminology, no firm-specific facts, and no verifiable claims.


fact: Vice-President of Information Technology (VPIT)

fact: Director - Information Security (DIS)

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — Audit Committee reports to the Board, and board members receive cybersecurity presentations, describing the oversight/information flow structure. The VP of IT and Director of Information Security are firm-specific cybersecurity leadership titles (VP-level+ and Director with security qualifier), elevating to Level 3.


fact: CISO

fact: Chief Risk Officer

reasoning: The paragraph identifies which management roles are responsible for cybersecurity risk — answering 'how is management organized?' Person-removal test: removing the three named roles leaves only generic language about assessing/managing risks, so MR. CISO is a cybersecurity-specific VP+ title (firm-specific); Chief Information and Technology Officer is a distinctive title variant also qualifying. No verifiable quantities or named external entities, so Level 3.


fact: security operations team

fact: automated event-detection notifications

fact: incident response team

reasoning: The paragraph describes how cybersecurity incidents are detected and analyzed — answering 'what does the cybersecurity program do?' with detection mechanisms and incident investigation processes. Domain terms like 'security operations team' and 'automated event-detection notifications' elevate beyond generic boilerplate, but no firm-specific facts (no named roles at VP+ level, no named tools) or verifiable claims are present.


reasoning: The paragraph states a conclusion about whether cybersecurity has materially affected business outcomes, using both backward-looking ('have materially impacted') and forward-looking ('reasonably likely to materially impact') assessment language, making it SI under the materiality assessment rule. The date 'October 31, 2024' is a reporting-period anchor for a negative self-assertion (claiming absence of incidents), which is not externally verifiable per the codebook's explicit guidance that negative assertions about absence cannot be independently confirmed. No domain terms or firm-specific facts are present, so specificity remains Level 1.

thinking: Materiality assessment paragraph.


reasoning: This paragraph describes how management stays informed about cybersecurity through briefings, threat intelligence, and security tools — but the person-removal test leaves a description of information sources and monitoring activities, pointing toward RMP. However, the language is entirely generic ('security tools,' 'internal security personnel,' 'threat intelligence,' 'external advisors') with no domain-specific terminology that passes the ERM test, no firm-specific facts, and no verifiable claims, keeping it at Level 1.


content_category: Incident Disclosure

fact: March 2021 - specific date of the cybersecurity incident

fact: $2.4 million in incremental one-time costs

fact: year ended December 31, 2021

fact: leading forensic information technology firms engaged

fact: brewery operations, production and shipments disrupted

fact: shift in production and shipments from first quarter of 2021 to balance of fiscal year 2021

reasoning: The paragraph describes an actual cybersecurity incident (systems outage in March 2021), its timeline, scope, response actions, and business impact — answering 'what happened?' This is a borderline ID/SI case since it includes significant financial impact ($2.4M costs, production shifts), but the incident narrative and timeline dominate the paragraph. Specificity is Level 4 due to the specific date (March 2021), dollar amount ($2.4 million), and specific reporting period (year ended December 31, 2021).

thinking: Incident disclosure about a real cybersecurity event in March 2021, with financial impact details.


reasoning: The paragraph describes general business context — that the company stores personal information and is targeted by security threats — but does not answer any of the six substantive cybersecurity disclosure questions. It contains no cybersecurity domain terminology, no firm-specific facts, and no verifiable claims; the language is generic business/risk framing that any data company could use.

thinking:
Classify this paragraph.

This describes the company as a target of cyber threats due to its business nature. It doesn't answer any of the six substantive questions - no board oversight, no management roles, no program details, no third-party risk management, no incident, no materiality assessment. It's general business context about being a target.

Category: None/Other - general business language about being targeted, no substantive cybersecurity disclosure.

Specificity: Level 1 - no domain terminology, no firm-specific facts, no QV facts. "Cyber and other security threats" is generic.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' by describing monitoring of service providers and commencement of a vendor risk management program — squarely TP. No domain terminology (all language is general ERM vocabulary like 'identify and manage material risks'), no firm-specific facts (the program has no distinguishing identifier), and no verifiable claims, so specificity remains Level 1.

thinking:
Let me classify this paragraph.

Content: About managing third-party service provider cybersecurity risks, including a vendor risk management program.

Category: This answers "How are third-party cyber risks managed?" → Third-Party Risk. The central topic is oversight of external parties' cybersecurity.

Specificity: Let me scan for facts.
- "vendor third-party risk management program" — generic program name, no distinguishing identifier
- "third-party service providers" — generic
- "monitoring" — generic
- No domain terminology that passes the ERM test
- No firm-specific facts
- No QV facts

This is generic language about managing third-party risks.

Since there are no domain-specific terms or company-specific details, this falls into Level 1.


fact: Third-Party Risk Management (TPRM) program — named internal program with distinguishing identifier

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing vendor due diligence, contractual review, and ongoing monitoring of third parties, making it clearly TP. The named 'Third-Party Risk Management (TPRM) program' with its distinguishing acronym elevates to Level 3; the remaining language (due diligence, contractual terms, ongoing monitoring) is general business vocabulary that fails the ERM test, and no QV-eligible facts are present.

thinking:
Let me classify this paragraph.

Content: About managing third-party cybersecurity risks through a TPRM program, including due diligence, contractual terms review, and ongoing monitoring.

Category: This clearly answers "How are third-party cyber risks managed?" → Third-Party Risk

Specificity:
- "Third-Party Risk Management (TPRM) program" - named internal program with distinguishing identifier → firm-specific (Level 3)
- "cybersecurity due diligence" - general business language
- "contractual terms" - general
- "ongoing monitoring" - general

- No domain terminology that would pass the ERM test, and no QV facts present, so this stays at Level 3.


fact: Senior Director of Governance & Information Security ('Senior Director, GIS')

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — delegation from Board to Audit Committee, quarterly updates, and reporting back to the full Board describe the oversight structure → BG. The 'Senior Director of Governance & Information Security' is a Director-level title with a security qualifier, making it firm-specific (Level 3). CFO and Audit Committee are generic roles/bodies that don't qualify, and 'quarterly'/'bi-annual' are generic cadences.

thinking:
Let me analyze this paragraph.

Category: This is about board oversight of cybersecurity - Board delegates to Audit Committee, Committee receives updates, Committee reports to Board. This is clearly Board Governance (BG).

Specificity: Let me scan for facts:
- "Audit Committee" - every company has one, NOT firm-specific
- "Chief Financial Officer" - generic role, NOT firm-specific
- "Senior Director of Governance & Information Security" - This is a Director-level title WITH a security qualifier. Per the codebook, "Director-level titles WITH a security qualifier (Director of IT Security, Director of Cybersecurity, Director of Information Security)" ARE firm-specific.

The Senior Director of Governance & Information Security title qualifies as a firm-specific fact, making this Level 3. The cadences mentioned are generic, and there are no QV-eligible facts like specific numbers, dates, named external entities, or certifications.


fact: ransomware

fact: malware

fact: phishing attacks

fact: social engineering

fact: operational technology

fact: phishing training and targeted training for specific roles

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing layered technical controls, third-party assessments, employee training, policies, and incident response procedures — all program activities → RMP. Multiple cybersecurity-specific threat types (ransomware, malware, phishing, social engineering) and the reference to operational technology pass the ERM test as domain terminology, elevating to Level 2. No firm-specific facts (no named roles, committees, or unique identifiers) and no verifiable claims keep it at Domain-Adapted.

thinking:
Let me classify this paragraph.

Content Category: "What does the cybersecurity program do?" → RMP. It describes the company's risk assessment program, technical controls, training, policies, and procedures.

Specificity: Let me scan for facts.

Domain terms: ransomware, malware, phishing attacks, data theft, phishing, social engineering, operational technology - these are domain terms that pass the ERM test.

Firm-specific: Nothing unique to this company specifically. "Third parties" unnamed. No named roles, committees, etc.

QV: No specific numbers, dates, named firms, certifications.

So Level 2 - Domain-Adapted.


reasoning: The paragraph describes general business context about data handling and the threat landscape — why ADP might be targeted — but contains no substantive cybersecurity disclosure: no program activities, governance structure, incident details, or materiality assessment. Terms like 'malicious tactics, code and viruses' and 'unauthorized parties' are general business language, not cybersecurity domain terminology passing the ERM test. No firm-specific or verifiable facts present.

thinking:
Let me classify this paragraph.

Content: Describes ADP's data handling activities and that they are targeted by cyberattacks due to the nature/volume of data they handle. This is general business context about cyber risk exposure - not describing a program, governance, management, incident, or materiality assessment.

Category: This is general business language about being a target. No substantive cybersecurity disclosure - no program, no governance, no incident, no materiality conclusion. It's describing the threat landscape and why they're at risk. This is closer to N/O or SI... Actually, it's describing business context about cyber risk but not making a materiality assessment.

Since there are no actual cybersecurity measures described here, this falls into N/O territory. The language is entirely generic with no domain-specific terminology or firm-specific details - just standard risk exposure framing at the most basic level.


fact: endpoint protection

fact: encryption

fact: two-factor authentication (2FA)

fact: real-time threat monitoring

reasoning: The paragraph answers 'What does the cybersecurity program do?' by describing monitoring, software updates, BYOD policy, cloud migration, and endpoint protection enhancements — all program activities. Domain terms like endpoint protection, encryption, 2FA, and real-time threat monitoring elevate beyond generic ERM language to Level 2, but no named entities, specific numbers, or firm-specific roles push it higher.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity program activities - policies, processes, programs including monitoring, software updating, BYOD policy, infrastructure simplification, cloud migration, endpoint protection, encryption, 2FA, threat monitoring.

Category: RMP - answers "What does the cybersecurity program do?"

Specificity: Let me scan for facts:
- "two-factor authentication (2FA)" - domain term
- "encryption" - domain term
- "endpoint protection" - domain term
- "real-time threat monitoring" - domain term
- "ERP system" - general IT term

- "migration of business-critical systems to Tier-1 cloud service providers" - describes organizational actions but doesn't name specific providers or include quantifiable details

The domain terms around encryption, 2FA, endpoint protection, and threat monitoring point to Level 2 specificity. While the cloud migration claim is firm-specific in describing what they've done, it lacks the named entities, numbers, dates, or certifications that would elevate it to Level 3. This lands at Level 2.


fact: Enterprise Cybersecurity Management Review Group (Enterprise Cybersecurity MRG)

fact: Chief Information Security Officer (CISO)

reasoning: The paragraph primarily describes a management-level steering committee (Enterprise Cybersecurity MRG) — its composition, responsibilities, meeting cadence with the CISO, and role in incident escalation. Per Rule 1, management-level committees described in terms of structure and membership → MR. The escalation path to Audit Committee/Board is subordinate to the MRG description. The named committee and CISO role are firm-specific facts elevating to Level 3, but no quantified or externally verifiable claims are present.

thinking:
Let me analyze this paragraph.

Category: This describes a management-level committee (Enterprise Cybersecurity MRG) - its structure, membership, meeting cadence, and responsibilities. The governance chain mentions escalation to Audit Committee and Board, but the primary content is about the MRG itself. This is a management-level committee description → MR.

Wait, let me reconsider. The paragraph describes oversight structure flowing from MRG → Audit Committee → Board. But the primary focus is on the MRG itself - its composition, what it does, how it meets with the CISO. Per Rule 1, management-level committees → MR if about structure/membership.

Now checking specificity: the Enterprise Cybersecurity MRG is a named, firm-specific committee, and the Chief Information Security Officer is a firm-specific role. There are no quantifiable facts, dates, or external certifications mentioned, so this lands at Level 3.


reasoning: This paragraph is a cross-reference pointing to Item 1A Risk Factors for discussion of cybersecurity risks. It contains no substantive cybersecurity disclosure itself — it merely directs the reader elsewhere. N/O always receives Specificity 1.


fact: cybersecurity awareness training

reasoning: The paragraph is a bulleted list answering 'what does the cybersecurity program do?' — covering risk assessments, security controls, incident response planning, training, and third-party oversight — squarely RMP. Most language is generic ERM ('risk assessments,' 'incident response plan,' 'ongoing monitoring'), but 'cybersecurity awareness training' is a domain-specific practice (security awareness training appears on the Domain Terminology list), elevating to Level 2.

thinking:
Let me analyze this paragraph.

Content: Describes what the cybersecurity program includes - risk assessments, a team, external service providers, training, incident response plan, third-party risk management.

Category: "What does the cybersecurity program do?" → RMP. It's a list of program components.

Specificity: Let me scan for facts.
- "Risk assessments" → general ERM language → L1
- "security controls" → general → L1
- "cybersecurity awareness training" → this is a domain term? The codebook says "Security awareness training" is domain terminology. Yes → L2

- "incident response plan" → not domain terminology → L1
- "third-party service providers" and "vetting process and ongoing monitoring" → both general language → L1

No firm-specific details here—no named roles, committees, numbers, or certifications. The only domain-specific terminology is the awareness training reference, so this lands at Level 2.


fact: penetration tests

reasoning: The paragraph primarily answers how the board oversees cybersecurity — the Audit Committee's oversight role, information flow via dashboards and briefings, and third-party reporting to the committee. The Director of Information Technology is mentioned in the context of reporting TO the committee (governance chain → BG). 'Director of Information Technology' is not firm-specific per the codebook (no security qualifier at Director level). Domain terms 'penetration tests' and 'threat detection rates and response times' elevate to Level 2, but no named firms, specific numbers, or verifiable credentials push it higher.

thinking:
Let me analyze this paragraph.

Content Category: The paragraph primarily answers "How does the board oversee cybersecurity?" - It describes the Audit Committee's oversight role, how information flows to them (dashboard, briefings, reports from third-party firm). The Director of Information Technology is mentioned but in the context of reporting TO the committee. This is BG.

Specificity:
- "Director of Information Technology" - This is a Director-level IT title WITHOUT a security qualifier. Per the codebook: "Director of IT", "Director of Information Technology" are NOT firm-specific.

- The dashboard, threat detection rates, response times, and penetration tests are all domain terminology that an ERM professional would recognize as standard security metrics and practices, not firm-specific details. The Audit Committee and unnamed third-party firm references are also generic governance structures without identifying information.

No firm-specific facts or named entities here—just standard cybersecurity oversight practices and terminology.


fact: Risk Management Committee (board-level committee with primary cybersecurity oversight)

fact: CISO

fact: Managing Committee

reasoning: The paragraph primarily answers how the board oversees cybersecurity, detailing the oversight structure through the Risk Management Committee, its Cybersecurity and Technology Subcommittee, joint meetings with the Audit Committee, and reporting flows from the CISO — all classic Board Governance. Specificity reaches Level 3 via firm-specific committees (Cybersecurity and Technology Subcommittee, Managing Committee) and the CISO role, but no QV-eligible facts (no specific numbers, dates, named external firms, or verifiable certifications) are present.

thinking:
Let me classify this paragraph.

Content Category: This paragraph primarily answers "How does the board oversee cybersecurity?" — it describes the Board's risk management oversight structure, committee responsibilities, reporting flows, and oversight mechanisms. This is Board Governance.

Specificity: Let me scan for facts.

- "Risk Management Committee" — named board-level committee (but this is a board committee, common at large banks... however it's more specific than "Audit Committee")
- "Cybersecurity and Technology Subcommittee" — named non-generic committee → firm-specific
- "quarterly reports" — generic cadence, not QV

- "CISO" — firm-specific named role
- "Managing Committee" — named committee → firm-specific

The Cybersecurity and Technology Subcommittee and Managing Committee are both firm-specific named committees, and the CISO is a firm-specific role, but there are no QV-eligible facts like specific numbers, dates, or external certifications. This puts it at Level 3.


reasoning: The paragraph's lead sentence states a backward-looking materiality conclusion ('to date none have materially affected the Company or our financial position, results of operations and/or cash flows'), making SI the primary category per the materiality assessment rule. The remaining text is generic risk language ('invest in cybersecurity and resiliency,' 'internal controls and processes,' 'protect our systems and infrastructure') and a cross-reference to Item 1A — none of which constitutes domain terminology, firm-specific facts, or verifiable claims, keeping specificity at Level 1.

thinking:
Let me analyze this paragraph.

Content: The paragraph starts with a materiality assessment ("none have materially affected"), then discusses ongoing risks, preventative actions, investment in cybersecurity, and ends with a cross-reference to Item 1A.

Category: The first sentence states a conclusion about materiality - "none have materially affected the Company or our financial position, results of operations and/or cash flows." This is a backward-looking materiality assessment → SI per Rule 5.

The rest is generic risk language and a cross-reference.

Specificity: Let me scan for facts:
- "have not materially affected" - negative self-assertion, not externally verifiable

- "cybersecurity and resiliency of our networks" - generic
- "internal controls and processes" - generic
- "Item 1A, Risk Factors" - cross-reference
- No domain terminology, no firm-specific facts, no QV facts

The remaining content is all boilerplate business language with no concrete details or company-specific information. This is Level 1 disclosure.


reasoning: The paragraph concludes with a backward-looking materiality assessment ('there have not been any that have had a material adverse effect on the company'), making it SI per the materiality rule. The threat landscape discussion and cross-reference to Item 1A are subordinate framing. Despite listing various threat actors (hackers, hacktivists, state-sponsored organizations), these are general risk language any business professional would use, not cybersecurity domain expertise; no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: Discusses cybersecurity threats IBM faces (referencing Item 1A), lists threat actors, then states "there have not been any that have had a material adverse effect on the company."

Category: The paragraph contains a materiality assessment - "there have not been any that have had a material adverse effect on the company." This is a backward-looking materiality conclusion → SI per Rule 5.

Specificity: Let me scan for facts.
- "criminal hackers, hacktivists, state-sponsored organizations, nation states" - threat types, but generic
- "AI" - general term

- "material adverse effect" - materiality conclusion but negative self-assertion
- No domain terminology that passes ERM test - the threat actors listed are general categories
- No firm-specific facts (no named roles, committees)
- No QV facts

The language here is essentially generic business risk boilerplate. Terms like "hacktivists," "state-sponsored organizations," and "vulnerabilities" are broad threat categories that could appear in any risk discussion, not cybersecurity-specific practices or tools. This reads as standard risk disclosure language without concrete details.


reasoning: This paragraph describes a grantor trust with no active operations, no customers, and no data — similar to a SPAC/no-operations entity. The sentence about cybersecurity threats being 'tailored to its specific circumstances' is vague and provides no substantive cybersecurity disclosure. The text appears truncated ('The Trust's from cybersecurity threats') and contains no actual program description, governance structure, or other substantive content. N/O at Level 1.


fact: phishing attempts

fact: ransomware

reasoning: The paragraph opens with a materiality assessment ('not aware of any material cybersecurity incidents that have impacted the Company'), which is a backward-looking negative assertion with materiality framing → SI. The remainder is speculation and a cross-reference, both subordinate. The date 'December 31, 2023' anchors a negative self-assertion (not externally verifiable), but specific threat types (phishing, ransomware, malware) are domain terminology elevating to Level 2.

thinking:
Let me analyze this paragraph.

Content: Starts with a negative assertion about material incidents ("not aware of any material cybersecurity incidents"), then discusses threats they face (cyber attacks, phishing, ransomware, etc.), acknowledges risk, and ends with a cross-reference to Item 1A.

Category: The opening sentence is a materiality assessment - "not aware of any material cybersecurity incidents that have impacted the Company." This is a backward-looking negative assertion with materiality framing → SI. The rest is speculation ("could adversely affect") and a cross-reference. The materiality conclusion is the substantive disclosure here.

Now I'm checking the specificity level. The date reference "As of December 31, 2023" provides temporal context for the negative assertion, though negative self-assessments aren't externally verifiable. The threat types mentioned—phishing, ransomware, malware, computer viruses—are domain-specific terminology that would qualify as Level 2 specificity. Cloud is more generic IT language. The cross-reference to Item 1A functions similarly to a note-or-other reference but remains secondary to the main materiality claim.


reasoning: This paragraph describes general business context about technology systems and data storage needs — it does not answer any of the six substantive cybersecurity questions. It contains no cybersecurity domain terminology, firm-specific facts, or verifiable claims, remaining at generic business language level.