fact: vulnerability scans related to our vendors' services

reasoning: The paragraph's central topic is how the company manages cybersecurity risks from third-party service providers — vendor management processes, assessments at different levels, contractual obligations, and security questionnaires — squarely answering 'how are third-party cyber risks managed?' The mention of 'vulnerability scans' is cybersecurity domain terminology (passes ERM test), elevating to Level 2, but there are no firm-specific or verifiable facts.

thinking:
Let me classify this paragraph.

Content: Describes how Vaxcyte manages third-party/vendor cybersecurity risks - vendor management processes, assessments, contractual obligations, security questionnaires, vulnerability scans.

Category: This is clearly about how third-party cyber risks are managed → Third-Party Risk (TP). The central topic is vendor oversight and requirements imposed on vendors.

Specificity: Let me scan for facts.
- "security questionnaires" - this is a vendor assessment practice, generic
- "vulnerability scans" - this is domain terminology (vulnerability scanning)

- "contractual obligations related to cybersecurity" - generic language
- "application providers, hosting companies, contract research organizations, and contract manufacturing organizations" - these are vendor types, not firm-specific

"Vulnerability scans" qualifies as domain terminology, so this lands at Level 2. There are no firm-specific facts or quantitative details here.


content_category: Risk Management Process

category_confidence: medium

specificity_confidence: high

reasoning: The paragraph describes the company's information security program as integrated and cross-functional, answering 'what does the program do?' However, it uses entirely generic business language with no domain terminology, no firm-specific facts, and no verifiable claims. 'Cross-functional approach,' 'comprehensive,' and 'integrated into operations' are general business terms that fail the ERM test.

provider: anthropic

generationId: agent-sdk

stage: benchmark


content_category: Strategy Integration

category_confidence: high

reasoning: The paragraph contains a backward-looking materiality assessment ('we do not believe we have…experienced a cybersecurity incident that materially affected our business, our business strategy, our results of operations or financial condition'), which is a conclusion about materiality → SI per Rule 5. The surrounding text is general risk language and speculation ('could materially adversely affect') plus a cross-reference to Item 1A. No domain terminology, firm-specific facts, or verifiable claims are present — all language is generic business/risk vocabulary any ERM professional could write — so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity risks the company faces, mentions "could materially adversely affect," includes a negative materiality assertion ("we do not believe we have...experienced a cybersecurity incident that materially affected..."), and cross-references Item 1A.

Category: The key sentence is "we do not believe we have...experienced a cybersecurity incident that materially affected our business, our business strategy, our results of operations or financial condition" — this is a backward-looking materiality assessment → SI.

The rest is general risk language and speculation ("could materially adversely affect" — not SI).

The materiality assessment conclusion makes this SI per Rule 5. Now I'm checking for specificity — the negative assertion about not experiencing a material incident isn't externally verifiable, so it doesn't qualify as QV. The paragraph lacks domain terminology and firm-specific facts like named roles or committees, just generic language around information theft and a work-from-home setup, with a cross-reference to Item 1A.

Looking at the language more carefully, terms like "cybersecurity threats," "information theft," and "extortion" are fairly standard boilerplate without any mention of specific security practices or frameworks. This is clearly Level 1 — Generic Boilerplate.


content_category: None/Other

reasoning: This paragraph is pure speculation and general business risk language ('may be a potential target,' 'may be exposed,' 'may depend upon') without describing any actual cybersecurity measures, processes, or assessments. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: The paragraph opens by stating the company develops and maintains systems and programs to mitigate cybersecurity incidents and continually monitors/updates them, which minimally answers 'what does the program do?' — pushing it past the N/O threshold per Rule 6. However, it is borderline N/O given the heavy risk-speculation language and cross-reference to Item 1A. No domain terminology, firm-specific facts, or verifiable claims are present — all language ('systems and programs,' 'monitor and update,' 'security measures') is generic business vocabulary any ERM professional would use.

thinking:
Let me analyze this paragraph.

Content: Generic language about developing systems to mitigate cyber incidents, monitoring/updating, mention of past/future occurrences causing adverse impacts, and a cross-reference to Item 1A Risk Factors.

Category: This is mostly generic risk language with a cross-reference. No specific cybersecurity measures described. "Systems and programs that seek to mitigate" is vague. The cross-reference points elsewhere. This feels like it could be RMP (very generic) or N/O. But it does say "we develop and maintain systems and operate programs" - that's describing what they do, albeit generically.

The first part makes vague claims about having cybersecurity programs and keeping them updated, while the second half is mostly speculation about potential incidents and then defers to another section. There's no concrete detail about what these systems actually do, making this lean toward N/O rather than a substantive risk mitigation practice disclosure. The paragraph does describe what they do—developing systems and programs to mitigate cybersecurity incidents—but it's so vague and wrapped in risk speculation that it reads more like an introduction to Item 1A than an actual description of measures. The codebook is clear that generic risk language without cybersecurity-specific content falls into N/O, and that's what I'm seeing here. I'll stick with N/O. is extremely generic. The cross-reference and risk language actually dominate the paragraph—only the first two sentences touch on actual measures, while the rest is risk framing and external references. The RMP content is too thin to be confident, but it's still the best fit since those opening sentences do describe program activities, however vaguely. I'll stick with RMP Level 1, though with less certainty than before.


content_category: Board Governance

reasoning: The paragraph answers 'How does the board oversee cybersecurity?' by describing the board's commitment to cybersecurity oversight and its delegation to the audit committee — classic BG content. No domain terminology, no firm-specific cybersecurity facts (board of directors and audit committee exist at every public company), and no verifiable claims, so it remains Level 1.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity - "board of directors", "audit committee", delegation of oversight. This answers "How does the board oversee cybersecurity?" → Board Governance.

Specificity: Let me scan for facts.
- "board of directors" - generic, every company has one
- "audit committee" - generic, every company has one
- "general partner's board of directors" - this is a partnership structure detail, not cybersecurity-specific
- No domain terminology (no specific security practices, tools, frameworks)
- No firm-specific cybersecurity facts (no CISO, no named committees beyond Audit Committee)

- No QV facts

This is generic board oversight language without any substantive cybersecurity details. Level 1.


content_category: Incident Disclosure

fact: ransomware incident

fact: phishing emails

fact: fourth quarter of fiscal year 2019

reasoning: The paragraph describes a real ransomware incident with timeline, scope, response actions (engaging consultants, forensic experts, law enforcement), and operational impact — directly answering 'what happened?' While it mentions financial consequences (costs, revenue impact), the incident frame dominates per Rule 4. The specific date 'fourth quarter of fiscal year 2019' tied to a cybersecurity event is a QV-eligible fact, elevating to Level 4.

thinking:
Incident Disclosure - describes a real ransomware incident from Q4 2019 with details about what happened, impact, and response.

Specificity: ransomware (domain term), Q4 fiscal year 2019 (specific date), specific event details. This is Level 4 with specific dates and named threat type.

Let me check: "fourth quarter of fiscal year 2019" - specific date tied to a cybersecurity event → QV. "ransomware" → domain term. The paragraph also mentions financial impact (costs, revenue impact), but the incident frame dominates.


content_category: Third-Party Risk

fact: IS Steering Committee

fact: Chief Information Officer (CIO)

reasoning: The paragraph's central topic is how the company manages third-party/vendor cybersecurity risks — describing the vendor management program's purpose, structure, and activities (identify, measure, monitor, control outsourcing risks), making TP the primary category. The IS Steering Committee (named non-generic committee) and CIO (cybersecurity-relevant VP+ title) are firm-specific facts elevating to Level 3, but the remaining language is general vendor risk management without domain-specific cybersecurity terminology or verifiable claims.

thinking:
Let me analyze this paragraph.

Content Category: This is about third-party/vendor risk management. The central topic is how the company manages vendor relationships and associated risks. It describes the vendor management program, who oversees it, and what it does. The primary question answered is "How are third-party cyber risks managed?" → Third-Party Risk.

Wait, let me reconsider. The paragraph describes the vendor management program - its purpose, oversight structure, and activities. The IS Steering Committee and CIO are mentioned as overseeing the vendor management program. The focus is on vendor oversight as the central topic → TP.

But there's also governance elements (Board direction, IS Steering Committee).

Actually, the central topic is clearly vendor management, and the governance mentions are just describing who manages the program. So this falls under Third-Party Risk.

Looking at specificity: The IS Steering Committee is a named committee specific to this firm, and the Chief Information Officer is a cybersecurity-focused executive role. There's no domain-specific terminology beyond standard vendor management language, and no quantifiable facts like numbers, dates, or external certifications that would qualify for QV eligibility.

This is Firm-Specific at Level 3.


reasoning: This paragraph is a cross-reference directing the reader to Item 1A for cybersecurity risk discussion, with no substantive cybersecurity disclosure itself. Cross-references are N/O per the codebook, and N/O always receives Specificity 1.


content_category: Management Role

reasoning: The paragraph answers 'how is management organized to handle cybersecurity?' by identifying the COO as the overseer of cybersecurity policies and processes. Person-removal test: removing the COO reference leaves only 'oversees our cybersecurity policies and processes,' which collapses to near-nothing substantive → MR. COO is not a cybersecurity-specific title (like CEO/CFO, it exists at every company), no domain terminology is present, and no verifiable facts are stated, so specificity remains Level 1.

thinking:
Classify this paragraph.

Category: This describes who oversees cybersecurity - the COO. It's about management's organizational role. But COO is not a cybersecurity-specific title. Let me think about BG vs MR. The paragraph says the COO "oversees" cybersecurity policies and processes. This is about management's role in handling cybersecurity - MR.

Wait - "oversees" could suggest governance. But this is about management (COO), not the board. So MR.

Person-removal test: Remove "Our Chief Operating Officer" → "oversees our cybersecurity policies and processes, including those described above." This collapses to nothing substantive about the program itself.

So that's MR. The COO title isn't cybersecurity-specific—it's a general executive role—and the language used is generic without any specialized terminology or quantifiable facts, putting this at Level 1.


reasoning: This paragraph acknowledges reliance on technology and associated security risks but describes no actual cybersecurity measures, processes, or organizational structures — it's generic business context. No domain terminology, firm-specific facts, or verifiable claims are present.


fact: Chief Information Security Officer (CISO)

reasoning: The paragraph centrally answers 'How are third-party cyber risks managed?' — describing processes to oversee service providers, pre-engagement security assessments, and ongoing compliance monitoring, making it TP. The CISO is mentioned as conducting periodic assessments, which is a firm-specific cybersecurity leadership role elevating to Level 3, but no quantified or externally verifiable facts push it to Level 4.

thinking:
Let me analyze this paragraph.

Content: About third-party risk management - vendor oversight processes, security assessments of providers, monitoring compliance, CISO and security specialists involved.

Category: This is centrally about how third-party cyber risks are managed → Third-Party Risk (TP). The paragraph answers "How are third-party cyber risks managed?" - it describes processes to oversee vendors, security assessments before engagement, monitoring compliance.

Specificity:
- "security assessments" - general enough to be L1
- "data breaches" - domain term? It's pretty common but let me think... "data breaches" is a specific threat type in cybersecurity context.

Actually, "data breaches" is fairly common business language now. Let me reconsider. "CISO" is firm-specific since it refers to a cybersecurity leadership role at VP+ level, making that Level 3. "Security specialists," "cybersecurity policies," and "security incidents" are all too generic. There are no QV-eligible facts here—no specific numbers, dates, named external entities, or certifications.


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

type: framework

fact: International Organization for Standardization (ISO) frameworks

reasoning: While the paragraph opens with board oversight framing, the majority of the text describes what the cybersecurity program does — ERM integration, framework adoption, and the company's approach to managing cyber risks — making RMP the best fit. NIST and ISO are named cybersecurity frameworks (domain terminology), but they are referenced as alignment ('based on'), not as held certifications, so specificity stays at Level 2.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph starts with board oversight but quickly moves to describing the cybersecurity program - ERM integration, frameworks, and the overall approach. The "what question" test: it answers multiple questions. The board mention is brief (2 sentences), then it shifts to what the program does (frameworks, approach). The majority of text describes the risk management process. Person-removal test isn't really needed here since there aren't specific persons. The board mention is framing, but the substance is about the program's design and framework basis.

Actually, let me re-read. Sentences:
1. Board recognizes importance of trust

2. Board is actively involved in oversight of risk management, cybersecurity is part of ERM
3. Cybersecurity policies/standards/processes are integrated into ERM and based on NIST, ISO frameworks
4. Company seeks to address cybersecurity risks through comprehensive cross-functional approach focused on confidentiality, security, availability

Sentences 3-4 are clearly RMP. Sentences 1-2 mention board but are transitional. The bulk is about the program. → RMP

Specificity:
- "National Institute of Standards and Technology" = NIST → domain term (Level 2)
- "International Organization for Standardization" = ISO → domain term (Level 2)
- "confidentiality, security and availability" - CIA triad language

So the board's role here is really just context-setting. The actual substance is about how the cybersecurity program operates within the ERM framework, grounded in established standards like NIST and ISO, with a cross-functional approach centered on the CIA triad principles.


fact: cybersecurity reviews of third-party vendors

fact: digital controls to monitor and manage third-party access

specificity_confidence: medium

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing vendor onboarding assessments, contractual cybersecurity requirements imposed on vendors, and monitoring of vendor access, all squarely TP. Specificity is Level 2: 'cybersecurity reviews,' 'digital controls to monitor third-party access,' and 'remediation' of cybersecurity risks show domain awareness beyond generic ERM language, but there are no firm-specific facts (Onex Corp. is the parent, not a unique cybersecurity role/committee) and no QV-eligible facts (no specific numbers, dates, named external firms, or certifications).

thinking: Third-party risk management is the central topic here.


reasoning: The paragraph contains only generic investment language ('invest in cybersecurity,' 'internal controls and processes,' 'protect our systems and infrastructure') without describing any actual cybersecurity measures, processes, or program details, followed by a cross-reference to Item 1A. None of the six substantive questions are answered—no board oversight, no management roles, no program activities, no third-party details, no incident, no materiality assessment. The cross-reference points elsewhere rather than disclosing anything. N/O at Level 1 as no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Content: Generic investment statement + cross-reference to Item 1A.

Category: The paragraph says they invest in cybersecurity and have controls/processes to protect systems. Then cross-references Item 1A. No specific question is primarily answered. The first sentence is generic RMP-like language but extremely vague. The cross-reference points elsewhere. This is borderline N/O vs RMP.

Per Rule 5/6: "If a paragraph describes any actual cybersecurity measure/process/assessment → relevant category." But this is extremely generic - "invest in cybersecurity," "adapt our internal controls and processes," "designed to help protect our systems and infrastructure." No actual cybersecurity measures are described. This is general business language.

The cross-reference to Item 1A Risk Factors signals this is really just a placeholder directing readers elsewhere, which makes it a clear N/O classification. The vague language about "internal controls and processes" and "protecting systems" doesn't articulate any concrete cybersecurity program or measure, so this gets a Level 1 specificity rating.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing incident response plan components (prioritization, evidence handling, communication, law enforcement engagement, severity-based protocols) — all program activities. Specificity remains Level 1 because every term used ('incident response plan,' 'data collection and evidence handling,' 'security incidents,' 'severity') is general business/risk management language that a non-security ERM professional could naturally write; no cybersecurity domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Content: Describes incident response plan details - prioritization, data collection, communication, law enforcement. This is about what the cybersecurity program does → RMP.

Specificity: Let me check for domain terms, firm-specific facts, and QV facts.

- "incident response plan" - this is listed as NOT domain terminology (Level 1)
- "prioritization guidelines" - general
- "data collection and evidence handling" - this could be domain... but "evidence handling" in context of incident response is somewhat domain-specific. Actually, let me apply the ERM test. Would a non-security ERM professional use "data collection and evidence handling"? Possibly in legal/compliance contexts. It's borderline.

- "communication channels" - generic
- "law enforcement engagement" - generic
- "security incidents" - generic
- "severity scale" - generic incident management

Looking at this more carefully, while "evidence handling" has a forensic ring to it, the codebook treats "incident response plan" as general business terminology, and the paragraph sticks to broad concepts without any NIST references, SOC mentions, or specific tools. Even the forensic-sounding language could fit in legal or compliance contexts. Everything points to Level 1.


reasoning: This paragraph states a conclusion about whether cybersecurity risks have materially affected the business (backward-looking) and whether they are reasonably likely to (forward-looking), making it a materiality assessment → SI. The language is standard boilerplate that could appear in any filing unchanged, with no domain terminology, firm-specific facts, or verifiable claims.


reasoning: The paragraph describes how the CEO and CFO are organized to handle cybersecurity incidents — their notification chain, decision authority over resources, and the flow of information to the Board of Managers. This answers 'how is management organized to handle cybersecurity?' The person-removal test leaves only a thin procedural shell ('incident response procedures... determine if resources needed'), confirming the substance is about roles, not program activities. For specificity, CEO and CFO are generic governance titles (not cybersecurity-specific), 'Board of Managers' is equivalent to Board of Directors, 'incident response procedures' is explicitly listed as non-domain terminology, and no domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Category: This describes incident response procedures, who gets notified, and the roles of CEO/CFO in handling incidents, plus board notification. The primary question: "What does the cybersecurity program do?" vs "How is management organized?"

The paragraph describes incident response procedures (RMP territory) but the substance is about WHO does what - CEO/CFO oversee, get notified, determine resources needed, Board gets notified of material incidents.

Person-removal test: Remove CEO, CFO, Board of Managers roles. What remains? "The Partnership has established incident response procedures... notified of cybersecurity incidents...

Even after removing the governance roles, there's still procedural substance left - the incident response procedures themselves, the notification flow, determining what resources are needed, and the remediation activities. But the core focus is really on the oversight chain and who's responsible at each level. This is fundamentally a governance structure paragraph about how management is organized to handle cybersecurity incidents, with some procedural elements embedded in it. The CEO and CFO are generic governance roles that exist everywhere, not cybersecurity-specific titles, so that doesn't add specificity. Looking at the language used—"incident response procedures," "Board of Managers"—there's no domain terminology that would pass the ERM test, no firm-specific cybersecurity roles, and no QV facts. This is clearly Level 1.


reasoning: This is a cross-reference pointing to Item 1A for cybersecurity risk factors, with no substantive cybersecurity disclosure itself. The 'may materially affect' language is pointing elsewhere, not stating a conclusion. N/O always receives Specificity 1.


fact: Director of Information Security

fact: over 30 years in information technology and information security

type: quantified

fact: Certified Information Systems Security Professional (CISSP)

fact: OD Technology Department

fact: Risk Committee

reasoning: The paragraph is organized around the Director of Information Security — their qualifications, experience, organizational role, team coordination, and reporting to the Risk Committee. Person-removal test: removing the Director's credentials, title, and reporting lines leaves only generic program language ('programs designed to protect... respond to incidents'), so MR wins. Specificity reaches Level 4 via 'over 30 years' (verifiable lower-bound quantity) and CISSP (verifiable certification via (ISC)²).

thinking:
Let me analyze this paragraph.

Content Category: This paragraph starts with the Director of Information Security's qualifications, then describes what the program does (protect systems, respond to incidents), team deployment, and monitoring activities. Let me apply the person-removal test for MR vs RMP.

Remove person-specific content: "has served in various roles in information technology and information security for over 30 years, and is a CISSP", "Director of Information Security", "He and other members of the OD Technology Department", reporting lines to Risk Committee.

Remaining: "implemented programs designed to protect our information systems from cybersecurity threats and position our Company to promptly respond to any cybersecurity incidents in accordance with our incident response and recovery plans.

The rest of the paragraph describes how multidisciplinary teams are deployed across the organization to handle threats and incidents, with ongoing monitoring and reporting of prevention, detection, mitigation and remediation activities. So there's still meaningful program description here, but the paragraph is heavily weighted toward the Director's background and organizational structure rather than the actual cybersecurity program itself. This feels like it's leaning toward MR—the person's qualifications and role are the main focus, with program details as supporting context. The experience requirement, CISSP certification, and specific department and committee names all point to firm-specific details that push this to Level 4 specificity.


fact: Named board member Paresh Patel identified as having IT expertise

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing periodic reporting to the board and identifying a board member with IT expertise — both core BG markers. Named individual Paresh Patel elevates to Level 3 as a firm-specific fact, but no verifiable credentials (e.g., CISSP) or quantified facts are present to reach Level 4.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity - receives reports, board member expertise. This answers "How does the board oversee cybersecurity?" → Board Governance.

Specificity:
- "Paresh Patel" - named individual in cybersecurity/board context → firm-specific
- "information technology expertise" - not a cybersecurity-specific credential
- No QV-eligible facts (no specific numbers, dates, certifications, named external entities)

Level 3 - Firm-Specific due to named individual.


reasoning: The paragraph's central topic is assessing and imposing security requirements on third-party service providers — directly answering 'how are third-party cyber risks managed?' All language ('security measures,' 'promptly report any suspected breach,' 'applicable laws') is general business/risk management vocabulary that any ERM professional would use; no cybersecurity domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Content: About assessing third-party service providers' security measures, requiring them to maintain security and report breaches. Central topic is vendor oversight → Third-Party Risk.

Specificity: No domain terminology (just "security measures", "breach" in general sense). No firm-specific facts. No QV facts. This is generic language about vendor oversight that any company could write.

Wait - "breach" could be domain terminology? Let me apply the ERM test. "Breach of its security measures" - this is fairly general business language. An ERM professional could use "breach" in non-cyber contexts too (breach of contract, data breach). In this context it's generic.

No domain terms, no firm-specific facts → Level 1.


fact: CISO

fact: CPO

fact: CIO

fact: VP of Global IT Security

fact: Certified Information Systems Auditor (CISA)

fact: Fellow of Information Privacy (FIP)

fact: Certified Information Privacy Professional (CIPP)

fact: Incident Response team

reasoning: The paragraph primarily answers 'how is management organized?' — it names four leadership roles, describes their qualifications and experience, and lists their certifications. While some program activity (Incident Response team meetings) is mentioned, the person-removal test shows the bulk of content is about roles and credentials. Specificity reaches Level 4 because CISSP, CISA, FIP, and CIPP are named certifications independently verifiable via their issuing bodies.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph describes management roles (CISO, CPO, CIO, VP of Global IT Security), their qualifications and certifications, and their responsibilities. The person-removal test: remove all person-specific content → "The cybersecurity and privacy offices are responsible for incident reporting and management... The Incident Response team... meets weekly and as needed to identify, respond, contain, and coordinate events..." Some program description remains but the bulk is about who leads, their qualifications, and credentials. The primary question answered is "How is management organized to handle cybersecurity?" → MR.

The leadership positions are firm-specific, but the certifications listed—CISA, CISSP, FIP, and CIPP—are all verifiable industry credentials, which pushes the specificity to Level 4.


fact: Cybersecurity Special Committee (named non-generic board committee)

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing a four-step incident response and breach management process and how incidents are assessed and prioritized. The person-removal test confirms RMP: removing the teams and committee references leaves a substantive process description. The four IR steps and severity-based prioritization use generic risk management language (Level 1), but the 'Cybersecurity Special Committee' is a named non-generic committee elevating specificity to Level 3.

thinking:
Let me classify this paragraph.

Content: Describes incident response and breach management processes with four steps, assessment/prioritization of incidents, and mentions the information security team reporting to a Board committee.

Category: "What does the cybersecurity program do?" — RMP. The paragraph describes the incident response process steps. The mention of the committee and reporting is subordinate to the process description.

Specificity:
- "incident response and breach management processes" — generic
- Four steps described are generic IR lifecycle
- "information security team" — not a named cybersecurity-specific title at VP+ level

- "legal team" — generic
- "Cybersecurity Special Committee" — this is a named non-generic committee → firm-specific (Level 3)
- "Board's Cybersecurity Special Committee" — board-level committee with specific name

The board-level committee would normally shift this to BG, but the core content is really about the four-step incident response process itself. When I remove the team names and committee references, the substantive program description of the IR lifecycle remains intact, so this stays in RMP. The specificity level is moderate since the committee name is firm-specific but the process steps themselves are generic. I'm seeing that "Cybersecurity Special Committee" is a named, non-generic committee structure that clearly signals Level 3 classification. The incident response steps outlined are generic lifecycle language, and while "information security team" is mentioned, it's not specific enough to push beyond the generic threshold—the codebook confirms similar team references don't qualify as firm-specific. So the Level 3 designation hinges on that named committee.


reasoning: The paragraph describes the Board's oversight role over risk management, consistent with 'How does the board oversee cybersecurity?' — though it uses entirely general enterprise risk language without any cybersecurity specificity. All terms (Board, CEO, senior management, standing committees, enterprise risk) are generic governance vocabulary found at every public company, with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Let me classify this paragraph.

Content: Board oversight of risk management generally. No cybersecurity-specific content.

Category: This talks about the Board's oversight of risk management process generally - not cybersecurity specifically. But it's in Item 1C, so it's framed as part of cybersecurity disclosure. The paragraph answers "How does the board oversee?" → Board Governance. But it's entirely general enterprise risk language with no cybersecurity specificity.

Actually, re-reading: "risk management process," "enterprise risk" - this is general governance language. It mentions Board oversight of risk but not specifically cybersecurity risk.

Since it's positioned in Item 1C, the context signals cybersecurity governance, and the paragraph does describe board oversight structure, so Board Governance fits. The language is entirely generic business and enterprise risk management terminology with no domain-specific terms, no company-specific details, and no facts unique to the firm - that puts it at Level 1 specificity.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing vendor due diligence, contractual security requirements, and ongoing monitoring of critical service providers, all squarely TP. SOC reports are domain terminology (a cybersecurity audit standard), elevating to Level 2. The Vendor Management team and 'dedicated information security resources' are generic organizational references, not firm-specific per the codebook's NOT lists.

thinking:
Let me analyze this paragraph.

Content: Describes how the company manages third-party vendor cybersecurity risks - due diligence, questionnaires, contractual requirements, ongoing monitoring.

Category: This is clearly about how third-party cyber risks are managed → Third-Party Risk (TP). The central topic is vendor oversight.

Specificity:
- "Service Organization Controls (SOC) reports" → domain term (Level 2)
- "self-attestation questionnaires" → general vendor management practice
- "Vendor Management team" → this is a named team but generic
- "dedicated information security resources" → generic

- "contractual requirements to meet... obligations to protect sensitive data against cybersecurity threats and unauthorized access" → general

The Vendor Management team is borderline - it's a named organizational unit but fairly common across companies, so not distinctly firm-specific. SOC reports stands out as domain terminology, making this Level 2. The rest of the language around cybersecurity threats, unauthorized access, and information security resources is standard industry vocabulary. I'm reconsidering whether "vendor management office" qualifies as firm-specific given its generic nature across organizations, so I'll classify this as a TP at Level 2 based on the SOC reports domain terminology.


fact: Chief Technology and Digital Officer

fact: Senior Vice President, Technology

fact: over 10 years of experience (Chief Technology and Digital Officer)

fact: 25 years of experience (SVP, Technology)

fact: Cybersecurity Committee

fact: Committee comprised of accounting, finance, legal, internal audit, and information technology

reasoning: The paragraph primarily answers 'How is management organized to handle cybersecurity?' — it identifies leadership roles and their experience, describes the Cybersecurity Committee's composition and membership, and defines the committee's role. While committee activities are listed, they are framed as the committee's organizational purpose ('The role of the Cybersecurity Committee is to...'), keeping this in MR territory. The specific years of experience ('over 10 and 25 years') are lower-bound quantified facts that are independently verifiable, elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph covers multiple things. Let me apply the "what question" test.

It describes management roles (Chief Technology and Digital Officer, SVP Technology, their experience), the Cybersecurity Committee (membership, activities), and reporting to the Board.

The primary content is about how management is organized - roles, qualifications, committee structure and membership, and what the committee does. The Board mention at the end is subordinate.

Person-removal test: Remove titles, qualifications, team composition, committee membership. What remains? "cyber risk assessments, monitor applicable key risk indicators, review cybersecurity training procedures, establish cybersecurity policies and procedures, and implement enhancements to our cybersecurity infrastructure.

There's some activity description but the bulk is about the committee's role and structure. This is leaning toward Management Roles since the paragraph frames committee activities through the lens of "The role of the Cybersecurity Committee is to..." rather than detailing specific risk management practices. The core question being answered is how the organization structures its management to oversee cybersecurity, which is fundamentally about governance and organizational design.

Looking at the specificity markers, I've got named roles like Chief Technology and Digital Officer and Senior Vice President of Technology, which are firm-specific. The committee itself is named and has a specific composition drawn from accounting, finance, legal, internal audit, and IT—all firm-specific details. The experience levels mentioned are lower bounds ("over 10 and 25 years"), which makes them verifiable. Monthly meetings is just a generic cadence. This puts us at Level 4 overall.


fact: penetration test

fact: Chief Information Officer (CIO)

fact: Information Security Policy and Program

fact: Risk Oversight Committee

fact: Enterprise Risk Management Committee (management committee)

reasoning: The paragraph primarily describes what the cybersecurity program does — auditing, penetration testing, and risk assessments — making it RMP. Person-removal test confirms: removing roles and committee names leaves a substantive program description. Specificity is Level 3 due to firm-specific facts: CIO (cybersecurity-adjacent C-level role), named 'Information Security Policy and Program,' named 'Risk Oversight Committee,' and named 'Enterprise Risk Management Committee.' No QV-eligible facts since third-party firms are unnamed and cadences are generic ('at a minimum, on an annual basis').

thinking:
Let me analyze this paragraph carefully.

**Content Category:**
This paragraph describes what the cybersecurity program does - testing, auditing, penetration testing, risk assessment. The Enterprise Risk Management Committee is mentioned but as the entity that oversees implementation. The primary question answered is "What does the cybersecurity program do?" - describing activities like Information Systems Audit, penetration testing, risk assessments.

Person-removal test: Remove the committee and roles - "Testing of the Information Security Policy and Program is accomplished through the use of a comprehensive Information Systems Audit... penetration test... assesses information security risks on at least an annual basis..." - substantive program description remains → RMP.

Now I'm looking at the specificity of the language used. Most of the titles mentioned—CEO, CFO, COO, Chief Administrative Officer—are generic corporate roles, though the CIO and Chief Risk Officer positions are more specialized. The "Information Security Policy and Program" is a named internal initiative that's firm-specific, and terms like "penetration test" and "Information Systems Audit" are domain-specific terminology rather than proprietary details.

The "Risk Oversight Committee" is a named committee that's non-generic, making it firm-specific. I need to reconsider the CIO classification—the codebook does list it as a firm-specific role alongside CISO and other IT leadership positions. Chief Risk Officer isn't explicitly cybersecurity-focused, so it doesn't meet that threshold, but the CIO definitely does.

So the Level 3 facts are the CIO title, the named "Information Security Policy and Program," and the "Risk Oversight Committee." The penetration test reference is Level 2 domain terminology.

There are no quantifiable facts here—no specific numbers, dates, or named external firms, just generic references to third-party consultants. This puts it at Level 3.


fact: Chief Information Security Officer (CISO)

reasoning: Person-removal test: removing the CISO and Board references leaves 'processes to assess, identify, manage and report cybersecurity risks,' 'business continuity plans,' 'regular evaluations of systems,' and 'enhancements to security infrastructure' — a substantive program description, so RMP. The vocabulary is almost entirely generic ERM language ('processes to assess, identify, manage,' 'regular evaluations,' 'business continuity plans,' 'security infrastructure'), none of which passes the ERM test for domain terminology. The CISO title is firm-specific, elevating to Level 3, but no QV-eligible facts are present.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph describes the cybersecurity program - processes to assess, identify, manage risks, business continuity, evaluations, security infrastructure enhancements. The CISO and Board are mentioned as attribution/context. Person-removal test: remove "Led by our CISO" and "under the oversight of our Board" - the remaining text describes processes, evaluations, enhancements to security infrastructure. That's a substantive program description → RMP.

Specificity: Let me scan for facts.
- "Chief Information Security Officer" / "CISO" → firm-specific (cybersecurity leadership role at VP+ equivalent)

- "IT security teams" → not firm-specific enough (generic)
- "processes to assess, identify, manage and report cybersecurity risks" → Level 1 (generic ERM language)
- "business continuity plans" → Level 1
- "regular evaluations" → Level 1
- "security infrastructure" → Level 1
- "cybersecurity threats" → Level 1

The CISO is the only firm-specific element here. Everything else—the risk assessment processes, business continuity planning, evaluations, and infrastructure improvements—reads as standard boilerplate without any quantifiable facts or domain-specific details that would distinguish this program.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors for cybersecurity risk descriptions — it provides no substantive cybersecurity disclosure itself. The mention of materiality is in the context of pointing elsewhere ('see our risk factors'), not stating an assessment. No domain terminology, firm-specific facts, or verifiable claims are present.


fact: ransomware attacks

fact: phishing attacks

fact: insider threats

reasoning: The paragraph contains a backward-looking materiality assessment ('none of which…have had a material impact on its business information systems or operations'), which is a conclusion about whether cybersecurity has affected business outcomes → SI per the materiality rule. The remaining content is general risk acknowledgment and a cross-reference. Specificity reaches Level 2 due to named threat types (ransomware, phishing, insider threats) that pass the ERM test, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content category: The paragraph discusses material cybersecurity risks (ransomware, phishing, insider threats, third-party attacks), monitoring, and includes a materiality assessment ("none of which...have had a material impact"). It also mentions disaster recovery and cross-references Item 1A.

The materiality assessment "none of which...have had a material impact on its business information systems or operations" is a backward-looking materiality conclusion → SI.

But the paragraph is mixed. Let me assess what dominates:
- Lists material cybersecurity risks (ransomware, phishing, insider threats, third-party attacks)

- Monitoring systems
- Past incidents acknowledged but no material impact → materiality assessment
- Disaster recovery process
- Cross-reference to Item 1A

The materiality conclusion is present: "none of which...have had a material impact" → SI per Rule 5. The paragraph's primary content is acknowledging risks and stating no material impact, with the materiality assessment being a key statement here. I'll go with SI.

For specificity, I'm seeing domain-specific threat types like ransomware and phishing attacks, which push this toward Level 2 at minimum. Insider threats are somewhat domain-specific too. The disaster recovery process and exercised annually cadence are more generic. There are no firm-specific facts, named roles, or committees, and no quantifiable facts either. This lands at Level 2.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors for cybersecurity risk descriptions. It uses speculative 'may materially affect' language pointing elsewhere rather than stating a materiality conclusion, and quotes a generic risk factor title. Per the codebook, cross-references like 'risks that may materially affect us, see Item 1A' are N/O. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: The paragraph describes how the Audit Committee and Board receive cybersecurity updates and discuss cybersecurity risks, directly answering 'how does the board oversee cybersecurity?' No domain terminology (risk management, business continuity planning are general business terms), no firm-specific facts (Audit Committee and Board exist at every public company), and no verifiable claims ('at least annually' is a generic cadence), so specificity remains Level 1.

thinking:
Let me classify this paragraph.

Content: Describes how Audit Committee members engage with management on cybersecurity, how material cyber risks are considered in Board meetings, and how updates flow to the Board. This answers "How does the board oversee cybersecurity?" → Board Governance.

Specificity: Let me scan for facts.
- "Audit Committee" — every public company has one, NOT firm-specific
- "Board" — generic
- "at least annually" — generic cadence
- "risk management, business continuity planning" — general business terms, not domain terminology
- "cybersecurity risk management and strategy programs" — generic

- "cybersecurity threats and risk mitigation" — generic business language

No domain terminology that passes the ERM test. No firm-specific facts. No QV facts. This is Level 1.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors for cybersecurity risk descriptions. It points elsewhere rather than making a substantive cybersecurity disclosure itself. The quoted language is speculative ('could experience adverse consequences') rather than an assessment, and the paragraph contains no domain terminology, firm-specific facts, or verifiable claims.


reasoning: The paragraph opens with a backward-looking materiality assessment ('we do not believe that our business strategy, results of operations or financial condition have been materially adversely affected'), which is a conclusion about whether cybersecurity has affected business outcomes → SI. The remainder is generic risk acknowledgment and vague statements about investing in capabilities, with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

The paragraph starts with a materiality assessment ("we do not believe that our business strategy, results of operations or financial condition have been materially adversely affected"), then discusses the threat landscape generally, and ends with generic statements about assessing risks and investing in capabilities.

Content Category: The first clause is a backward-looking materiality assessment → SI. The rest is generic risk language. The materiality assessment is the most specific/substantive claim. SI wins.

Specificity: Let me scan for facts.
- "materially adversely affected" - this is a materiality assessment conclusion, but as a negative self-assertion it's not externally verifiable

- The rest is just boilerplate—mentions of financial institutions, customers, colleagues, regulators, and service providers are all generic stakeholder references with no domain-specific terminology, firm-specific details, or substantive facts. This is Level 1 language.


fact: ISO 27001 compliance certification (domain standard)

fact: SomaLogic Operating Co, Inc. — named external entity involved in merger/integration

fact: SomaLogic's ongoing ISO 27001 compliance certification — verifiable claim via certification body

fact: Early 2024 merger completion

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' — it describes the wholesale review and integration of cybersecurity policies, procedures, and tools following a merger, which are program activities (RMP). While the merger context could suggest Strategy Integration, the substance is about cybersecurity program integration work, not a materiality assessment or business-impact conclusion. Specificity reaches Level 4 because SomaLogic Operating Co, Inc. is a named external entity and the paragraph states SomaLogic maintains 'ongoing ISO 27001 compliance certification,' which is an externally verifiable claim checkable against ISO certification registries.

thinking:
Let me analyze this paragraph.

Content: Describes a merger with SomaLogic, review of cybersecurity policies/procedures/tools for the combined entity, and notes SomaLogic's ISO 27001 compliance certification.

Category: This is about integrating cybersecurity programs post-merger. The primary question it answers is "What does the cybersecurity program do?" - specifically reviewing and integrating cybersecurity policies, procedures, and tools. This is RMP - it's about program activities (review, integration of security measures). Could be SI since it mentions a merger's impact, but the content is really about the cybersecurity program integration activities, not about how cybersecurity affects business/finances.

Now I'm looking at the specificity of the claims. The ISO 27001 compliance certification is a verifiable claim about SomaLogic that qualifies as QV at Level 4, and SomaLogic Operating Co, Inc. is a named entity involved in the merger. The date "early 2024" is somewhat soft, and ISO 27001 itself is domain terminology at Level 2. The paragraph essentially states that SomaLogic maintains an ongoing ISO 27001 compliance certification as part of their approach.


fact: CISO leads the corporate information security organization

fact: cyber threat detection and response

fact: security engineering

fact: certificate in Cybersecurity Oversight from the Carnegie Mellon University Software Engineering Institute

reasoning: The paragraph primarily answers 'how is management organized?' — it introduces the CISO, describes their qualifications and experience, and defines the corporate information security organization's responsibilities. While some program activities remain after person-removal, the CISO's credentials and organizational role are the primary content. The Carnegie Mellon University Software Engineering Institute certificate in Cybersecurity Oversight is an externally verifiable credential, elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph describes the CISO's role, qualifications, and the corporate information security organization. Let me apply the person-removal test for MR vs RMP.

Remove person-specific content (CISO title, experience, certificate, reporting): What remains is "corporate information security organization is responsible for overall information security strategy, policy, security engineering, operations and cyber threat detection and response... oversees, manages, and continually enhances a robust enterprise security structure with the goal of preventing cybersecurity incidents...

The rest of the paragraph continues describing the organization's responsibilities around system resilience and employee involvement in security culture. Looking at the overall structure, the CISO's qualifications and experience take up a meaningful portion, but there's substantial content about what the organization actually does and its mission. The paragraph is roughly balanced between describing the person's credentials and describing the organization's functions, though the person-specific elements are concentrated at the beginning.

The core question being answered is really about organizational structure—who leads this security function, what are their qualifications, and what responsibilities does the organization carry. The Carnegie Mellon certification is externally verifiable and represents a specific, high-level credential. The other qualifications and domain expertise mentioned are more general industry terms, while the CISO role itself is firm-specific.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors for cybersecurity risks that 'may materially affect' the company — it points elsewhere rather than stating a materiality conclusion itself, making it N/O. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: The paragraph describes third-party service providers hired to assess and support the company's own security program (threat landscape views, monitoring, breach response support), which per Rule 3 is RMP—not TP—because these firms serve the company's program rather than being vendors whose cybersecurity posture is being assessed. All language ('information security program,' 'control environment,' 'breach notification and response processes,' 'cyberthreat landscape') is general business/compliance vocabulary that a non-security ERM professional would comfortably use; no domain-specific terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me classify this paragraph.

Content: Describes third-party service providers who assess the company's security program, provide threat landscape views, and support monitoring/control/breach response.

Category: These are third parties hired to serve the company's own security program. Per Rule 3: "Third parties hired to serve the company (assessors, consultants, pen testers) → RMP." The central topic is what these third parties do FOR the company's program, not requirements imposed on vendors. → RMP

Specificity: Let me scan for facts.
- "third-party service providers" — unnamed, not firm-specific

- "information security program" — generic
- "cyberthreat landscape" — fairly general business language in cybersecurity context
- "control environment" — general audit terminology
- "breach notification and response processes" — standard compliance language

I'm checking whether these terms would resonate with a non-security ERM professional. "Cyberthreat landscape," "breach notification and response," and "control environment" are all fairly mainstream business language now, not specialized domain terminology. I don't see the kind of firm-specific or technical jargon that would clearly mark this as domain-specific.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing the Board's delegation to the Audit Committee and the Committee's oversight of management's cybersecurity program — a classic governance-chain paragraph. No domain terminology, firm-specific facts, or verifiable claims are present; 'Board,' 'Audit Committee,' and 'cybersecurity risk management program' are generic terms found at every public company.

thinking:
Classify this paragraph.

Category: "How does the board oversee cybersecurity?" → Board Governance. Board delegates to Audit Committee, Audit Committee oversees management's implementation. This is oversight structure.

Specificity: Let me scan for facts.
- "Board" / "Audit Committee" — every public company has these, NOT firm-specific
- "cybersecurity risk management program" — generic program name
- No domain terminology (no specific security practices, tools, frameworks)
- No firm-specific facts (no named roles like CISO, no named committees beyond Audit Committee)
- No QV facts

- This is Level 1 specificity.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by stating the company has processes to assess, identify, and manage cybersecurity risks and that the Investment Adviser has implemented a cybersecurity program — this is RMP, though extremely generic. No domain terminology, no firm-specific facts (Investment Adviser is a generic structural reference for externally managed BDCs, not a named entity), and no verifiable claims, leaving this at Level 1.

thinking:
Let me analyze this paragraph.

This is from a BDC (Business Development Company) that depends on an external Investment Adviser for operations.

Category: The paragraph says the company has processes to assess/identify/manage risks, depends on the Investment Adviser's systems, and the Investment Adviser has implemented a cybersecurity program. This is describing what the program does at a very high level - RMP. But it's extremely generic. The "processes to assess, identify, and manage material risks" is standard boilerplate. The mention of the Investment Adviser having a cybersecurity program is a brief organizational note.

Actually, this is a BDC - externally managed.

The Investment Adviser manages operations and has a cybersecurity program in place, which is the RMP category. Looking at the specificity here, I'm seeing mostly generic language - "processes designed to assess, identify, and manage material risks from cybersecurity threats" is textbook boilerplate, the Investment Adviser reference is unnamed, and mentions of third-party service providers and the cybersecurity program itself lack any firm-specific details or domain terminology. This reads as L1 specificity across the board.


fact: ransomware attack

fact: malware

fact: persistence mechanisms

fact: forensic analysis

fact: compromised exchange on-premises accounts (Microsoft Exchange)

reasoning: The paragraph describes an actual ransomware incident from early 2019 — its nature, scope, investigation, and remediation — squarely answering 'what happened?' → Incident Disclosure. Multiple domain terms (ransomware, malware, persistence mechanisms, forensic analysis) establish at least Level 2, and the reference to 'exchange on-premises accounts' identifies Microsoft Exchange as a named system/product, which is externally verifiable, pushing to Level 4.

thinking:
Classify this paragraph.

Content: Describes a 2019 ransomware attack - what happened, impact, investigation, remediation. This is clearly Incident Disclosure.

Specificity:
- "ransomware attack" - domain term (specific threat type)
- "early 2019" - specific date
- "malware, persistence mechanisms" - domain terms
- "forensic analysis" - domain term
- "encrypted certain information technology systems" - describes the attack

"early 2019" - this is a timeframe tied to a real event, specific enough for QV
"ransomware" - domain term

"malware, persistence mechanisms" - domain terms
"forensic analysis" - domain term

Actually, I need to reconsider whether "early 2019" meets the specificity threshold. It's a bounded timeframe but not as precise as month+year, so I'm being conservative and marking it as not quite specific enough. And the investigation firm mentioned is unnamed, so that doesn't count as a qualified verifiable fact either. Looking more carefully at what actually qualifies - there are no named external sources, no specific numbers, and no exact dates that would meet the codebook's requirements.

But wait, "compromised exchange on-premises accounts" - that's referencing Microsoft Exchange as a specific system, which might push toward more technical specificity.


fact: Chief Technology Officer tasked with cybersecurity

reasoning: The paragraph answers 'how is management organized to handle cybersecurity?' by describing the CTO's responsibility for cybersecurity risk and the IT Director's supporting role. Person-removal test collapses the paragraph. CTO is a firm-specific cybersecurity leadership role (VP+ level); 'IT Director' is a generic IT title without a security qualifier and does not qualify. No verifiable facts (years of experience not quantified, no certifications named), so specificity stays at Level 3.

thinking:
Let me analyze this paragraph.

Category: This is about management roles - CTO tasked with cybersecurity, IT Director's role and background. Person-removal test: remove CTO, IT Director, expertise, roles → nothing substantive remains. → MR

Specificity:
- CTO = cybersecurity-specific leadership role at VP+ level → firm-specific
- "IT Director" - this is "Director of IT" without security qualifier → NOT firm-specific per codebook
- No QV facts (no specific numbers, dates, named firms, certifications)

So Level 3 based on CTO.


fact: Specific team composition by department: Legal/Compliance, Corporate Security, Internal Audit, Human Resources, Directors of Banking and Mortgage, Corporate Communications

reasoning: The paragraph describes which roles and departments may join incident response teams, answering 'how is management organized?' Person-removal test leaves only a hollow shell ('representatives may be included from time to time'), confirming MR. The enumerated list of specific departments (Legal/Compliance, Corporate Security, Internal Audit, Human Resources, Directors of Banking and Mortgage, Corporate Communications) constitutes a firm-specific team composition that distinguishes this company's organizational approach, elevating to Level 3.

thinking:
Let me analyze this paragraph.

It describes who may be included on incident response teams - listing various corporate roles and departments. The primary question: "How is management organized to handle cybersecurity?"

This is about team composition for incident response. It lists specific departments and roles that may participate.

Person-removal test: Remove all person-specific content. What remains? "Depending upon the type of incident or event, representatives from other areas of the Company may be included on any of these teams from time to time for a particular investigation/response." - This collapses to near-nothing substantive.

So MR.

Specificity: Let me scan for facts.

The departments listed—Legal/Compliance, Corporate Security, Internal Audit, Human Resources, Directors of Banking and Mortgage, and Corporate Communications—form a concrete organizational structure that's specific to this company. "Directors of Banking and Mortgage" especially signals firm-specific operations. While titles like CFO and CEO are generic, the particular combination of departments and the banking/mortgage reference make this Level 3.


fact: over 25 years of work experience in information technology and cybersecurity

reasoning: Person-removal test: stripping the Senior Director of IT and CFO along with their qualifications leaves only 'Our cybersecurity risk assessment and management processes are implemented and maintained' — near-nothing — so this is MR. 'Over 25 years' is a lower-bound quantified fact verifiable against a resume, elevating to Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes management roles (Senior Director of IT, CFO) and their qualifications/experience in relation to cybersecurity risk assessment and management processes.

Category: The paragraph starts with "cybersecurity risk assessment and management processes" but the bulk of the text is about WHO implements them and their qualifications. Person-removal test: remove all person-specific content → "Our cybersecurity risk assessment and management processes are implemented and maintained." That's near-nothing. → MR.

Specificity:
- "Senior Director of Information Technology" — Director-level title. Per codebook: "Director of IT" without security qualifier is NOT firm-specific.
- "Chief Financial Officer" — NOT firm-specific (generic governance role)
- "over 25 years of work experience" — this is a quantified fact with a lower bound, verifiable against resume. The codebook confirms lower bounds count as QV.
- No domain terminology that passes the ERM test.

So: MR, Level 4.


reasoning: The paragraph opens with a brief Board oversight mention but the majority of text describes the company's general approach to cybersecurity risk management ('comprehensive, cross-functional approach focused on preserving confidentiality, security and availability... identifying, preventing and mitigating cybersecurity threats'). By text volume, the program description dominates, making RMP the best fit. All language is entirely generic—'cross-functional approach,' 'ERM,' 'policies, standards, processes and practices'—with no domain terminology passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Let me classify this paragraph.

Content: Board oversight mention, ERM integration, general approach to cybersecurity. The paragraph starts with the Board but quickly shifts to describing the company's general approach. The "what question" test: it's a mix of board oversight and general program description, but mostly generic framing.

The Board mention is brief - "Board is actively involved in oversight." The rest describes the general approach to cybRM/cybersecurity in very generic terms.

This is primarily answering "What does the cybersecurity program do?" but in extremely generic terms. Actually, it's a mix - the first part is about Board oversight, the second is about the program approach.

Looking at the text distribution, the Board gets minimal coverage while the bulk focuses on the company's risk management approach to cybersecurity. I'm checking for specificity - domain terminology, firm-specific facts - and finding mostly generic language like "confidentiality, security and availability," "cross-functional approach," and standard business terms. This lands in RMP category since it's fundamentally describing the cybersecurity risk management program, though it lacks any real domain expertise or concrete details.


reasoning: The paragraph states two materiality conclusions — a backward-looking assessment ('have not... materially affected') and a forward-looking assessment ('reasonably likely to materially affect') — both squarely answering how cybersecurity affects the business, making this SI. The third sentence is a cross-reference subordinate to the assessments. No domain terminology, firm-specific facts, or verifiable claims are present; the language is pure SEC boilerplate usable by any filer.

thinking:
Let me analyze this paragraph.

Content: Two materiality assessments (backward-looking negative, forward-looking "reasonably likely") plus a cross-reference to Item 1A.

Category: The first sentence is a backward-looking materiality assessment → SI. The second sentence uses "reasonably likely to materially affect" → SI (forward-looking assessment per SEC Item 106(b)(2)). The third sentence is a cross-reference → N/O. But the dominant content is two materiality conclusions → **Strategy Integration**.

Specificity: Let me scan for facts.

The language here is purely generic boilerplate—phrases like "have not materially affected" and "reasonably likely to materially affect" are standard SEC language with no firm-specific details, domain expertise, or quantifiable facts backing them up. This reads like template language that could fit any filing.

Level 1.


reasoning: This is a cross-reference directing readers to Item 1A Risk Factors, not a substantive cybersecurity disclosure. The 'may materially affect' language points elsewhere rather than stating a conclusion. N/O always receives Specificity 1.


fact: penetration testing

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' — describing risk assessment, policies, frameworks, and security control evaluations. Third parties are mentioned as serving the company's own program (assessors, pen testers, consultants → RMP per Rule 3), not as vendors whose cybersecurity is being overseen. 'Penetration testing' is the sole domain term elevating specificity to Level 2; the rest is generic process language (risk assessment, policies, evaluations) that any ERM professional could write.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph describes what the cybersecurity program does - risk assessment, policies, practices, frameworks, security controls evaluation. It mentions third parties but as part of serving the company's own program (assessors, pen testers, consultants → RMP per Rule 3). The primary question answered is "What does the cybersecurity program do?" → RMP.

Specificity: Let me scan for facts.
- "penetration testing" → domain term (Level 2)
- "cybersecurity consultant" → unnamed, not firm-specific

- "third party frameworks" → generic
- "independent audits" → generic
- The rest is generic process language

So Level 2 based on "penetration testing."


reasoning: The paragraph primarily answers 'How does the board oversee cybersecurity?' by describing the Board's ultimate risk oversight responsibility and the Audit Committee's specific oversight of cybersecurity strategies, risks, and data protection. Specificity is Level 1 because the paragraph uses only general governance and ERM language — 'Audit Committee' is not firm-specific (every public company has one), and there are no domain terms, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph discusses board and committee oversight of cybersecurity. It mentions the Board's responsibility for risk oversight and the Audit Committee's role in overseeing IT security, cybersecurity strategies, and risk management. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

Specificity: Let me scan for facts.
- "ERM" - general business term, not domain terminology
- "Audit Committee" - every public company has one, NOT firm-specific
- "Board" - generic
- "cybersecurity strategies and risks, data privacy and data protection" - general

- "Information Security" - just a label they've defined, no actual domain terminology like NIST, SOC, or penetration testing
- No firm-specific details like a named CISO or specialized committees beyond the standard Audit Committee
- No QV facts

This is entirely generic boilerplate that could appear in any company's filing. Level 1.


reasoning: The paragraph states a conclusion about materiality ('have not identified any cybersecurity incidents or threats that have materially affected us or are reasonably likely to materially affect us'), which is a backward-looking and forward-looking materiality assessment → SI per Rule 5. The cross-reference to Risk Factors is subordinate. No domain terminology, firm-specific facts, or verifiable claims are present — all language is generic boilerplate any company could use.

thinking: Materiality assessment paragraph.


reasoning: The paragraph primarily answers 'How does the board oversee cybersecurity?' — describing the Audit Committee's oversight role, how information flows from management to the committee and full Board, and periodic reporting structures. This is a governance-chain paragraph centered on board oversight. For specificity, domain terms like 'information security training and awareness program' and 'information security audits' pass the ERM test, but the Director of Global Information Systems is a director-level title without a security qualifier (not firm-specific), the Audit Committee exists at every company, and 'independent cybersecurity advisor' is an unnamed entity — so the paragraph stays at Level 2.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph answers "How does the board oversee cybersecurity?" - it describes the Board's role, the Audit Committee's oversight, how information flows to the board (periodic updates, annual reports). The Director of Global Information Systems is mentioned but in the context of reporting TO the Audit Committee. This is clearly Board Governance.

Specificity: Let me scan for facts.
- "Director of Global Information Systems" - this is a named role. Is it firm-specific? It's a director-level title. Per the codebook, "Director-level titles WITH a security qualifier" are firm-specific, but "Director of IT" without security qualifier is not.

So looking at the remaining specificity claims: the Director of Global Information Systems is just a standard IT director title without a security focus, so not firm-specific. The Audit Committee is standard across public companies. "Information security training and awareness program" and "annual third-party and internal information security audits" are domain terminology rather than firm-specific claims. The mention of an independent cybersecurity advisor is vague and unnamed, making it more of a generic third-party reference than a concrete firm-specific detail. The unnamed cybersecurity advisor doesn't qualify as firm-specific since external consultants fall outside that category per the codebook. And while "Director of Global Information Systems" is a director-level role, it lacks the security qualifier needed to be firm-specific. So this lands at Level 2 - Domain-Adapted.


reasoning: The paragraph's central topic is oversight of external vendors' cybersecurity posture—reviewing their internal controls and procedures—which directly answers 'How are third-party cyber risks managed?' → TP. All language is generic business/ERM vocabulary ('internal controls,' 'procedures,' 'mitigate risks'); swapping 'cybersecurity' for 'financial' would produce equally natural text, so no domain terminology is present and specificity remains Level 1.

thinking:
Let me classify this paragraph.

Content: About managing third-party vendor cybersecurity risks - reviewing internal controls of third-party service providers.

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

Specificity: Let me scan for facts.
- "internal controls" - general business term, Level 1
- "third-party vendors", "third-party service providers" - general terms
- "cybersecurity threats/risks" - topic of the filing, not domain terminology
- No domain terms, no firm-specific facts, no QV facts

- The language is generic vendor oversight without specialized terminology like SOC 2 or specific assessment frameworks. This passes the ERM test—swap cybersecurity for financial and the statement remains equally valid. Level 1.


reasoning: This paragraph defines regulatory terms by cross-referencing Item 106 of Regulation S-K; it contains no substantive cybersecurity disclosure. N/O always receives Generic Boilerplate.


reasoning: The paragraph's central topic is oversight of third-party service providers' cybersecurity — vendor management program, periodic reviews of vendors' cybersecurity controls, risk-based review frequency — squarely answering 'how are third-party cyber risks managed?' For specificity, the language is entirely general business/ERM vocabulary ('vendor management program,' 'periodic reviews,' 'cybersecurity controls,' 'risks from cybersecurity threats'); no domain-specific security terms pass the ERM test, 'Fidelity' is the company sponsor (not an external named firm), and there are no firm-specific or verifiable facts.

thinking:
Let me analyze this paragraph.

Content: About third-party vendor cybersecurity oversight. The central topic is how third-party cyber risks are managed - vendor management program, oversight of third-party service providers, periodic reviews of their cybersecurity controls, risk-based frequency.

Category: Third-Party Risk (TP) - central topic is vendor oversight.

Specificity: Let me scan for facts.
- "vendor management program" - generic program name, not firm-specific
- "Fidelity" - this is a named entity but it's the company/sponsor itself, not an external third party

- "cybersecurity controls" - standard ERM terminology, but the phrase itself is generic without firm-specific details
- "periodic reviews" - generic language
- "risks from cybersecurity threats" - generic phrasing

The paragraph describes vendor oversight processes using standard business language, but I'm not finding domain-specific terminology that would pass the ERM test or any firm-specific facts beyond the company name itself.

This rates as Level 1.


reasoning: The paragraph describes the Audit Committee's oversight role regarding cybersecurity risks, reviewing policies and procedures, and management reporting to the board — all answering 'how does the board oversee cybersecurity?' No domain terminology beyond generic risk/controls language, Audit Committee is not firm-specific, and no verifiable facts are present.


reasoning: This is a governance-chain paragraph describing how information flows upward: Global Director of IT → CEO/CFO → Audit Committee → Board. Per Rule 1, this defaults to BG because the purpose is describing the oversight structure and escalation path. For specificity, 'Global Director of IT' is a Director-level IT title without a security qualifier (not firm-specific per codebook). CEO, CFO, Audit Committee, and Board are generic governance roles present at every company. 'Weekly briefings' and 'periodic updates' are generic cadences. No cybersecurity domain terminology passes the ERM test — 'cybersecurity systems testing,' 'risks and activities,' 'mitigation strategies' are all general business language.

thinking:
Let me analyze this paragraph.

Category: This describes how information flows from management to the board. The governance chain is: Global Director of IT → CEO/CFO → Audit Committee → Board. The purpose is describing the oversight structure and how information flows upward. This is primarily answering "How does the board oversee cybersecurity?" — it's a governance-chain paragraph describing oversight flow.

Wait, let me reconsider. The paragraph starts with the Global Director of IT providing briefings to CEO/CFO, then escalation to audit committee, then future plans for audit committee updates and board reporting. The primary purpose is describing oversight structure and information flow — this is BG per Rule 1.

Now I'm checking the specificity. The titles and roles mentioned—Global Director of IT, CEO, CFO, audit committee—are all generic business positions without firm-specific qualifiers. The cadences like "weekly briefings" and "periodic updates" are standard terminology. Looking at the actual content being discussed, the language stays general: "cybersecurity risks and activities," "incidents and responses," "systems testing," "third-party activities," "risk management process." These are broad business terms rather than specialized cybersecurity domain language, so there's no domain terminology that would trigger the ERM test.

Even "cybersecurity systems testing" is too vague—it doesn't reference specific practices like penetration testing or vulnerability scanning. This is Level 1 boilerplate, the kind of generic oversight language any ERM professional would use.


reasoning: The paragraph answers 'How does the board oversee cybersecurity?' — the Audit Committee's oversight role, what it reviews, and how information flows to it via management briefings. The VP and SVP titles are mentioned as briefers to the board (governance flow), not as the primary subject. Two VP-or-above cybersecurity-relevant titles (VP Information Security and Privacy; SVP Chief Strategy and Digital Officer) are firm-specific facts elevating to Level 3, but no quantified-verifiable facts are present ('quarterly' is a generic cadence).

thinking:
Let me analyze this paragraph.

Content Category: This describes how the board (via Audit Committee) oversees cybersecurity. The primary question answered is "How does the board oversee cybersecurity?" The VP and SVP are mentioned in the context of briefing the board - this is about the oversight flow, not about management's organizational role.

→ Board Governance

Specificity: Let me scan for facts:
- "Vice President, Information Security and Privacy" — cybersecurity leadership role at VP level → firm-specific
- "Senior Vice President, Chief Strategy and Digital Officer" — SVP level, CDO overseeing cyber → firm-specific

- "quarterly" — generic cadence, not QV

No QV facts present. Since there are firm-specific facts but no QV details, this is Level 3.


reasoning: The paragraph is a governance-chain description answering 'how does the board oversee cybersecurity?' — Board delegates to Audit Committee, which reviews with management. The General Counsel mention is brief attribution of responsibility, not a detailed management role description. All entities mentioned (Board, Audit Committee, General Counsel) are generic governance structures present at every public company, and the language ('assessing, monitoring and managing cybersecurity risks') is standard ERM phrasing with no domain terminology or firm-specific facts.

thinking:
Let me analyze this paragraph.

Content: Board assigned oversight to Audit Committee. Audit Committee reviews with management. General Counsel has primary responsibility.

Category: This is a governance-chain paragraph. It starts with Board → Audit Committee oversight, then mentions General Counsel's role. The primary question answered is "How does the board oversee cybersecurity?" The General Counsel mention is brief attribution. BG.

Specificity: Let me scan for facts.
- "Board of Directors" — not firm-specific (every company has one)

- "Audit Committee" — not firm-specific (every public company has one)
- "General Counsel" — not a cybersecurity-specific role, not firm-specific
- "assessing, monitoring and managing cybersecurity risks" — generic ERM language
- "policies, practices and risks related to information security and cybersecurity" — generic

Everything here is boilerplate governance language with no domain expertise, firm-specific details, or substantive facts. This rates as Level 1.


fact: Vice President of Information Systems and Architecture (VP of IT) — VP-level title with IT/security portfolio

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' — it describes the VP of IT's responsibilities, team, qualifications, and reporting lines (to CEO, board, audit committee). Person-removal test: removing the VP of IT and reporting structure leaves only a generic list of program areas, so MR holds. Specificity is Level 3 because 'Vice President of Information Systems and Architecture' is a VP-level title with an IT/security portfolio, qualifying as firm-specific. The mention of 'holds relevant and applicable certifications' is too vague to be QV-eligible (no specific certification like CISSP is named).

thinking:
Let me analyze this paragraph.

Content category: This is primarily about management's organizational role. The VP of IT manages a team, has qualifications, reports to CEO, and provides reporting to board. The person-removal test: remove VP of IT, team, qualifications, reporting lines → "enterprise-wide strategy, policy, standards, architecture, processes, and risk assessment related to information security and data protection, including data privacy and network security (our Cybersecurity Program)" — some program description remains but it's generic. The bulk is about the person's role, qualifications, and reporting structure. → MR

Specificity:
- "Vice President of Information Systems and Architecture (VP of IT)" — VP-level title with IT portfolio → firm-specific

- The certifications claim lacks specifics, and the CEO reporting line isn't firm-specific either. The Cybersecurity Program name is generic, and terms like information security, data protection, and network security are standard industry language that don't strongly differentiate this organization. This points to Level 3 based primarily on the VP-level cybersecurity-relevant title.


reasoning: The paragraph states a backward-looking and forward-looking materiality conclusion ('have not materially affected or are reasonably likely to materially affect'), making it SI per the materiality assessment rule. The cross-reference to Item 1A is subordinate. No domain terminology, firm-specific facts, or verifiable claims — the negative assertion about absence is not externally verifiable.


fact: Named hotel manager 'Our Town' as a specific third-party entity

reasoning: The paragraph centrally addresses how third-party cyber risks are managed — the company lacks control over its hotel manager's and franchisors' information systems and relies on them to manage their own cybersecurity risk, making TP the clear category. The named entity 'Our Town' is a specific, externally identifiable third-party firm, elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

Content: Discusses reliance on third parties (hotel manager "Our Town", franchisors) for cybersecurity, lack of control over their systems, and mentions the hotel manager's cybersecurity insurance.

Category: This is about how third-party cyber risks are managed - specifically vendor/supplier cybersecurity oversight. The central topic is the relationship with external parties and their cybersecurity. → Third-Party Risk

Specificity:
- "Our Town" is a named external entity - but it's actually a named firm/partner, which would be QV-eligible
- "cybersecurity insurance" - this is a strategy/financial concept but not domain terminology per se

- "Our Town" is the hotel manager's name, a verifiable third party → qualifies at Level 4 as a named firm
- Insurance doesn't meet the domain terminology threshold for ERM purposes

So this maps to Third-Party Risk at Level 4 due to the named external entity "Our Town".


reasoning: This is a governance-chain paragraph (CFO → Audit Committee → Board Chair) where the primary purpose is describing the oversight structure and information flow, making it BG per Rule 1. Specificity is Level 1 because CFO and Audit Committee are explicitly listed as not firm-specific, 'outside consultants' are unnamed, 'at least annually' is a generic cadence, and terms like 'mitigation strategies,' 'controls,' and 'risk assessment' are general business language that fails the ERM test.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph describes both management's role (CFO responsible for cybersecurity) and board oversight (Audit Committee). The governance chain is Board → Audit Committee → CFO. Let me determine the primary question answered.

The paragraph starts with CFO's responsibility, then flows into how he reports to the Audit Committee, and then describes the Audit Committee's role. The bulk of text is about the oversight structure - how information flows from CFO to Audit Committee to Board. This is a governance-chain paragraph where the purpose is describing the oversight structure → BG.

Actually, let me re-read. The paragraph covers:

1. CFO responsible for managing cybersecurity risk (MR)
2. With outside consultants, develops strategies and implements controls (RMP-ish)
3. Annually discusses with Audit Committee (BG - reporting to board)
4. Audit Committee reviews cybersecurity risk and control tests (BG)
5. Chair may report to Board (BG)

The majority of text is about the oversight flow from CFO → Audit Committee → Board. This is a governance-chain paragraph. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure. The CFO mention is part of the chain. → **Board Governance**

Specificity: The paragraph provides clear details about the reporting cadence (annual discussions) and what gets reviewed (cybersecurity risk and control tests), so this is moderately specific.

However, looking at the facts themselves: CFO is a generic governance role, the consultants are unnamed, the Audit Committee is standard across all companies, and the language uses general business terminology rather than firm-specific or cybersecurity-specific details. This reads as generic boilerplate governance language that could apply to any company's cybersecurity oversight structure.

→ Level 1: Generic Boilerplate


reasoning: The paragraph states a materiality conclusion — 'have not materially affected or are reasonably likely to materially affect the Company, including its business strategy, results of operations or financial condition' — which is the SEC's Item 106(b)(2) assessment language, making this SI per Rule 5. The cross-reference to Item 1A is subordinate to the assessment. No domain terminology, firm-specific facts, or verifiable claims are present; the language is standard boilerplate materiality assessment wording.

thinking:
Let me analyze this paragraph.

Content: States they've experienced incidents, then makes a materiality assessment (not materially affected, not reasonably likely to), then cross-references Item 1A.

Category: The core statement is a materiality assessment - "have not materially affected or are reasonably likely to materially affect" → SI per Rule 5.

Specificity: Let me scan for facts:
- "have materially affected or are reasonably likely to materially affect the Company, including its business strategy, results of operations or financial condition" - this is boilerplate SEC language
- Cross-reference to Item 1A - N/O type content

- No domain terms, no firm-specific facts, no QV facts

This is a Level 1 disclosure.


fact: Breach Response Team (named internal team with distinguishing identifier)

reasoning: The paragraph describes program activities — tabletop exercises simulating incident responses, risk analysis, and development of detection/mitigation strategies — answering 'what does the program do?' Person-removal test confirms RMP: removing the Breach Response Team leaves a substantive description of exercises and strategies. The 'Breach Response Team' is a named internal team with a distinguishing identifier (not generic 'incident response team'), elevating to Level 3. No QV-eligible facts (no numbers, dates, named external entities, or certifications).

thinking:
Let me analyze this paragraph.

Content: Describes tabletop exercises conducted by the "Breach Response Team" to simulate incident responses, analyze risks, develop strategies, and discuss cybersecurity developments.

Category: This answers "What does the cybersecurity program do?" — describes activities (tabletop exercises, simulations). The Breach Response Team is the actor but the content is about what they DO. Person-removal test: remove "Breach Response Team" → still describes tabletop exercises and cybersecurity activities → RMP.

Specificity:
- "Breach Response Team" — named internal team with a distinguishing identifier → firm-specific (Level 3)

- "tabletop exercises" — even with the cybersecurity qualifier, these are general ERM practices rather than domain-specific terminology, so this stays Level 1

. "Breach Response Team" is different though — it's a named internal team with a specific identifier, not just a generic incident response function, which makes it Level 3. There are no QV facts here, so my final assessment is Level 3.


reasoning: The paragraph primarily answers 'how does the board oversee cybersecurity?' by describing Board and Audit Committee oversight responsibilities, making it BG. All language is generic — 'Board of Directors,' 'Audit Committee,' 'risk identification, mitigation strategy,' 'industry standards,' 'dedicated resources' — none passes the ERM test as domain terminology, none is firm-specific, and there are no verifiable facts.

thinking:
Let me classify this paragraph.

Content Category: This answers "How does the board oversee cybersecurity?" - Board and committee oversight structure. BG.

Specificity: Let me scan for facts.
- "Board of Directors" - generic, every company has one
- "Audit Committee" - generic, every company has one
- "cyber risk management program" - generic
- "risk identification, mitigation strategy and efforts, and resources" - generic
- "reviewing the Company's financial reporting of cybersecurity risks and incidents in accordance with SEC rules" - generic
- "invest in our security infrastructure" - generic

- "industry standards for cybersecurity" - generic
- "dedicated resources" - generic

No domain terminology that passes the ERM test. No firm-specific facts. No QV facts. This is Level 1.


reasoning: The first sentence states a conclusion about whether cybersecurity risks are reasonably likely to materially affect the company — this is the SEC's Item 106(b)(2) forward-looking materiality assessment, making it SI. The second sentence is a cross-reference to Item 1A, subordinate to the assessment. No domain terminology, firm-specific facts, or verifiable claims are present — the language is standard boilerplate materiality language.


reasoning: The paragraph answers 'how is management organized to handle cybersecurity?' — it describes management's responsibility for programs, their generic qualifications (education, work experience), and how they are informed by their teams. Person-removal test: removing management references leaves only a thin mention of 'prevention, detection, mitigation and remediation,' confirming MR. No domain terminology (prevention/detection/mitigation/remediation is standard ERM language), no firm-specific facts (no named roles, titles, or committees), and no verifiable claims — Level 1.

thinking:
Let me analyze this paragraph.

Content: Describes management's responsibility for cybersecurity programs, their expertise (generic - education and experience), and how they're informed by cybersecurity teams about incident prevention/detection/mitigation/remediation.

Category: This is about management's role - responsibilities, qualifications (generic), and how they receive information. Person-removal test: remove person-specific content → "cybersecurity programs... prevention, detection, mitigation and remediation of cybersecurity incidents" remains but it's thin. The primary focus is on management's responsibility and qualifications. → MR

Specificity: Let me scan for facts:

- "relevant degrees" - generic
- "prior work experience" - generic
- "cybersecurity teams" - "dedicated cybersecurity team" is listed as NOT firm-specific
- "prevention, detection, mitigation and remediation" - generic risk management language
- No domain terms, no firm-specific facts, no QV facts

Level 1.


reasoning: The paragraph states multiple materiality conclusions: 'none of the cybersecurity attacks...have resulted in a material impact to its financial condition, results of operations, or business strategy' (backward-looking) and 'we do not believe cybersecurity threats are reasonably likely to affect us' (forward-looking), making it SI. All language is generic business/risk vocabulary with no domain terminology, firm-specific facts, or verifiable claims — purely boilerplate materiality assessment language.

thinking:
Let me classify this paragraph.

Content: This paragraph discusses whether cybersecurity has materially affected the company's business. It contains materiality assessments both backward-looking and forward-looking, plus a cross-reference to Item 1A.

Category: Strategy Integration - multiple materiality conclusions are stated: "none of the cybersecurity attacks...have resulted in a material impact to its financial condition, results of operations, or business strategy" and "we do not believe cybersecurity threats are reasonably likely to affect us, our business strategy, our results of operations, or our financial conditions."

Specificity: Let me scan for facts.

The language here is entirely generic—no domain-specific terminology, no company-specific details, no named roles or committees, and no quantitative facts. These are boilerplate materiality statements without substantive support, which puts this at Level 1 Strategy Integration.


reasoning: The first sentence states a materiality conclusion ('have not identified any cybersecurity threats that are reasonably anticipated to have a material effect on our business strategy, results of operations or financial condition'), making this SI under the materiality assessment rule. The remainder is generic forward-looking language about priorities. No domain terminology, firm-specific facts, or verifiable claims are present — all language is standard business/ERM vocabulary.

thinking:
Let me analyze this paragraph.

First sentence: "we have not identified any cybersecurity threats that are reasonably anticipated to have a material effect" — this is a materiality assessment (backward-looking/forward-looking conclusion). → SI

Second sentence: generic forward-looking statement about priorities and plans. No specific content.

Category: Strategy Integration — the first sentence states a conclusion about materiality.

Specificity: Let me scan for facts.
- "reasonably anticipated to have a material effect on our business strategy, results of operations or financial condition" — materiality assessment language, but generic
- "third-party service providers" — unnamed, not firm-specific

- No domain terminology, no firm-specific facts, no QV facts

This is just boilerplate materiality language without any substantive detail. Level 1.