reasoning: The paragraph describes multiple elements of the company's internal cybersecurity risk management program (monitoring, insider threats, information sharing, training, supplier engagement, scalability). While third-party and supplier oversight are mentioned, they are components within a broader program description, making Risk Management Process dominant. No named frameworks, no cybersecurity-specific titles, no named tools/firms, no specific dates or numbers — all practices described (data analytics, phishing training, tabletop exercises, security questionnaires) are common and generic.

thinking:
Let me analyze this paragraph from Allegiant Travel's 10-K Item 1C filing.

This is a long paragraph describing multiple elements of their cybersecurity risk management program: multi-layered defenses, insider threats, information sharing, third-party risk assessments, training, supplier engagement, and scalability.

**Content Category:** This describes the company's internal cybersecurity processes and methodology. While it mentions third parties and suppliers, these are components of the overall program description. The dominant topic is the company's own risk management approach. → **Risk Management Process**

**Specificity:** Let me check for specific facts:
- No named frameworks (NIST, ISO, etc.)

- No named tools or products
- No named third-party firms
- No specific dates or dollar amounts
- No cybersecurity-specific titles (CISO, CIO, etc.)
- "insider threat program" - generic program name
- "Allegiant" - company self-reference, doesn't count
- Practices mentioned: data analytics, phishing training, tabletop exercises, internal audit - all common practices
- "defense industrial base" - interesting but not a named standard
- "spear phishing" - common practice

Everything here is generic practices described in general terms. No named standards, no firm-specific facts from the IS list. → **Generic Boilerplate**

This is all generic language around insider threat programs and standard security practices—nothing that qualifies as a named framework or IS-list fact.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes four components of the company's internal cybersecurity program — technical safeguards, incident response planning, third-party risk management, and employee training. While TPRM is mentioned, it is one of four equally weighted components of the broader internal program, making Risk Management Process the dominant category. No named frameworks, cybersecurity-specific roles, named tools/firms, dates, or quantified facts appear; all practices described (firewalls, IDS/IPS, vulnerability scanning, tabletop exercises, training) are common practices on the NOT list, and 'Information Security and Privacy team' is a generic functional team name, not a firm-specific composition.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph from Live Nation Entertainment's 10-K filing, Item 1C.

This is a multi-bullet paragraph describing the company's cybersecurity program components: Technical Safeguards, Incident Response, Third-Party Risk Management, and Education/Awareness.

Content Category: This describes the company's internal cybersecurity processes - technical controls, IR planning, TPRM, and training. While TPRM is mentioned, it's one of four components of the overall program. The dominant topic is the company's own internal risk management processes. → Risk Management Process

Checking for specificity now. The paragraph mentions an "Information Security and Privacy team" by name, but that's fairly generic—most companies have a team with that title. There are no named frameworks like NIST or ISO, no specific tools or vendors, no dates or financial figures. TPRM is a standard abbreviation in the industry, not unique to Live Nation. The team name alone doesn't seem firm-specific enough to warrant a different categorization.

Looking at the actual practices listed—firewalls, IDS/IPS, anti-malware, access controls, vulnerability assessments, tabletop exercises, training—these are all standard security measures that appear on the NOT list. Without any named standards, specific roles like CISO, or other distinguishing details, this reads as generic boilerplate security language.


content_category: Management Role

reasoning: The paragraph describes two management-level committees (OROC and IT Steering Committee) responsible for cybersecurity oversight, their leadership (CRO, CIO), and their departmental composition. Per the codebook, 'management committees responsible for cybersecurity' falls under Management Role. The content is about organizational structure and committee composition rather than processes/tools (Risk Management Process) or board-level oversight (Board Governance). Multiple firm-specific facts (named committees with unique identifiers, specific departmental composition, CIO role) but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms/tools), so Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes two management committees (OROC and IT Steering Committee) that oversee cybersecurity. OROC is led by CRO, meets quarterly, composed of specific departments. IT Steering Committee led by CIO.

Category: This is about management committees and their composition/oversight role. The grammatical subjects are OROC and the IT Steering Committee - these are management-level committees, not board committees. This describes management's role in cybersecurity oversight through committee structures.

Wait - is this Management Role or Risk Management Process? The person-vs-function test: this paragraph describes committee structures, their composition, meeting cadence, and what they oversee.

The codebook explicitly lists "management committees responsible for cybersecurity" under Management Role, and that's exactly what I'm looking at here—two committees with defined leadership, membership, and oversight responsibilities. Even though the paragraph mentions specific roles like CRO and CIO, the focus is on the committee structures themselves and how they're organized for cybersecurity oversight, which fits the Management Role category.

Now I'm evaluating the specificity: the committee names (OROC and IT Steering Committee) are specific internal programs, the departmental composition is concrete rather than generic, and CIO is a cybersecurity-specific title from the IS list. The quarterly cadence is generic, but I have multiple IS facts here. There are no specific dates mentioned, so QV doesn't apply.

fact: Operational Risk Oversight Committee ("OROC")

fact: CRO leads OROC

fact: IT (including Security), Legal, Accounting, and Operational Risk Management departments

fact: Information Technology Steering Committee

fact: CIO leads IT Steering Committee


content_category: Strategy Integration

reasoning: The paragraph contains an explicit materiality assessment ('not aware of any cybersecurity incidents that have materially affected... business strategy, results of operations, or financial condition'), making it Strategy Integration per Rule 6. The appended cross-reference to Risk Factors does not change the classification. No specific facts from the IS list are present — all language is boilerplate materiality disclaimer.


reasoning: The paragraph describes the structure and function of a cybersecurity crisis management team and a cyber incident disclosure committee — organizational processes for incident escalation and materiality evaluation. While CIO and CISO are named as leaders, the paragraph is about what the teams do (communicate incidents, evaluate materiality, provide updates), not about the persons' qualifications or backgrounds. Removing the titles, the paragraph still describes the process. Two cybersecurity-specific roles (CIO, CISO) provide firm-specific facts, but neither counts toward QV, so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes a cybersecurity crisis management team structure, its leadership (CIO and CISO), its responsibilities (communication to Audit Committee), and a cyber incident disclosure committee for materiality evaluation.

**Content Category:**
This is about organizational structure for incident management. The primary content is about the crisis management team and disclosure committee - what they do, how they're structured. The CIO and CISO are mentioned as leaders but the paragraph is about the function/process, not the persons. Using the person-vs-function test: remove "led by our CIO and CISO" and the paragraph still describes the crisis management team structure and processes.

So this falls under Risk Management Process. The Audit Committee communication is secondary to the main focus on the crisis management team structure.

**Specificity:**
Looking at what qualifies as firm-specific facts here: CIO and CISO are cybersecurity-specific titles, so those count. The "cyber incident disclosure committee" has a specific name but it's fairly generic. The "cybersecurity crisis management team" is also a generic program name.

For QV eligibility, named roles don't count toward QV. There are no dates, dollar amounts, headcounts, named firms, named tools, or named certifications present.

This gives me 3 firm-specific facts based on the CIO and CISO titles.

fact: CIO

fact: CISO


category_confidence: medium

reasoning: The paragraph defines the charter and responsibilities of the Information Security Management Committee, a management-level body, including its reporting line to the board's Compliance and Information Security Committee. While the listed responsibilities are process-oriented, the paragraph's primary communicative purpose is to establish what this specific management committee is accountable for — organizational structure and role definition rather than describing the processes themselves. Two named non-generic committees and a named team provide firm-specific detail without reaching QV (no dates, dollar amounts, headcounts, or named third-party firms).

thinking:
Let me analyze this paragraph.

Content: Describes the responsibilities of the "Information Security Management Committee" - setting/reviewing security program, monitoring risks, ensuring resources, risk management, culture, assessments, incident response, reporting to "Compliance and Information Security Committee of the Board."

Category: This is about a management committee's responsibilities. The primary actor is the "Information Security Management Committee" which is a management-level committee. It describes what this committee DOES (functions/processes). But wait - is this about the person/committee or about the function?

The paragraph lists the committee's responsibilities - what it does.

So I'm seeing this is a management-level committee that reports up to a board-level committee, and the content focuses entirely on what the committee does rather than who sits on it. The responsibilities are all process-oriented—setting the security program, monitoring risks, managing incidents—which suggests this is really about the function itself. But the paragraph is structured around defining the committee's role and accountability within the organization, so there's tension between whether this is primarily about the process or the organizational structure. I think the key is that the committee is the subject and the paragraph is establishing its responsibilities and reporting relationships, making this fundamentally about organizational structure and governance. These are firm-specific facts with no quantitative indicators like dates, dollar amounts, headcounts, named third parties, tools, or certifications, so this falls under Firm-Specific (3).

fact: Compliance and Information Security Committee of the Board of Directors

fact: Information Security team


content_category: None/Other

reasoning: This is a pure cross-reference directing readers to Item 1A Risk Factors, with no materiality assessment or substantive cybersecurity disclosure content. The quoted heading name is not a cybersecurity-specific fact—it is a reference to another section.

thinking: Pure cross-reference with no materiality assessment.


reasoning: The paragraph primarily describes the company's own internal cybersecurity program — its design, review cadence, benchmarking, and threat identification process. The Audit Committee mention in the final sentence is a subordinate component of the program description, not the primary topic. Specificity is Sector-Adapted because ISO is a named recognized standard, but no firm-specific facts from the IS list are present: 'quarterly' is a generic cadence, 'Audit Committee' is standard governance, and 'corporate security team' is not a cybersecurity-specific title on the IS list.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity management program, review cadence, benchmarking to ISO, and Audit Committee oversight.

Category: The paragraph primarily describes the company's internal cybersecurity processes - program design, quarterly review, benchmarking to frameworks, team identification of risks. The last sentence mentions Audit Committee but it's one component. Dominant topic = Risk Management Process.

Specificity: Let me check facts:
- "quarterly basis" - generic cadence, NOT list
- "International Organization for Standardization" (ISO) - named framework → Sector-Adapted

- "Audit Committee" - NOT list (generic governance)
- "corporate security team" - not a cybersecurity-specific title from the IS list

No IS-list facts. ISO is a named standard → Sector-Adapted (Level 2).

fact: International Organization for Standardization (ISO)

type: framework


reasoning: The paragraph describes how the company manages cybersecurity risks through senior executives and an IT Managed Service Provider, focusing on processes (security policies, incident response plans, regular review meetings). The MSP is a component of the company's own risk management program, not vendor oversight as the central topic. No specific facts from the IS list are present: 'senior executives' is generic, the MSP is unnamed, and no frameworks, dates, cybersecurity-specific titles, or quantified details appear.

thinking:
Let me analyze this paragraph.

Content: Describes senior executives working to protect systems, mentions engaging an IT Managed Service Provider for data security oversight, and regular meetings with that provider.

Category: This is about risk management processes - describing how the company manages cybersecurity. The "senior executives" are generic (not cybersecurity-specific roles), and the focus is on processes and the MSP engagement. The MSP is central but unnamed. This is a mix of internal processes and third-party involvement. The MSP seems like a key component of their internal program rather than vendor oversight being the central topic - they're describing how they manage cyber risk using an MSP.

Now I'm checking the specificity of the claims here. The senior executives mentioned are generic without named titles, the IT Managed Service Provider isn't identified by name, and the cybersecurity incident response and recovery plans are described only in general terms. There are no specific frameworks referenced, no dates, no named roles like a CISO, and no concrete numbers - this is all generic boilerplate language without substantive details.


reasoning: The paragraph describes internal processes for cybersecurity crisis management, incident communication to the Board, and materiality evaluation via a disclosure committee. Applying the person-vs-function test, the CIO and CISO are mentioned as team leaders but the substantive content is about what the crisis management team and disclosure committee do — processes, not persons. The Board is mentioned only as a recipient of communications, not as the primary actor. CIO and CISO are cybersecurity-specific titles on the IS list, elevating specificity to Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph.

The paragraph describes a cybersecurity crisis management team led by CIO and CISO. It covers the team's responsibilities for incident communication to the Board and materiality evaluation through a cyber incident disclosure committee.

Content Category: This is about internal processes - crisis management team structure, incident communication, materiality evaluation. The CIO and CISO are mentioned as leaders but the paragraph is about what the team/process does, not about the persons. The Board is mentioned but as a recipient of communications, not as the primary actor. The primary topic is the crisis management process and disclosure committee process.

Actually, I'm reconsidering the categorization here. The paragraph really focuses on the internal processes for managing cybersecurity incidents and evaluating their materiality through established committees. Even if I remove the CIO and CISO titles, the core structure remains—it's fundamentally about how the organization handles incident management and disclosure. The CIO is a cybersecurity-specific title on the inclusion list, and the CISO definitely is, but the paragraph itself is describing the process framework rather than focusing on these individuals. I'm looking at the specificity of the language too—"cybersecurity crisis management team" and "cyber incident disclosure committee" are fairly generic program names that describe functions rather than unique roles. This points toward Risk Management Process as the category.

For the quality verification check, I'm not finding the hard facts needed—there are no dates, financial figures, headcounts, named external firms, or specific tools mentioned. The named roles themselves don't count as verifiable facts. So this doesn't meet the QV threshold.

Given that CIO and CISO are on the inclusion list, though, this would be Firm-Specific despite lacking QV.

fact: CIO leads the cybersecurity crisis management team

fact: CISO leads the cybersecurity crisis management team


reasoning: The paragraph describes internal and external risk assessments and an incident response plan — all internal cybersecurity processes. No named frameworks, specific roles, dates, or firm-specific details are present; 'risk assessments' and 'incident response plan' are generic program names and common practices.


reasoning: The paragraph describes the company's internal cybersecurity processes—vulnerability assessments, incident detection, disaster recovery, encryption, MFA, access controls, and employee training. All of these are common practices on the NOT list. No named frameworks, tools, roles, firms, dates, or quantified facts appear, making this Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes the company's internal cybersecurity processes - scans, vulnerability assessments, incident detection, disaster recovery, encryption, network security, MFA, training, etc.

Category: Risk Management Process - this is about the company's own internal processes and controls.

Specificity: Let me check for specific facts:
- No named frameworks (NIST, ISO, etc.)
- No named roles (CISO, CIO, etc.)
- No named tools or products
- No specific dates
- No named firms
- No specific numbers
- Practices mentioned: vulnerability assessments, incident detection, disaster recovery, encryption, MFA, security awareness training - all common practices on the NOT list

- The cadences mentioned like "annually" and "monthly" are also generic and don't add specificity

This is clearly Generic Boilerplate - no named standards, no firm-specific facts, just standard security practices described in vague terms.


reasoning: The paragraph primarily describes the company's enterprise-wide information security program and the types of cybersecurity risks it addresses. The CISO is mentioned as attribution for who manages the program, but the substantive content is about risk types and the program's purpose. Applying the person-vs-function test: removing the CISO reference leaves a coherent process description. One IS-list fact (CISO title) yields Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Lists cybersecurity risk types, mentions enterprise-wide information security program, and notes CISO manages it.

Category: The paragraph describes risk types and the company's internal program. The CISO is mentioned as attribution at the end. Applying the person-vs-function test: remove "Our CISO manages this program" and the paragraph still describes the program and risks. → Risk Management Process.

Specificity: CISO is a cybersecurity-specific title (IS list). No other specific facts. One IS fact → Firm-Specific.

Wait - let me check QV.

Only one fact (CISO). Not QV. Firm-Specific.

fact: Chief Information Security Officer (CISO)


reasoning: The paragraph's primary communicative purpose is assessing the business and financial effects of cybersecurity risk — it quantifies incident costs ($1.5M), describes operational impact (shipping disruption), notes ongoing investment, and concludes with an explicit materiality assessment. While the incident is referenced, it serves as context for the impact discussion rather than being the narrative focus. The heading 'Effects and Impacts of Cybersecurity Risks' confirms the strategic framing. Multiple hard verifiable facts (specific date + dollar amount) yield Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. A specific cybersecurity incident (October 28, 2023, operational impact, recovery by mid-December 2023)
2. Financial impact ($1.5 million expenses)
3. A materiality assessment
4. Cross-references to risk factors

The dominant content: This paragraph describes an actual incident AND its financial/business impact AND a materiality assessment. Let me apply the tiebreakers.

The paragraph describes what happened (incident impacting operations, shipping disruption, recovery timeline) AND discusses financial cost ($1.5M) AND makes a materiality conclusion.

Looking at the tiebreakers more carefully: the paragraph opens with incident narrative details—when it happened, what the operational impact was, how long recovery took—then transitions into the financial and materiality discussion. The heading "Effects and Impacts" suggests a strategy integration focus, but the bulk of the text actually walks through what occurred during the incident itself.

Applying Rule 4 about mixed content: the incident description spans roughly 2-3 sentences while cost and materiality each get about one sentence, with the rest being cross-references. That's a fairly balanced split, but the paragraph's framing around effects and impacts—the $1.5M cost and materiality assessment—seems to be the main point it's driving toward. I'm leaning toward Strategy Integration as the better classification since the communicative purpose centers on discussing the financial and strategic implications rather than documenting the incident details themselves. I'm identifying the specific verifiable facts in the paragraph—October 28, 2023 as the incident date, $1.5 million in expenses, and the first quarter of fiscal 2024 timeline—which confirms this falls into the Quantified-Verifiable category.

fact: October 28, 2023 announcement date

fact: $1.5 million of expenses related to the cybersecurity incident

type: quantified

fact: mid-December 2023 return to operations

fact: first quarter of fiscal 2024


reasoning: The paragraph describes the company's internal and external security testing processes — assessments, vulnerability disclosure, bug bounty programs, remediation timelines, and compliance tracking. These are all internal cybersecurity processes. No named frameworks, no cybersecurity-specific roles, no named tools or firms, no specific dates or numbers — 'bug bounty programs' and 'vulnerability disclosure' are common practices, not firm-specific facts.

thinking:
Let me analyze this paragraph.

Content: Describes internal and external testing processes - security assessments, vulnerability disclosure, bug bounty programs, remediation timelines, compliance tracking.

Category: This is about the company's own internal processes for managing cybersecurity risk. The mention of "reporting to management and the board" is incidental. → Risk Management Process

Specificity: Let me check for specific facts:
- "vulnerability disclosure and bug bounty programs" - these are named internal programs but generic names
- "public-facing technology assets" - generic
- No named frameworks, no specific dates, no named tools, no headcounts
- No cybersecurity-specific titles (just "management" and "board of directors" which are generic)

- No industry-specific standards referenced, just boilerplate language about their processes.


specificity_confidence: medium

reasoning: The paragraph makes an explicit materiality assessment ('have not materially affected... business strategy, results of operations, or financial condition'), which per Rule 6 is Strategy Integration even with the appended cross-reference to Risk Factors. The specific year '2024' is a firm-specific date anchoring the assessment to a particular fiscal period, yielding one IS-list fact but not two QV-eligible hard facts.

thinking: Materiality assessment paragraph with cross-reference.


reasoning: The paragraph describes the company's own internal processes (tools and processes for monitoring, prevention, detection, mitigation, remediation) with third-party service providers mentioned as one component rather than the central topic, making this Risk Management Process per Rule 3. No named frameworks, tools, roles, dates, or any specific facts are present — entirely generic language that could apply to any company.

thinking:
Classify this paragraph.

The paragraph describes internal tools and processes for monitoring cybersecurity incidents, mentioning third-party service providers as a component. This is about the company's own internal processes with third-party as one component → Risk Management Process.

No named frameworks, no specific facts, no named roles, no dates, no tools named. Generic language throughout.

Specificity: Generic Boilerplate.


reasoning: The paragraph describes what the Information Security Program does — safeguarding assets, monitoring threats, implementing controls. Although the CISO and two named committees are mentioned, they serve as attribution; the substantive content is about the program's function. Applying the person-vs-function test, removing the role/committee names leaves a coherent process description. CISO (cybersecurity-specific title) and TIRC/Management Risk Committee (non-generic named committees) each qualify as IS-list facts, making this Firm-Specific. However, none are QV-eligible (no dates, dollar amounts, headcounts, named firms, or named tools), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the Information Security Program, led by CISO, overseen by TIRC and Management Risk Committee. Describes program goals (safeguard confidentiality, integrity, availability) and how it's accomplished (monitoring, controls).

Category: The paragraph mentions CISO and committees but the bulk is about what the program does - safeguarding assets, monitoring threats, implementing controls. Apply person-vs-function test: remove "led by our CISO" and the paragraph still makes complete sense as a process description. → Risk Management Process.

Now I'm checking the specificity of the roles and committees mentioned. The CISO is a cybersecurity-specific title that belongs on the IS list, and both TIRC and the Management Risk Committee are named committees rather than generic ones. Looking at whether any of these qualify as QV-eligible facts—the CISO, TIRC, and Management Risk Committee are all named entities without any associated dates, dollar amounts, headcounts, or references to specific firms or tools, so none of them meet QV criteria. Since there's at least one IS-specific fact present, this falls into Firm-Specific category.

fact: CISO leads the Information Security Program

fact: TIRC (Technology/Information Risk Committee) oversees the program

fact: Management Risk Committee oversees the program


content_category: Board Governance

reasoning: The grammatical subjects throughout are the Audit Committee, the full Board, and Board members — all board-level entities receiving reports and briefings on cybersecurity. This is squarely Board Governance. The CISO title is the one IS-list fact, making it Firm-Specific; no second QV-eligible hard fact exists to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Board/Audit Committee reporting, full Board briefings, board education on cybersecurity from CISO and others.

Category: The grammatical subjects are "The Audit Committee," "The full Board," and "Board members" — all board-level entities. This is about board oversight activities. → Board Governance

Specific facts:
- CISO mentioned → cybersecurity-specific title → IS list
- "Audit Committee" → NOT list (generic)
- "Board" → NOT list
- "external experts" → NOT list (unnamed)

So one IS fact (CISO). No QV facts (no dates, dollars, headcounts, named firms, named tools, named certs).

This lands as firm-specific since I've identified one IS fact with the CISO title.


reasoning: The paragraph describes a board-level cybersecurity sub-committee (of the audit committee) and its oversight activities — reviewing risk assessments, monitoring, regulatory developments, and incident response. The sub-committee is the grammatical subject performing oversight, making this Board Governance. It contains firm-specific facts (named non-generic committee, CISO, CIO) but no QV-eligible hard facts (no dates, dollar amounts, named firms, or tools).

thinking:
Let me analyze this paragraph.

Content: Describes a cybersecurity sub-committee of the audit committee, its composition (CIO, CISO, audit committee/board reps), and what it reviews (risk assessments, monitoring, regulatory developments, incident response process, incident details).

Category: The grammatical subject is "the cybersecurity sub-committee" which is a board-level committee (sub-committee of audit committee). It describes board/committee oversight activities. → Board Governance

Specific facts:
- "cybersecurity sub-committee" - named non-generic committee → IS list
- CIO - cybersecurity-specific title → IS list

- CISO - cybersecurity-specific title → IS list

QV check: CIO and CISO are named roles (not QV-eligible). No dates, dollar amounts, headcounts, named firms, named tools, named certifications. So not QV.

Firm-Specific: Yes, multiple IS-list items (CISO, CIO, cybersecurity sub-committee).

Specificity: Firm-Specific (3)

fact: Chief Information Officer (CIO)


reasoning: The paragraph focuses on the IT Director's qualifications (25 years IT, 15 years cybersecurity) and the named IT Steering Committee (ITSC), making it about the person and management structure rather than processes. Two QV-eligible quantified facts (specific years of experience) push specificity to Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the IT Director's role, qualifications (25 years IT, 15 years cybersecurity), and the IT Steering Committee (ITSC).

Category: This is about the person - their experience and qualifications. The IT Director's credentials are the primary content. There's also the ITSC committee. The person-vs-function test: the paragraph tells us about who the person is (years of experience, background). This is Management Role.

Specificity: Let me check facts:
- "IT Director" - this is a leadership title but is it on the IS list? The IS list includes "Director of IT Security" but "IT Director" is more generic.

Looking at the NOT list, "Head of IT", "IT Manager", and "Director of IT" are all flagged as non-specific, so "IT Director" falls into that same category of generic IT leadership rather than cybersecurity-specific roles.
- "over 25 years of IT management experience" - specific number → quantified
- "over 15 years of experience in cybersecurity management" - specific number → quantified
- "IT Steering Committee, or ITSC" - named committee with unique identifier → named_committee (this is a non-generic committee)

The years of experience count as specific numbers. "25 years" and "15 years" are two quantified facts that are verifiable.

fact: IT Steering Committee, or ITSC


reasoning: The paragraph describes internal cybersecurity processes: ERM integration, a security points of contact program embedded in product teams, and a security council with defined composition and meeting cadence. The CISO is mentioned as chairing the council, but the paragraph is about what the program does, not who the person is — applying the person-vs-function test, removing the CISO reference leaves the process description intact. Specificity is Firm-Specific due to the CISO role, the named security council (non-generic committee), and the specific departmental composition of the council; however, no two QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes internal cybersecurity processes - risk management integration, security points of contact program, security council chaired by CISO that meets monthly, council composition.

Category: This is about internal processes and program structure. The CISO is mentioned as chairing the council, but the paragraph is about what the program does (security points of contact, security council meetings, council composition). Person-vs-function test: remove "chaired by our CISO" and the paragraph still describes the program. → Risk Management Process

Specific facts:
- CISO (cybersecurity-specific title) → IS list ✓

- "Security council" as a named committee qualifies → IS list ✓
- Council composition with specific departments (product development, operations, security, quality, services) → IS list ✓
- Monthly meeting cadence → generic, not on list
- "Security points of contact program" as a named internal program → IS list ✓

Now checking for hard verifiable facts: there's no dates, dollar amounts, headcounts, or named external firms/tools. The CISO is a role title, not a quantifiable fact. This doesn't meet the QV threshold, so it's Firm-Specific (3).

fact: CISO chairs the security council

fact: Security council (named non-generic committee)

fact: Council comprised of senior leaders in product development, operations, security, quality, and services


reasoning: The paragraph's grammatical subjects throughout are the CISO and CTO, defining their responsibilities and reporting lines (CISO reports to Risk Committee, CTO partners with CISO). While the paragraph catalogues many activities these roles perform, it lacks any personal qualifications, credentials, or background — making it a borderline case between Management Role and Risk Management Process. The organizing principle is role definition ('The CISO is responsible for...', 'The CTO provides...'), not process methodology, so Management Role is dominant. Specificity is Firm-Specific: CISO and CTO are cybersecurity-specific titles on the IS list, and Risk Committee is a named non-generic committee. No QV-eligible hard facts (dates, dollar amounts, headcounts, named firms/tools/certifications) are present.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph names CISO and CTO roles and describes what they do. Let me apply the person-vs-function test. The paragraph describes responsibilities and activities: implementing cybersecurity organization, maintaining incident response plan, testing it annually, sharing threat info, training, logging incidents. If I remove the role titles, the paragraph describes processes and activities. However, the paragraph is fundamentally about defining the roles - what the CISO does, what the CTO does, their reporting lines. The CISO reports to the Risk Committee - that's a reporting line.

Actually, this is a borderline case. The paragraph starts by identifying CISO and CTO as "key management roles responsible for assessing and managing material risks." Then it describes what each role is responsible for.

The core issue here is that it's structured around role definition and reporting relationships rather than describing individual qualifications or credentials. The paragraph outlines who holds responsibility for what—the CISO reports to the Risk Committee, and both roles oversee specific functions like incident response and staff training. There are no personal backgrounds or named individuals, just the management positions themselves and their assigned duties. CTO
- It defines reporting lines (CISO reports to Risk Committee)
- It's about role responsibilities

But per the person-vs-function test, credentials/background/qualifications are absent. The paragraph describes what the function does. However, the codebook says "Assign when a management role is the grammatical subject" - and CISO/CTO are the grammatical subjects throughout.

I think this is Management Role - it's defining the management structure for cybersecurity, reporting lines, and role responsibilities. It's not about internal processes per se but about who is responsible for what.

Specificity:
- CISO: cybersecurity-specific title → IS list ✓
- CTO: cybersecurity-specific title → IS list ✓
- Risk Committee: named non-generic committee → IS list ✓
- "Incident Response Plan" - generic program name → NOT list

QV-eligible

There aren't any concrete facts here—no dates, financial figures, headcount, or named external parties—so this falls under Firm-Specific.

fact: CISO identified as key management role

fact: CTO identified as key management role

fact: CISO reports to the Risk Committee


reasoning: The paragraph describes the company's internal cybersecurity processes: assessments, audits, cross-functional exercises, penetration testing, training programs, and incident response plan maturity. Third parties are mentioned as service providers to the company (not vendor oversight), so this is Risk Management Process. No named frameworks, no cybersecurity-specific titles, no named firms or tools, no specific dates or numbers. 'Cyber Incident Response Plan' lacks a unique distinguishing identifier, third-party firms are unnamed, and practices like penetration testing and training are generic per the NOT list.

thinking:
Let me analyze this paragraph from Cheniere Energy Partners' 10-K filing.

Content: Describes internal cybersecurity processes - assessments, audits, exercises, penetration testing, training programs. Third parties are mentioned but as service providers to the company, not as the central topic of vendor oversight.

Category: Risk Management Process - this is about the company's own internal processes, tools, and methodologies.

Specificity analysis:
- "Cyber Incident Response Plan" - this is a named internal program but is it unique? It doesn't have a unique abbreviation beyond the generic. Actually, looking at the IS list: "Named internal programs with unique identifiers: 'Cyber Incident Response Plan (CIRP)'" - hmm, the example shows CIRP as unique.

Here it's just "Cyber Incident Response Plan" without a distinguishing abbreviation. That's generic per the NOT list. "Cheniere" is a company self-reference, unnamed third parties performing tests fall under the NOT list, annual training is generic cadence, and penetration tests, assessments, and audits are all common practices. Board governance references are also generic. There are no named frameworks like NIST or ISO, no firm-specific facts, no specific dates, named roles, tools, firms, or numbers. The Cyber Incident Response Plan doesn't qualify as specific enough without a unique identifier.


reasoning: The paragraph's primary purpose is establishing the management oversight structure for cybersecurity — identifying who is responsible (CFO, VP of Internal Audit), describing reporting lines (IT → CFO/VP → Board), and how information flows. Per Rule 2b, reporting lines as primary content points to Management Role. However, CFO is generic C-suite (✗ NOT list) and VP of Internal Audit is not a cybersecurity-specific title per the IS list, so no firm-specific facts survive the validation filter, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes oversight responsibility shared by Board, CFO, VP of Internal Audit, and IT resources. It then describes what the CFO and VP of Internal Audit do (oversee cybersecurity risk management, receive quarterly updates), how CFO communicates with the Board, and mentions a cyber incident response plan.

Content Category: This is a mixed paragraph. Let me apply the decision rules.

The paragraph has multiple actors:
- Board is mentioned but not as the primary grammatical subject doing most of the work
- CFO and VP of Internal Audit are the primary actors - they oversee cybersecurity risk management, receive updates, communicate with the Board

- There's also a mention of an incident response plan

The primary communicative purpose: describing who manages cybersecurity and how. The CFO and VP of Internal Audit are the grammatical subjects for most sentences. This is about management's role in cybersecurity oversight.

But wait - is this about the PERSON or the FUNCTION? The person-vs-function test: the paragraph describes what the CFO and VP of Internal Audit DO (oversee risk management, receive updates, communicate with Board, incident response plan protocol). It doesn't describe their qualifications, credentials, background, or experience.

However, Management Role covers "reporting lines, management committees responsible for cybersecurity" - and this paragraph is about WHO is responsible and what they do in that capacity, which fits the Management Role category.

Actually, I'm applying the person-vs-function test more carefully: if I remove the specific titles and replace them with generic language, the paragraph becomes about processes and oversight structures rather than about the individuals themselves. The core content is about how risk management oversight works, how updates flow to the Board, and what the incident response protocol is - these are all processes. So this leans more toward Risk Management Process than Management Role. The paragraph is really about the oversight structure and reporting lines—who's accountable, how information flows up to the Board, the incident response protocol. Rule 2b is clear that reporting lines and management committee structure point to Management Role, and that's what dominates here. The role titles aren't just attributions; they're the core of what's being described. I'm checking each element against my specificity criteria. The CFO and VP of Internal Audit are generic C-suite roles, not cybersecurity-specific positions like CISO or CTO. The quarterly updates, incident response plan, and Board references are all standard boilerplate without named frameworks, dates, or firms. After filtering out everything that doesn't meet the specificity threshold, there's nothing concrete left—this classifies as Generic Boilerplate.


reasoning: The paragraph contains an explicit materiality assessment ('have materially affected or are reasonably likely to materially affect the Company, including its business strategy, results of operations or financial condition'), which per Rule 6 is Strategy Integration even though it is boilerplate. The opening clause is a generic forward-looking disclaimer. No named frameworks, roles, dates, or firm-specific facts appear.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. A forward-looking disclaimer about potential cybersecurity incidents
2. A materiality assessment stating no material impact from cybersecurity threats

The materiality assessment ("have materially affected or are reasonably likely to materially affect the Company, including its business strategy, results of operations or financial condition") is the substantive content here. Per Rule 6, this is Strategy Integration.

Specificity: No named frameworks, no specific facts from the IS list. This is boilerplate materiality language. → Generic Boilerplate.


reasoning: The paragraph is an explicit materiality assessment concluding that cybersecurity risks have not materially affected the company's business strategy, results of operations, or financial condition. Per Rule 6, materiality disclaimers are Strategy Integration even when boilerplate. No named frameworks, firm-specific facts, or verifiable details are present.

thinking: Materiality disclaimer → Strategy Integration, Specificity 1


reasoning: The Board of Directors is the grammatical subject in both sentences, describing its oversight of cybersecurity policies and receipt of updates from senior management. No specific facts are present — 'Board of Directors' and 'senior management' are generic, and no named roles, committees, frameworks, dates, or quantified details appear.

thinking:
Classify this paragraph.

The paragraph is about the Board of Directors overseeing cybersecurity. The Board is the grammatical subject in both sentences. This is Board Governance.

Specificity: No named frameworks, no specific roles (just "senior management" which is generic), no dates, no specific committees. "Board of Directors" is generic. This is Generic Boilerplate.


reasoning: The paragraph is framed around the Audit Committee's primary responsibility for overseeing cybersecurity risk, making the board committee the grammatical subject and primary actor. The CISO is mentioned in a subordinate role reporting TO the committee, which per Rule 2 keeps this as Board Governance. The CISO title is a cybersecurity-specific role (IS list), elevating specificity to Firm-Specific, but there is only one QV-eligible fact so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Board/Audit Committee oversight, CISO reporting to Audit Committee.

Category: The paragraph opens with "Board of Director Oversight" and the Audit Committee is the primary subject performing oversight. The CISO is mentioned in terms of reporting TO the Audit Committee. Per Rule 2, "Board delegates responsibility to management → Board Governance" and "Management role reports TO the board → Management Role." But the overall frame is about the Audit Committee's oversight role. The CISO reporting line is subordinate to the board oversight framing. → Board Governance.

Now looking at specificity: "Audit Committee" is a generic governance term, but "CISO" is a firm-specific cybersecurity role that qualifies as a named position. Since there's only one QV-eligible fact here, this falls into Firm-Specific.

fact: CISO role exists and reports directly to the Audit Committee


reasoning: The board of directors and Audit Committee are the primary grammatical subjects and actors throughout the paragraph — the board has 'ultimate oversight,' the Audit Committee receives updates, ensures annual board briefings, and assesses incident materiality. Management's role is described in a subordinate capacity (providing updates to the Committee). The VP of Information Technology is a cybersecurity-adjacent title on the IS list, and the specific departmental composition (legal, finance, corporate governance) is a firm-specific detail, yielding two IS-list facts but neither is QV-eligible (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Let me analyze this paragraph from Pacira BioSciences' 10-K filing.

The paragraph covers board/committee oversight (Audit Committee, board), management roles, and processes. The primary frame is about oversight structure - the board has ultimate oversight, Audit Committee assists, and the paragraph describes the oversight flow.

The grammatical subject shifts: "Our board of directors" → "Audit Committee" → "Members of management" → back to "Audit Committee". The dominant theme is the oversight structure centered on the board and Audit Committee.

But there's a mix. Let me apply the dominant category rule. The paragraph starts with board oversight, then mentions management working with functions, then Audit Committee receiving updates, then Audit Committee ensuring board gets updates, then incident materiality assessment by Audit Committee. The board/Audit Committee is the primary actor throughout most of the paragraph.

So this falls under Board Governance - the board and Audit Committee drive the narrative as the primary actors. Now I'm checking the specific facts: the Audit Committee and quarterly/annual cadences are generic governance terms, not list items. The Chief Accounting Officer is a standard C-suite role. The Vice President of Information Technology maps to the VP of IT/Security on the information security list, so that's a match for specificity.

The information security certifications mentioned are generic without named credentials. The team composition of legal, finance, and corporate governance functions is firm-specific - similar to the "Legal, Compliance, and Finance" composition on the IS list - but neither this nor the VP title qualifies as QV-eligible since QV requires concrete data like dates, dollar amounts, headcounts, named firms, tools, specific certifications, years of experience as numbers, or named universities.

fact: legal, finance and corporate governance functions work together on cybersecurity


reasoning: This paragraph is a cross-reference directing readers to three specific Risk Factor subsections. While it uses the phrase 'reasonably likely to affect,' this is framing language for the cross-reference rather than a standalone materiality assessment — it does not conclude whether cybersecurity risks have or have not materially affected the company's business strategy, results of operations, or financial condition. Per the codebook, a pure cross-reference with no materiality conclusion is None/Other.

thinking:
This is a cross-reference paragraph pointing to Risk Factors. Let me check if there's any materiality assessment here.

The paragraph says "risks from cybersecurity threats that are reasonably likely to affect the Company" — but this is framing the cross-reference, not making a standalone materiality conclusion. It's saying "for discussion of risks, see these other sections." This is a pure cross-reference.


reasoning: The paragraph contains an explicit materiality assessment ('To date, these threats and attacks have not resulted in a material cybersecurity incident') and discusses potential adverse business/financial consequences (financial losses, remediation expenses, reputational damage, regulatory fines). Per Rule 6, materiality disclaimers are Strategy Integration even when boilerplate. The appended cross-reference to Risk Factors does not change the classification. No firm-specific facts are present — all threat descriptions, impact language, and terminology are generic boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes various cyber threats the company faces, states no material incident has occurred, discusses potential adverse effects, and cross-references Risk Factors.

The key sentence: "To date, these threats and attacks have not resulted in a material cybersecurity incident." - This is a materiality assessment.

Then "a material failure... could adversely affect" - hypothetical impact language.

Per Rule 6: materiality disclaimers → Strategy Integration. The paragraph makes an explicit materiality assessment ("have not resulted in a material cybersecurity incident") plus discusses potential business/financial impact.

The cross-reference at the end doesn't change the classification per the codebook.

Now looking at the specificity—there are no named frameworks or company-specific details from the information security list, just generic threat descriptions and standard impact language. This points to Generic Boilerplate.


content_category: Third-Party Risk

reasoning: The paragraph's central topic is oversight of third-party service providers — assessing vendor risks, reviewing contracts, and conducting due diligence on vendors' security obligations. The specific departmental composition (Risk Management, Legal, Information Security) reviewing vendor contracts is a firm-specific organizational detail per the IS list.

thinking:
Let me analyze this paragraph.

Content: This is about third-party service provider oversight - vendor risk management program, assessing third-party risks, reviewing contracts, due diligence on vendors.

Category: Third-Party Risk - vendor oversight is clearly the central topic.

Specificity: Let me check for specific facts.
- "Risk Management, Legal and/or Information Security Departments" - this is a specific team/department composition → Firm-Specific
- No named frameworks, no dates, no dollar amounts, no named firms/tools
- "service organization controls reports" - this is essentially SOC reports, a named standard → Sector-Adapted

- The department composition is the only firm-specific fact here, and there are no quantifiable or verifiable details like dates, amounts, or named entities, so this falls under Firm-Specific.

fact: Risk Management, Legal and/or Information Security Departments review higher risk and material contracts


reasoning: The CISO is the grammatical subject performing the primary action (presenting reports to the Risk Committee), making this Management Role per the Board-vs-Management tiebreaker. The paragraph describes the CISO's reporting relationship and briefing content rather than the committee's oversight activities. CISO (cybersecurity-specific title) and Risk Committee (non-generic committee) are both IS-list facts triggering Firm-Specific, but neither qualifies as QV-eligible.

thinking:
Classify this paragraph.

The paragraph describes the CISO presenting reports to the Risk Committee on a quarterly basis. The grammatical subject performing the action is the CISO, but the content is about reporting to a committee (Risk Committee). Let me think about this...

The CISO is the grammatical subject presenting to the Risk Committee. This is about the reporting/briefing relationship. The Risk Committee is receiving the reports.

Per Rule 2: "CISO reports quarterly to the Board on..." → Management Role (CISO is primary actor). But also, this could be Board Governance since it's about committee oversight receiving briefings.

The CISO is clearly the primary actor here reporting to the Risk Committee, which matches the Management Role pattern. Looking at the specificity, I have a cybersecurity-specific title with the CISO and a named non-generic committee in the Risk Committee, so both are IS facts.

For QV eligibility, neither the CISO nor the Risk Committee qualifies—there are no dates, dollar amounts, headcounts, named firms, tools, or certifications present. This makes it Firm-Specific, since it contains IS facts but no QV-eligible ones.

fact: CISO

fact: Risk Committee


reasoning: The paragraph is primarily about the CISO as a person — their years of experience, degree, and the qualifications of their supporting team. While it opens with an ISO certification claim and mentions risk management briefly, the dominant content is who the CISO is and what makes them qualified. QV-eligible: 28 years of experience (specific number) + named certifications (CISA, CISM, etc.) = two or more hard verifiable facts.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. ISO 27001:2022 certification
2. CISO designation and responsibility
3. CISO's qualifications (28 years experience, master's in IT)
4. Team composition (ISOs + third-party consultant with certifications)

Person-vs-function test: The paragraph is primarily about WHO the CISO is (experience, degree, knowledge) and who supports them (ISOs, consultant with certifications). It's about the person and team, not about processes/tools/methodologies.

Category: **Management Role**

Now I'm identifying which facts are specific and verifiable for qualification purposes. The 28 years of experience, CISA and CISM certifications, and ISO 27001:2022 certification are all concrete, named credentials that could support the CISO's qualifications.

fact: ISO/IEC 27001:2022 certified

fact: Chief Information Security Officer (CISO)

fact: 28 years of experience in Information Security

fact: Master's degree in Information Technology

fact: CISA, CISM, HITRUST Certified Common Security Framework Practitioner, QSA, CSP certifications (held by third-party consultant)


reasoning: The entire paragraph describes the qualifications, career backgrounds, tenure, and credentials of five named leadership roles (CISO, CDIO, CEO, CFO, GC) — squarely about the persons, not about what processes or programs they run. Multiple specific years-of-experience figures (25, 20, 30, 15, 18) provide well more than two QV-eligible hard verifiable facts.

thinking:
Let me analyze this paragraph from Philip Morris International's 10-K filing.

This paragraph describes the qualifications and backgrounds of multiple executives: CISO, CDIO, CEO, CFO, and GC. It's about the people - their experience, credentials, career history.

Content Category: Management Role - the paragraph is entirely about the persons' qualifications, experience, and backgrounds.

Specificity: Let me count hard verifiable facts:
- "over 25 years" (CISO experience) - quantified

- "over 20 years" (CDIO experience) - quantified
- "over 30 years" (CEO experience) - quantified
- "over 15 years" (CFO experience) - quantified
- "18 years" (GC tenure) - quantified
- CISO title - named_role
- CDIO title - named_role
- "engineering degree" - generic degree
- "master's degree in economics" - generic
- "two master's degrees" - generic
- "Senior Vice President, IT Sales, and Global Chief Information Officer" - prior role
- "Chief Financial Officer and Chief Operating Officer" - prior roles

QV-eligible: specific numbers of years of experience and prior roles are documented.

fact: CISO title

fact: CDIO (Chief Digital Information Officer) title

fact: CISO has over 25 years of experience in IT and information security

fact: CDIO has over 20 years in senior IT positions

fact: CEO has over 30 years at PMI

fact: CFO has over 15 years of experience

fact: GC has served at PMI for 18 years


reasoning: The paragraph describes the composition of a management-level committee (Technology and Operations Committee), identifying which roles and departments comprise it. This is about organizational structure — who sits on the committee — fitting Management Role's coverage of management committees responsible for cybersecurity. No processes, tools, or activities are described; the person-vs-function test points to structure/personnel. Multiple IS-list facts (named non-generic committee, CISO, CIO, specific departmental composition) support Firm-Specific, but none are QV-eligible (no dates, dollar amounts, named firms, or tools).

thinking:
Let me analyze this paragraph.

Content: Describes a Technology and Operations Committee composed of various leadership members including CIO, CISO, and representatives from multiple departments.

Category: This is about a management committee's composition. It's not about the board - it's about an internal management committee. The paragraph describes who is on the committee (organizational structure), not what the committee does in terms of processes. This is about management structure/reporting - Management Role.

Wait, let me reconsider. The "Technology and Operations Committee" is a management-level committee. The paragraph describes its composition. This is about organizational structure - who comprises the committee.

This fits the Management Role category since it covers management committees responsible for cybersecurity. The committee includes named cybersecurity-specific roles like CIO and CISO, plus specific team representation from operational risk, information security, information technology, and operations - all concrete details that make this an IS list item. There are no quantifiable values like dates or dollar amounts to flag for QV eligibility.

fact: Technology and Operations Committee

fact: CIO

fact: Committee composition includes operational risk, information security, information technology, operations, and other departments


reasoning: The board committee (RCOC) is the grammatical subject performing oversight of cybersecurity risk, making this Board Governance. The named non-generic committee 'Risk and Compliance Oversight Committee' is a firm-specific fact, but there is only one QV-eligible fact, so specificity is Firm-Specific.

thinking:
Classify this paragraph.

The paragraph is about the RCOC (Risk and Compliance Oversight Committee) of the Board overseeing cybersecurity. The board committee is the grammatical subject → Board Governance.

Specific facts:
- "Risk and Compliance Oversight Committee" (RCOC) — this is a named non-generic committee (not just "Audit Committee")

No QV facts (no dates, dollar amounts, headcounts, named firms, named tools, named certifications).

One IS fact → Firm-Specific.

fact: Risk and Compliance Oversight Committee (RCOC)


reasoning: The paragraph opens with an explicit materiality assessment ('have not materially affected us or are reasonably likely to materially affect us') and follows with a forward-looking materiality statement, making it Strategy Integration per Rule 6. The appended cross-references to Risk Factors do not change the classification. No firm-specific facts are present — the materiality language is boilerplate and the risk factor titles are generic cross-references.

thinking:
Let me analyze this paragraph from Kaltura Inc's 10-K filing.

The paragraph contains:
1. A materiality assessment: "have not identified risks...that have materially affected us or are reasonably likely to materially affect us"
2. A forward-looking risk statement about potential material impact
3. Cross-references to Risk Factors

Per Rule 6 and the codebook, any paragraph with an explicit materiality assessment → Strategy Integration. The cross-references don't change this.

Specificity: The language is boilerplate materiality language. No named frameworks, no firm-specific facts.

The risk factor titles themselves are just cross-references without substantive detail, so they fall into Generic Boilerplate.


reasoning: The paragraph opens by establishing the VP IT Security's qualifications — 26 years of experience, degree, and CISSP/CRISC/CISM certifications — making the person's credentials the primary framing. While the second half describes processes (risk assessments, framework reviews), the person remains the grammatical subject throughout, and the paragraph's communicative purpose is to establish who this individual is and what they oversee. Multiple QV-eligible hard facts: 26 years of experience + named certifications (CISSP, CRISC, CISM).

thinking:
Let me analyze this paragraph carefully.

The paragraph has two parts:
1. First part: About the VP IT Security person - experience (26 years), degree, certifications (CISSP, CRISC, CISM)
2. Second part: About what the Adviser does - risk assessments, vendor audits, framework reviews

Person-vs-function test: The paragraph starts with the person's credentials and background, then shifts to describing processes. The first ~half is about the person, the second ~half is about functions.

Dominant category: The paragraph opens with and emphasizes the person's qualifications. But then it shifts to process description. Let me assess which dominates.

Looking at the breakdown, there are four sentences about the person's background and four about their functions, so it's split evenly between personal credentials and operational responsibilities.

The role title "Vice President, IT Security" serves as the grammatical subject throughout, which frames this as fundamentally about the person and their position. Even when describing processes, the person remains the active agent. The opening half establishes qualifications, while the second half details what they do in that role. This is clearly a Management Role category—the paragraph's core purpose is defining who this person is and what they're accountable for, with the process details supporting that establishment rather than driving it.

For specificity, the Vice President title is cybersecurity-specific, the 26 years is a concrete number, and the three named certifications are all QV-eligible. The Bachelor's degree in Electronics and Communication Engineering adds technical foundation to the profile.

Since I have at least two hard verifiable facts—the quantified experience and the named certifications—this qualifies as Quantified-Verifiable.

fact: Vice President, IT Security

fact: more than 26 years of experience

fact: CISSP certification

fact: CRISC certification

fact: CISM certification


reasoning: The paragraph primarily describes the company's internal cybersecurity policies, procedures, and ERM integration — all process-oriented content. The Board/Audit Committee mention is a brief closing attribution of oversight, not the paragraph's primary focus. No named frameworks, cybersecurity-specific roles, dates, or firm-specific facts are present; all language is generic boilerplate that could apply to any company.

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity measures, policies, procedures, ERM integration, with brief mention of Board/Audit Committee oversight.

Category: The paragraph primarily describes the company's internal processes - policies and procedures for risk management, ERM integration. The Board/Audit Committee mention is at the end as oversight attribution. The dominant content is about risk management processes. → Risk Management Process

Specificity: Let me check facts:
- "Board of Directors" - NOT list
- "Audit Committee" - NOT list
- "management" - NOT list
- No named frameworks, no specific roles, no dates, no numbers

- Everything here is generic boilerplate language with no concrete details or specifics.


reasoning: The grammatical subject is the Director of Compliance reporting TO the board, which per Rule 2 signals Management Role. However, the paragraph describes report topics rather than the person's qualifications or background, making this a borderline case with Board Governance. 'Director of Compliance' is not a cybersecurity-specific title per the IS list (comparable to 'Chief Compliance Officer' on the NOT list), 'regular reports' is a generic cadence, and 'Board of Directors' is standard — no specific facts remain after filtering.

thinking:
Let me analyze this paragraph.

Content: The Director of Compliance provides reports to the Board on cybersecurity risks. The reports cover controls/procedures, third-party oversight, and management's evaluation of material risks.

Category: The grammatical subject is "The Director of Compliance" - a management role providing reports to the board. But "Director of Compliance" - is this a cybersecurity-specific title? No, it's a generic compliance role. The paragraph describes what the reports may include - this is about the reporting relationship between management and the board.

The primary actor is the Director of Compliance reporting TO the board. Per Rule 2, "Management role reports TO the board" → Management Role.

But I'm torn between whether this is really about the person in that role or the reporting function itself. The paragraph focuses on what gets reported—controls, procedures, third-party oversight, materiality assessments—rather than anything about the Director as an individual. That functional emphasis pulls toward Reporting Process, though the Director is clearly the grammatical subject performing the action.

Looking at the tie-breaker: if management is mentioned briefly with board oversight as the main focus, that's Board Governance. Here, the Director of Compliance is the vehicle delivering information to the board about cybersecurity risks. The core of the paragraph is really about how the board gets informed for its oversight responsibilities, not about the Director's management duties. I'm settling on Board Governance—this describes the board's information channel for oversight. The explicit rule about management roles reporting to the board pushes this toward Management Role classification, even though the paragraph's focus is really on information flow and governance. Looking at the specificity markers: "Director of Compliance" isn't a cybersecurity-specific title like CISO or Director of IT Security, and there are no named frameworks, dates, or firms—just generic language about regular reports to the Board of Directors. This reads as Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, its integration into the enterprise risk management framework, and its alignment with NIST CSF. This is squarely about processes and methodology. NIST CSF is a named standard triggering Sector-Adapted, but there are no firm-specific facts (no cybersecurity-specific roles, named tools, dates, or quantified details) to reach Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes integration of cybersecurity into ERM, and use of NIST CSF framework. This is about internal processes and methodology.

Category: Risk Management Process - describes ERM integration, framework adoption (NIST CSF), risk identification methodology.

Specificity: Names NIST CSF (framework). Any firm-specific facts? Let me check the IS list... No cybersecurity-specific titles, no named committees beyond generic, no specific dates, no named tools/firms, no numbers. The ERM integration is a common practice.

The mention of NIST CSF as a named framework suggests Sector-Adapted classification, but they're using it as a guide rather than maintaining formal certification, so that's a level 2 rating.

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


reasoning: The paragraph describes the incident response workflow — how threats are identified, assessed, contained, and reported. Although the VP of IT is the grammatical subject in several sentences, applying the person-vs-function test shows the content is about the process (notification → assessment → containment → reporting), not about the person's qualifications or background. Replace 'VP of IT' with 'the Company' and the paragraph still describes a coherent IR process. The VP of IT title is on the IS list as a cybersecurity-adjacent leadership role ('VP of IT/Security'), providing one firm-specific fact; however, 'SIEM partner' is unnamed, 'Audit Committee' and 'incident response plan' are on the NOT list, so no second hard verifiable fact exists for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the VP of IT's role in incident response - being informed of risks, assessing incidents, formulating responses, reporting to Audit Committee.

Category: This is about what happens when incidents occur - the process of identifying, assessing, containing, and resolving incidents. The VP of IT is mentioned but the paragraph is about the incident response *process*, not the person's qualifications/background. Applying the person-vs-function test: remove "VP of IT" and replace with "the Company" - the paragraph still describes an incident response workflow. → Risk Management Process.

Wait, let me reconsider. The VP of IT is the grammatical subject in most sentences.

But actually, the substance here is the workflow itself - what gets triggered when an incident is identified, the assessment steps, the response formulation, the reporting chain. There's nothing about the person's background or credentials. This is fundamentally describing a process, not a person.

Now I need to check the specificity list. "VP of IT" appears on the NOT list as a generic IT leadership title, similar to "Head of IT" or "IT Manager". The IS list mentions "VP of IT/Security" as cybersecurity-specific, but that's paired with Security - a standalone "VP of IT" is too general to be cybersecurity-specific.

"SIEM partner" is vague since it's unnamed, and "Audit Committee" is explicitly on the NOT list, so neither of those count as specific facts.

fact: VP of IT


reasoning: Applying the person-vs-function test: while the paragraph mentions the InfoSec Director's thought leadership and conference participation, the dominant content describes processes — monitoring information systems, deploying security measures, system audits, and incident response planning. Removing the person's identity, the paragraph still functions as a process description. Specificity is Firm-Specific: InfoSec Director is a cybersecurity-specific title and eRISC is a uniquely named internal body, but only FS-ISAC qualifies as a QV-eligible hard fact (named external organization), falling short of the two needed for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph discusses the "InfoSec Director" and "eRISC" and their role in monitoring cybersecurity incidents. Let me apply the person-vs-function test.

The paragraph mentions:
- InfoSec Director being informed about developments
- InfoSec Director is a thought leader/speaker at conferences (FS-ISAC, CISO summits)
- InfoSec Director implements and oversees monitoring processes
- Deployment of security measures, system audits
- Incident response plan

This is a mixed paragraph. There's some content about the person (thought leader, conference participation) and some about processes (monitoring, incident response). Let me think about the dominant category.

The header frames this as a process-focused section, and while the InfoSec Director's conference participation adds a personal dimension, the core content centers on what the role actually does—monitoring systems, deploying security measures, conducting audits, and maintaining incident response protocols. The person-vs-function balance leans toward function, though the thought leadership aspect does blur the line somewhat.

Now I'm cataloging the specific terms: "InfoSec Director" is a cybersecurity-specific title that belongs in the IS list, "eRISC" is a named internal program with a unique identifier so that's firm-specific, and "FS-ISAC" is a named external organization that could qualify as other_specific. The CISO summits reference is more generic and doesn't carry the same specificity weight.

fact: InfoSec Director (cybersecurity-specific leadership title)

fact: eRISC (named internal body with unique identifier)

fact: FS-ISAC (named cybersecurity conference/organization)


reasoning: This paragraph is general business context describing the company's IT environment, types of sensitive data collected (PHI, PII), regulatory landscape (HIPAA, CCPA), and how IT supports business operations. It contains no substantive cybersecurity disclosure — no processes, governance structures, risk management activities, or incident descriptions. While HIPAA and CCPA are named, they appear as incidental regulatory context for the company's data handling obligations, not as part of describing a cybersecurity program or framework. The paragraph is setting the stage for subsequent disclosure rather than making one.

thinking:
Let me analyze this paragraph from ModivCare Inc's 10-K Item 1C filing.

The paragraph describes the importance of IT systems, the types of data collected (PHI, PII, etc.), mentions HIPAA and CCPA regulations, and discusses IT infrastructure supporting business operations. It's general business/IT context language rather than describing a specific cybersecurity program, process, or governance structure.

This is borderline between None/Other and Risk Management Process. Let me think...

The paragraph doesn't describe any cybersecurity process, framework adoption, risk assessment, or specific security measures. It describes what data they collect and that they're subject to privacy laws. It's more of a business context paragraph.

Looking at the codebook guidance on regulatory compliance language—naming specific regulations like HIPAA and CCPA without describing company-specific programs should still count as Risk Management Process with Specificity 2 since the named standards trigger a sector-adapted classification. But I'm hesitant because this really reads as general business context rather than describing any actual risk management process. The paragraph is fundamentally about what data they handle and which regulations apply, not how they manage risks or comply with those regulations. The distinction in Case 9 is clear: naming specific regulations like HIPAA and CCPA does push this toward Risk Management Process, Specificity 2, even if the paragraph doesn't describe actual processes. But I'm hesitant because this really reads as business context rather than cybersecurity risk management—the regulations are mentioned as constraints the company operates under, not as part of how they manage cyber risk.

Looking at the actual content, it's describing IT systems' importance to operations, types of sensitive data handled, and the regulatory landscape. That's foundational business language, not cybersecurity disclosure. I think None/Other, Specificity 1 is the right call here—this is general context-setting, not a description of cybersecurity processes or risk management approaches. I keep second-guessing myself on whether this is really a cybersecurity risk management disclosure or just general business context. The paragraph mentions HIPAA and CCPA, but it's not describing any actual process—it's just saying what data we handle and what regulations apply. I think the core issue is that this is context-setting about IT systems and regulatory obligations, not a substantive description of how we actually manage cybersecurity risks. I'm going to commit to None/Other, Specificity 1, since there's no real process being disclosed here.

Wait, but the codebook Case 9 is explicit: if specific regulations like HIPAA and CCPA are named, it's Risk Management Process, Specificity 2, regardless of whether a program is actually described. The naming itself triggers that classification. So I should follow that rule and go with RMP, Specificity 2.

Actually, stepping back—this paragraph is really about the company's data environment and privacy compliance obligations, not cybersecurity risk management specifically. Even though it's in Item 1C of a 10-K filing, the HIPAA and CCPA references are framed as general regulatory context, not as part of a cybersecurity process or governance structure. There's no actual cybersecurity disclosure here—no processes, no management roles, no incidents. It's just background information about what data the company handles and what regulations apply. So None/Other is the right call.


reasoning: The paragraph describes the company's internal ERM Program processes for identifying and monitoring cybersecurity risks, plus incident response escalation procedures. Management is mentioned only as attribution — the substantive content is about processes (risk identification, monitoring, triage, response), making this Risk Management Process per the person-vs-function test. 'Enterprise Risk Management Program (ERM Program)' is a generic name used across many companies (not a unique identifier), 'incident response plan' is on the NOT list, 'senior members of management' is generic, and 'AppFolio' is a company self-reference. No named frameworks, cybersecurity-specific titles, dates, or quantified facts remain after filtering.

thinking:
Let me analyze this paragraph.

Content: Describes management team's ERM Program, how management is informed of cyber risks, and incident response procedures. The paragraph is about processes and programs, not about specific people's credentials.

Category: Risk Management Process - describes internal processes (ERM Program, risk identification, incident response). Management is mentioned but only as attribution. The person-vs-function test: remove management references and it's still about processes.

Specificity: Let me check facts:
- "Enterprise Risk Management Program (the 'ERM Program')" - named internal program with unique identifier? It has a name and abbreviation, but "Enterprise Risk Management Program" is pretty generic.

Now I'm reconsidering whether "ERM Program" is specific enough. The codebook example shows "Cyber Incident Response Plan (CIRP)" as a distinguishing name, but "Enterprise Risk Management Program" is extremely common across companies. Even with the abbreviation, it lacks the uniqueness the codebook seems to require. I'm leaning toward treating this as generic rather than firm-specific.


reasoning: The paragraph describes what management committees (IT Steering Committee, IT Subcommittee) do to manage cybersecurity risk — reviewing controls, monitoring threats, providing guidance, reviewing projects. Applying the person-vs-function test: removing the role titles and replacing with 'the Company' still yields a coherent process description. The committees and roles are organizational context, but the primary communicative purpose is describing internal cybersecurity risk management processes. Multiple firm-specific facts (CISO, CTO, named committees) place this at Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named third-party firms, named tools) reach the two-fact threshold.

thinking:
Let me analyze this paragraph carefully.

Content Category: The paragraph describes management committees (IT Steering Committee, IT Subcommittee) and their roles in cybersecurity. The CISO, CTO, CRO are mentioned along with their committee work. This is about organizational structure and internal processes for cybersecurity risk management.

Person-vs-function test: The paragraph is about what the committees DO (review controls, monitor threats, provide guidance, review projects). The CISO and other roles are mentioned as members of these committees, not for their personal qualifications. This is about the function/process, not about the people.

However, the paragraph describes management committees and their composition - this straddles Management Role and Risk Management Process.

The committees' functions and compositions are the main focus here. While the IT Steering Committee and IT Subcommittee are management-level structures assisting with cybersecurity, the emphasis is really on what these committees do—reviewing controls, monitoring threats, providing guidance, and assessing projects. Even if I remove the specific names and titles, the core processes and committee functions remain intact, which points toward Risk Management Process rather than Management Role.

There's tension between the composition details (who sits on these committees) and the functional descriptions (what they actually do), but the dominant content is about how these committees operate. The composition information is there to support understanding their function, not as the primary focus. I'm going with Risk Management Process as the category.

Now I need to verify the specificity markers—CISO and CTO are clearly cybersecurity-specific titles on the IS list, but I should double-check whether Chief Risk Officer appears explicitly in the defined list of IS titles.

Looking at the full IS list, I see CISO, CTO, CIO, VP of IT Security, Information Security Officer, and Director of IT Security, but Chief Risk Officer isn't there. The IT Steering Committee and IT Subcommittee are named non-generic committees that qualify as IS. Director of Internal Audit, CEO, and CFO don't meet the cybersecurity-specific criteria, and "quarterly" is just a generic cadence.

For Quantifiable Value, there are no specific dates, dollar amounts, headcounts, percentages, named third-party firms, products, tools, or certifications mentioned. Named roles and committees don't count toward QV eligibility, so this lands in Firm-Specific rather than QV.

fact: CISO

fact: Chief Technology Officer

fact: Chief Risk Officer

fact: IT Steering Committee

fact: IT Subcommittee

fact: Director of Internal Audit


reasoning: The paragraph describes the company's internal IT risk identification process, risk register, and how cybersecurity risks are categorized within it — all internal process description pointing to Risk Management Process. No named frameworks, cybersecurity-specific roles, dates, tools, or other IS-list facts are present; the categories listed (cybersecurity, data privacy, governance, application development) are generic.

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

Content: Describes the company's IT risk identification process, risk register, and how cybersecurity fits within it. This is about internal processes.

Category: Risk Management Process - describes internal risk assessment methodology, risk register, categories.

Specificity: Let me check for specific facts. No named frameworks, no named roles (cybersecurity-specific), no dates, no dollar amounts, no named tools. The risk register categories listed are generic. No IS-list items present. No named standards.

This is generic boilerplate language that could apply to most companies' risk management disclosures.


reasoning: The paragraph describes the company's internal cybersecurity processes — risk management integration, a cross-functional approach focused on confidentiality/security/availability, and an incident response plan. All content is about internal processes and methodology, making it Risk Management Process. No named frameworks, no cybersecurity-specific roles, no specific dates, tools, or firms appear; 'cross-functional approach,' 'incident response plan,' and 'cybersecurity risks' are all on the NOT list, leaving no firm-specific facts.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity processes integrated into risk management, cross-functional approach, and incident response plan. This is about internal processes and methodology.

Category: Risk Management Process - describes the company's own internal cybersecurity processes, risk management integration, incident response planning.

Specificity check:
- "cross-functional approach" - generic, not naming specific departments
- "incident response plan" - generic program name (on the NOT list)
- "Manager" - refers to an external manager (ORC is an externally managed REIT), but this is just attribution
- No named frameworks, no specific facts from the IS list

- No named roles, dates, tools, or firms mentioned

This is generic boilerplate without any named standards or company-specific details.


reasoning: The paragraph describes what the cybersecurity program does — monitoring, security measures, system audits, incident response planning. Applying the person-vs-function test: removing the CISO/CIO titles and replacing with 'the Company' leaves the paragraph fully intact as a process description. The CISO and CIO are incidental attributions, not the subject of the disclosure. Named cybersecurity-specific roles (CISO, CIO) place this at Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph.

Content: Describes what the CISO and CIO do - they stay informed, implement monitoring processes, deploy security measures, conduct audits, and have an incident response plan.

Category: The CISO and CIO are mentioned, but the paragraph is about what the program DOES - monitoring, security measures, audits, incident response. Apply the person-vs-function test: remove "Our CISO and CIO" and replace with "The Company" - the paragraph still makes sense as a process description. → Risk Management Process

Specificity:
- CISO → cybersecurity-specific title → IS list ✓

- CIO → cybersecurity-specific title → IS list ✓
- "incident response plan" → generic program name → NOT list
- "regular monitoring", "system audits", "security measures" → common practices → NOT list

I've identified CISO and CIO as specific roles, but they're not QV-eligible since there are no dates, dollar amounts, headcounts, named firms, tools, or certifications mentioned. With at least one IS fact present, this categorizes as Firm-Specific.

fact: CIO


reasoning: Applying the person-vs-function test: the paragraph's primary content describes what the company does — continuous monitoring, analyzing threats, implementing policies, training programs, security assessments. The CTO mention with 20 years of experience is one subordinate clause providing attribution ('Led by...'), but the paragraph still makes complete sense as a process description if that clause is removed. The CTO title (IS-list cybersecurity role) makes it Firm-Specific; 'over 20 years' is one QV-eligible fact, but a second QV-eligible fact is absent (named roles don't count toward QV), so it stays at Firm-Specific.

thinking:
Let me analyze this paragraph.

Content category: The paragraph starts with "Management plays a pivotal role" - about management's function. But then it describes the CTO's role and what the company does (processes, policies, training, assessments). The person-vs-function test: if I remove "Led by our Senior Vice President and Chief Technology Officer with over 20 years of cyber and risk management experience," the paragraph still describes processes. But the CTO mention with 20 years experience is significant content.

Actually, let me re-read. The paragraph has two parts:
1. Management's role in identifying/assessing/managing risks - generic process description

2. "Led by our SVP and CTO with over 20 years of experience" - person detail
3. "the Company actively implements and enforces cybersecurity policies, procedures, and strategies, including employee training programs, security assessments, and updates" - process description

The dominant content is about processes and activities. The CTO reference with their experience is just one clause. When I apply the person-vs-function test and remove the CTO mention, the paragraph still reads as a coherent process description. So this falls under Risk Management Process, not Management Role.

Looking at specificity: "Senior Vice President and Chief Technology Officer" identifies the CTO role clearly, but the emphasis is on what the company does, not who's leading it.

Now I'm checking what qualifies for QV eligibility. The "over 20 years" of experience is a specific number, which counts. The CTO title itself is firm-specific but doesn't meet QV standards. So I have one QV-eligible fact when I need two for that classification. That means this is Firm-Specific.


reasoning: The paragraph opens with an explicit materiality assessment ('have not experienced any cybersecurity incidents that have had a material impact on our service, systems, business, financial condition, or results of operations'), which per Rule 6 triggers Strategy Integration. The middle section is generic risk language with a cross-reference, and the final two sentences describe risk management processes, but the materiality conclusion frames the paragraph's primary communicative purpose. No specific facts survive the NOT-list filter: 'Management' is generic, 'cybersecurity consultants and third-party cybersecurity firms' are unnamed entities, and 'cybersecurity organization within our operations department' is a generic structural description without a unique identifier.

thinking:
Let me analyze this paragraph carefully.

The paragraph contains multiple elements:
1. "To date, we have not experienced any cybersecurity incidents that have had a material impact..." - This is a materiality assessment → Strategy Integration
2. "Any significant disruption..." - Generic risk language
3. "See 'Risk Factors...'" - Cross-reference
4. "Management has implemented risk management structures, policies, and procedures..." - Risk management process description
5. "We have a cybersecurity organization within our operations department..." - Risk management process

The paragraph starts with a materiality disclaimer, then has generic risk language and a cross-reference, then shifts to describing risk management processes.

The opening materiality statement is the clearest signal of Strategy Integration, but the paragraph also contains substantial risk management process descriptions at the end. The middle section is mostly boilerplate language and cross-references that don't add much weight to the classification. The RMP description at the end is concrete—they're implementing risk structures and maintaining a cybersecurity organization—but the paragraph really opens with and hinges on the materiality assessment. I'm going to land on Strategy Integration as the dominant purpose since that framing statement about not experiencing material incidents is what anchors the whole thing, even though the RMP content is substantive.

Now looking at specificity: "cybersecurity organization within our operations department" is telling me something about their actual organizational structure, which is company-specific. But I'm questioning whether that's specific enough to count—the examples on the IS list are things like Legal, Compliance, and Finance, which are more concrete functional areas. "Operations department" feels generic. The consultants and third-party firms mentioned aren't named, and there are no frameworks, dates, dollar amounts, or named roles anywhere in this section.

I'm concluding this is Generic Boilerplate—nothing from the IS list actually appears once I filter out the vague references.


reasoning: The paragraph contains an explicit materiality assessment ('we did not experience a material cybersecurity incident' in the year ended December 31, 2023), which per Rule 6 triggers Strategy Integration even though the surrounding text is generic risk language and a cross-reference to Risk Factors. The specific fiscal year-end date is the one firm-specific fact; the remainder is boilerplate risk acknowledgment that could apply to any company.

thinking:
Let me analyze this paragraph from RARE ELEMENT RESOURCES LTD's 10-K Item 1C filing.

This is a long paragraph that covers multiple topics. Let me break it down:

1. Generic cybersecurity risk acknowledgment
2. Commitment to governance and oversight (generic)
3. No material cybersecurity incident in year ended December 31, 2023 - this is a materiality assessment
4. Generic risk language about potential future incidents
5. Generic language about evolving threats
6. Generic language about detection and prevention
7. Regulatory compliance concerns
8. Cross-reference to Risk Factors

The key question is what's the dominant category. The paragraph contains an explicit materiality assessment—they state no material cybersecurity incident occurred in 2023, which per Rule 6 signals Strategy Integration. Even though the materiality statement is just one sentence among much boilerplate language, the explicit materiality disclaimer is the dominant signal here.

But I'm second-guessing myself on the dominant category rule. Most of the text is generic risk language that probably belongs in Risk Factors, not Item 1C. The materiality assessment is the most substantive cybersecurity-specific claim though, so that should drive the classification.

The date reference "year ended December 31, 2023" is specific to the fiscal year, which is standard disclosure practice. Let me think about whether this specificity matters for the categorization.

Actually, the codebook treats exact dates like "December 31, 2023" as firm-specific facts. That's one fact pointing toward Firm-Specific classification. The regulatory citation to Item 106(a) doesn't count as a firm-specific fact, but the date does.

So this disclosure is Strategy Integration with Firm-Specific characteristics.

fact: Year ended December 31, 2023 — no material cybersecurity incident


reasoning: The paragraph describes the company's own internal cybersecurity operations — continuous threat monitoring, identification, prevention, mitigation, and incident response/recovery plans. These are all internal process descriptions. No named frameworks, tools, roles, dates, or other specific facts appear; 'incident response and recovery plans' is generic program language on the NOT list.

thinking:
Classify this paragraph.

Content: Describes the company's cybersecurity operations - continuous threat operations, identifying/preventing/mitigating threats, incident response and recovery plans. This is about internal processes.

Category: Risk Management Process - describes internal cybersecurity processes (monitoring, threat operations, incident response).

Specificity: No named frameworks, no named roles, no dates, no specific facts. "incident response and recovery plans" is generic. "continuously and uninterrupted" = 24/7 but generic. No IS-list items.

→ Generic Boilerplate (1)


reasoning: The paragraph briefly mentions a 2021 ransomware incident but its primary communicative purpose is the materiality assessment — evaluating whether past and ongoing cybersecurity threats have materially affected or are reasonably likely to materially affect the company's business, results of operations, or financial condition. This matches the tiebreaker: 'brief mention of a past incident + materiality conclusion as the main point → Strategy Integration.' The year 2021 is one specific date (firm-specific), but no second QV-eligible hard fact exists (lawsuit, settlement, and cross-references are not on the QV list).

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Past cyber attacks experience (generic)
2. A specific 2021 ransomware attack - incident disclosure
3. A class action lawsuit from that attack - legal/strategy
4. A materiality assessment - strategy integration
5. Cross-references to other sections

The paragraph describes a real incident (2021 ransomware attack), mentions its legal consequences (lawsuit, settlement), and then provides a materiality assessment. Let me determine the dominant category.

The incident description is brief: "In 2021, the Bank was the target of a ransomware attack in which an external actor illegally accessed and/or acquired certain data on its network." Then it shifts to the lawsuit and settlement, then to a materiality assessment.

Looking at the tiebreakers, the incident itself gets only one sentence while the legal proceedings and materiality assessment take up the bulk of the discussion. This looks like a brief incident mention followed by a materiality conclusion as the main focus, so it should be categorized as Strategy Integration rather than Incident Disclosure.

For specificity, I'm finding just one concrete verifiable fact here—the 2021 date. The ransomware attack type is mentioned but without naming a specific tool or threat actor, and the class action lawsuit is a legal detail but not something on the IS list. So that's one firm-specific fact total.

fact: In 2021, ransomware attack on the Bank