reasoning: The Board and Audit Committee are the grammatical subjects throughout, performing oversight actions (provides oversight, receives reports, reviews risks, meets with CISO/CIO, hosted external expert). Management roles (CISO, CIO) are mentioned subordinately as who reports to the board. Specificity is Firm-Specific: CISO and CIO are cybersecurity-specific titles on the IS list, and 'In 2023' is a specific date, but only the date qualifies as QV-eligible (named roles do not count toward QV), so with one QV-eligible fact it stops at Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: The Board oversees cybersecurity, receives reports, reviews risks via ERM. Audit Committee meets with CISO and CIO twice a year. CISO and CIO present to Board annually. New board member onboarding. In 2023, Audit Committee hosted external expert.

Category: Board Governance - the Board and Audit Committee are the primary subjects performing oversight actions.

Specific facts:
- CISO (cybersecurity-specific role) ✓
- CIO (cybersecurity-specific role) ✓

- "In 2023" is the only QV-eligible fact here since the meeting cadences are generic, and while CISO and CIO are named firm-specific roles, they don't count toward QV. That single date reference means this doesn't meet the QV threshold.

fact: CISO

fact: CIO


content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The paragraph's primary focus is the Audit Committee's oversight role — it is described as 'central to the Board's oversight' and bearing 'primary responsibility,' making the board committee the grammatical subject for most of the paragraph. Management roles (CIO, CSIRT, SVP) are mentioned in the subordinate role of informing the committee. Specificity is Firm-Specific due to cybersecurity-specific titles (CIO) and a named team (CSIRT), but no two QV-eligible hard facts are present.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

The paragraph discusses both management roles (CIO, CSIRT, SVP, CEO) informing the Audit Committee, and then focuses on the Audit Committee's oversight role. The Audit Committee is the central subject for most of the paragraph - it's described as "central to the Board's oversight" and bearing "primary responsibility." The management roles are mentioned in the context of informing the board committee.

Category: Board Governance - The Audit Committee/Board is the primary focus. Management is mentioned in the role of informing the board.

Specificity: Let me check the facts:
- CIO - cybersecurity-specific title? The IS list includes CIO. Yes, that's firm-specific.

- CSIRT is a named team for incident response, which is specific. SVP Technology and Innovation is a particular title but doesn't clearly fall into cybersecurity-specific categories. CEO and Audit Committee are both generic terms. The Board's stated expertise in risk management, technology, and finance does represent a specific composition though.

- CIO appears on the cybersecurity-specific list as a named role. CSIRT as a team name and CIO as a role are both firm-specific identifiers rather than QV-eligible facts.

- This means the only QV-eligible fact here is the firm-specific designation based on the CIO role.

fact: CSIRT (Computer Security Incident Response Team)

fact: Senior Vice President, Technology and Innovation


content_category: Incident Disclosure

category_confidence: medium

reasoning: The paragraph is anchored by a description of an actual cybersecurity incident (April 2022 disruption and data exfiltration), followed by remediation actions taken in response. While it includes financial impact language ('significant costs,' 'lost revenues') and a forward-looking materiality statement, the incident narrative and post-incident response measures are the dominant content. Only one QV-eligible hard fact (April 2022 date) is present; remediation details (SOC enhancements, backups, tools) are generic and unnamed, so specificity stays at Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes a past cybersecurity incident (April 2022), its impact, remediation actions taken, and a forward-looking risk statement with a materiality assessment.

Content category analysis:
- Describes an actual incident (April 2022, disrupted hospital operations, exfiltration of data) → Incident Disclosure
- Describes costs and business impact → Strategy Integration
- Describes remediation changes → could be Risk Management Process or Incident Disclosure (post-incident response)
- Materiality language at the end → Strategy Integration
- Cross-reference to Risk Factors → None/Other element

The paragraph starts with the incident, then discusses financial impact (costs, lost revenues), then remediation, then ongoing risk/materiality. This is a mixed paragraph.

The core message here is that we experienced an incident with significant financial consequences and implemented fixes, though risks remain. The incident itself frames the discussion, but the real substance is about what it cost us and how we responded. Given that the paragraph weaves together the incident narrative with business impact and remediation, I'd classify this as primarily Incident Disclosure with strong Strategy Integration elements—the financial and operational consequences are too prominent to ignore. I'm working through the classification criteria more carefully. The tiebreaker language is key here—it distinguishes between a paragraph that describes what happened in an incident with response details versus one that briefly mentions an incident mainly to support a materiality conclusion. This paragraph goes beyond a brief mention: it lays out the incident, the financial consequences, the remediation steps taken, and then the ongoing risk. Since the incident description and response actions are substantial rather than incidental, I'm leaning toward Incident Disclosure as the primary category.

For specificity, I'm finding only one QV-eligible fact: the April 2022 date. That's not enough to qualify as QV, but it does make this Firm-Specific since it references a particular timeframe tied to this company's operations.

fact: April 2022


content_category: Management Role

reasoning: The paragraph is about the person filling the cybersecurity leadership role — their title, certification (CISA), and career background. This passes the person-vs-function test as Management Role. Two QV-eligible hard facts: named certification (Certified Information Systems Auditor) and specific years of experience (over 30 years).

thinking:
Classify this paragraph.

The paragraph describes the VP Technology and CISO role, their certifications (CISA), years of experience (30+), and background. This is about the person, not the function.

Content category: Management Role

Specific facts:
- VP Technology and CISO (cybersecurity-specific title)
- Certified Information Systems Auditor (named certification)
- Over 30 years of experience (specific number)

QV check: Named certification (CISA) + specific years of experience (30+) = 2 hard verifiable facts → Quantified-Verifiable

fact: VP Technology and CISO

fact: Certified Information Systems Auditor

fact: over 30 years of industry experience

type: quantified


content_category: Strategy Integration

reasoning: The paragraph's primary purpose is a materiality assessment ('not experienced a cybersecurity incident that resulted in a material effect on our business strategy, results of operations, or financial condition'). The 2020 incident is referenced briefly to support the materiality conclusion ('without material impact'), not to narrate the event in detail, keeping this Strategy Integration rather than Incident Disclosure. The specific year (2020) for the past incident is one firm-specific fact, reaching Firm-Specific but not QV (only one hard verifiable fact).

thinking:
Let me analyze this paragraph.

Content: Materiality assessment ("not experienced a cybersecurity incident that resulted in a material effect"), references a past 2020 incident, cross-reference to Risk Factors.

Category: The primary purpose is a materiality assessment - Strategy Integration per Rule 6. It also mentions a past incident (2020 malware) but briefly, and the main point is that it didn't have material impact.

Specificity: Let me check for facts:
- "2020" - specific date (year)
- "systems intrusion" with "malware" - standard incident language

- Cross-reference to Risk Factors is contextual, not a fact itself

For QV-eligibility, I've got one concrete fact with "In 2020" as the specific date, which makes this Firm-Specific.

fact: 2020 publicly announced systems intrusion with malware


content_category: Risk Management Process

reasoning: The paragraph describes the company's cybersecurity risk management program, its ERM integration, and its purpose (security, confidentiality, integrity, availability). The CIO and CISO are mentioned as attribution for who oversees the program; removing those titles, the paragraph still describes a process. Per the person-vs-function test, this is about the function, not the people. The CIO and CISO titles are cybersecurity-specific roles on the IS list, elevating specificity to Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) are present.

thinking:
Classify this paragraph.

Content: Describes the company's cybersecurity risk management program - ERM integration, program purpose. Mentions CIO and CISO but as attribution for who oversees the program. The paragraph is about the function/program, not the people.

Person-vs-function test: Remove "overseen by the CIO and CISO" → paragraph still describes the program. → Risk Management Process.

Specificity: CIO and CISO are cybersecurity-specific titles on the IS list. That gives Firm-Specific. Any QV facts? No specific dates, dollar amounts, headcounts, named firms, named tools.

The roles mentioned don't contribute to quantitative value, so this stays Firm-Specific.

fact: Chief Information Officer (CIO)

fact: Chief Information Security Officer (CISO)


specificity_confidence: medium

reasoning: The paragraph describes the company's participation in an external benchmarking group (Data Privacy Board) as part of its approach to managing privacy/cyber risk, making it a Risk Management Process activity. The named external organization 'Data Privacy Board' is a firm-specific fact identifying a unique aspect of this company's program, but there are no second hard verifiable facts to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph from Valmont Industries' 10-K Item 1C filing.

The paragraph discusses membership in the "Data Privacy Board" - an external group for benchmarking and peer discussions about privacy. It's about building "privacy resilience" across international operations.

This is about data privacy benchmarking through an external membership, not really about cybersecurity processes, governance, or any of the core categories. It's tangential - privacy-adjacent but not cybersecurity disclosure content per se.

Actually, let me reconsider. This could be Risk Management Process - it describes a component of their risk management approach (benchmarking via industry group membership).

I'm torn on this one. The Data Privacy Board membership is an external benchmarking activity that fits loosely into their risk management approach, but it's fundamentally about data privacy rather than cybersecurity. The description is fairly vague - "building privacy resilience" doesn't give much concrete detail about what they're actually doing or learning from the group.

That said, the Data Privacy Board itself appears to be a named external organization, which makes this firm-specific rather than generic. I'll categorize it as Risk Management Process since it describes a concrete activity the company participates in, and flag the Data Privacy Board as a specific named entity.

fact: Membership in the Data Privacy Board (external benchmarking organization)


reasoning: The paragraph describes a management-level committee (ERC) and its composition — CRO, CIO as members, interim CISO as a regular briefer — along with its delegated authority from the BRC. The primary actors are management roles and a management committee, making this about management structure and reporting lines rather than board governance or process description. Multiple IS-list facts (CISO, CIO, named non-generic committees ERC and BRC) support Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named firms, tools) reach the two-fact threshold.

thinking:
Let me analyze this paragraph.

Content: Describes the ERC (Enterprise Risk Committee), a cross-functional executive forum. Mentions CRO, CIO as members, and interim CISO providing updates at every meeting.

Category: The paragraph describes a management committee (ERC) and its composition/function. The primary actors are management-level (CRO, CIO, interim CISO). It's about the management structure for cybersecurity oversight. The ERC is a management committee, not a board committee. The BRC (Board Risk Committee) is mentioned but only as the source of delegated authority.

This is about management oversight structure - who sits on the committee and what they do.

I'm testing whether this fits the Management Role category by looking at the grammatical subjects and what's being described. The ERC functions as a cross-functional executive forum where the CISO reports regularly, and its composition includes key management roles like the CRO and CIO. Even if I strip away the role titles, the paragraph still conveys the ERC's operational purpose and structure, which confirms this is fundamentally about how the management committee is organized and what it does.

Now checking specificity: I've got named committees (ERC, BRC), cybersecurity-specific titles (CISO, CIO), and organizational structure details. These are all on the IS list, so this qualifies as Firm-Specific. However, there are no quantifiable facts like dates, headcounts, or dollar amounts, so it doesn't meet the QV threshold. The classification is Firm-Specific (3) based on multiple IS-list elements.

fact: ERC (Enterprise Risk Committee) — cross-functional executive forum

fact: CIO is a member of the ERC

fact: Interim CISO provides updates at every ERC meeting

fact: BRC (Board Risk Committee) delegates authority to ERC


reasoning: The paragraph is about the person filling the Enterprise Security Director role — her experience (26 years), certification (CISSP), and organizational memberships. While the first sentence mentions responsibilities, the dominant content is credentials and background, satisfying the person-vs-function test for Management Role. Two QV-eligible hard facts: specific years of experience (26 years) and a named certification (CISSP).

thinking:
Let me analyze this paragraph.

Content: About the Enterprise Security Director - her responsibilities, experience, certifications, reporting lines. This is about the person.

Person-vs-function test: The paragraph describes who the person is (26 years experience, CISSP certification, member of organizations) and what she's responsible for. The first sentence describes responsibilities, but the bulk is about qualifications. If I remove the person's credentials and background, there's less substance. The paragraph is primarily about the person.

Category: Management Role

Specific facts:
- "Enterprise Security Director" - cybersecurity-specific title → named_role

- "ERSC" and "AOC" are named committees she's involved with
- Over 26 years of experience is a quantified metric
- CISSP is a named certification

QV check: With 26 years of experience and CISSP certification, that's 2 hard verifiable facts → Quantified-Verifiable

fact: Enterprise Security Director

fact: ERSC (Enterprise Risk Steering Committee)

fact: AOC

fact: over 26 years of experience in IT/OT cybersecurity

fact: certified information system security professional (CISSP)


reasoning: The paragraph contains an explicit materiality assessment ('We have not had any material cybersecurity breaches or incidents and have not incurred any material expenses, penalties or settlement costs'), which per Rule 6 makes it Strategy Integration regardless of the surrounding generic risk language and cross-reference to Risk Factors. The ERM mention is incidental, and the risk enumeration and forward-looking disclaimer are boilerplate. No specific facts from the IS list are present — 'ERM program' is a generic program name, and all other content is standard boilerplate language.

thinking:
Let me analyze this paragraph.

Content: Mentions ERM program, lists generic cyber risks, cross-references Risk Factors, makes a materiality assessment ("have not had any material cybersecurity breaches"), and includes forward-looking disclaimer.

The paragraph contains a materiality assessment: "We have not had any material cybersecurity breaches or incidents and have not incurred any material expenses, penalties or settlement costs related to any cybersecurity breaches or incidents." Per Rule 6, this is Strategy Integration.

But there's also risk management content (ERM program mention) and a cross-reference. The materiality assessment is a significant portion.

The tiebreaker rule points to Strategy Integration for materiality disclaimers. Looking at specificity though—there's no named frameworks beyond a generic "ERM program," no specific facts from the IS list, and no named standards. The language reads as standard boilerplate, which would suggest Generic Boilerplate classification instead.


reasoning: The paragraph is primarily about the people — the Information Security Director and CIO — describing their reporting relationship, combined years of experience, tenure at the company, and familiarity with the cybersecurity landscape. While responsibilities are mentioned, the dominant content is who these people are and what qualifies them. Two quantified facts (55 combined years of experience, 31 combined years in the organization) meet the QV threshold.

thinking:
Let me analyze this paragraph.

Content: Describes the Information Security Director's role, reporting line to CIO, responsibilities, and combined experience. Also mentions CIRT and CIC.

Category: This is about the person(s) - their reporting lines, experience, tenure. The person-vs-function test: the paragraph tells us about who these people are (experience, tenure, familiarity). While it mentions responsibilities, the dominant content is about the people's qualifications and background. → Management Role

Specific facts:
- "Information Security Director" - cybersecurity-specific title → IS list ✓

- "CIO" - cybersecurity-specific title → IS list ✓
- "CIRT" (Cyber Incident Response Team) - named internal program with unique identifier → IS list ✓
- "CIC" - named internal program/role → IS list ✓
- "over 55 combined years" and "over 31 combined years" - two specific quantified figures → Quantified-Verifiable ✓

fact: Information Security Director

fact: CIO

fact: CIRT (Cyber Incident Response Team)

fact: CIC (Cyber Incident Committee)

fact: over 55 combined years of IT and program management experience

fact: over 31 combined years in the Company's corporate information security organization


reasoning: The paragraph is primarily about the CAO as a person — her tenure (24 years), prior positions (CIO), and the expertise she developed through those roles. While it briefly mentions the cybersecurity program and the Enterprise Security Director, the dominant content is the person's qualifications and background, passing the person-vs-function test for Management Role. Specificity is Firm-Specific: multiple IS-list facts (Enterprise Security Director, CIO role, 24 years) but only one QV-eligible hard fact (24 years), falling short of the two needed for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph is about the CAO's role, experience, and background. It describes who the person is, their qualifications, experience (24 years), prior positions (CIO), and expertise areas.

Person-vs-function test: The paragraph tells us about the person - their tenure (24 years), prior role (CIO), expertise developed. There's a brief mention of overseeing the program and the Enterprise Security Director, but the bulk is about the CAO's background.

Content category: Management Role

Specific facts:
- CAO (not a cybersecurity-specific title per the IS list... but wait, let me check)

- Actually, CAO = Chief Administrative Officer. This is not on the cybersecurity-specific titles list (CISO, CTO, CIO, VP of IT/Security, etc.)
- Enterprise Security Director - this could be considered a cybersecurity-specific title
- 24 years of experience - specific number
- Chief Information Officer (CIO) - cybersecurity-specific title on the IS list

Now I'm checking what qualifies for QV eligibility. The 24 years of experience is a quantified fact, so that's eligible. The CIO and Enterprise Security Director are named roles from the IS list, but they're not QV-eligible themselves. The only QV-eligible fact here is that specific number.

With just one QV-eligible fact and multiple IS facts, this falls into the Firm-Specific category.

fact: CIO (Chief Information Officer) - prior role

fact: 24 years of experience


reasoning: The paragraph's primary content is about the cybersecurity team's organizational structure, reporting lines (directors report to CISO), and team qualifications (multiple named certifications), making it about the people rather than the processes they execute. While it briefly mentions what the Cyber Security Office is responsible for, the dominant communicative purpose is describing who comprises the team and what credentials they hold. Multiple named certifications (CISSP, CISM, CRISC, CEH) provide two or more QV-eligible hard verifiable facts, reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the internal cybersecurity team structure - led by CISO, information security directors, certifications held by team members, and engagement of third parties.

Category: This is about the team structure and their certifications. The person-vs-function test: The paragraph describes the organizational structure (CISO leads, directors report to CISO, teams support directors) and team certifications. It's a mix - it describes who the team is (certifications) but also what they do (implementation, monitoring, maintenance). The primary subject is "The Company's Cyber Security Office" and the team structure.

The CISO anchors the organizational hierarchy, but the real focus is on how the office is structured and what qualifications the team members hold. The certifications and reporting lines matter more than any individual's background, so this leans toward describing the function and structure rather than a person. The certifications are listed as team-held credentials rather than tied to specific individuals, but they're still named and verifiable facts—CISSP, CISM, CRISC, and CEH all appear on the QV-eligible list. That gives me multiple quantified-verifiable facts to work with here.

So this content qualifies as both a Management Role and Quantified-Verifiable.

fact: CISO leads the Cyber Security Office

fact: CISSP certification held by team

fact: CISM certification held by team

fact: CRISC (Certified in Risk and Information Systems Control) certification

fact: CEH (Certified Ethical Hacker) certification


reasoning: The heading says 'Management's Role' but the person-vs-function test resolves this: removing the CIO attribution, the paragraph still describes the organizational placement of cybersecurity risk management within the Information Security Office and the implementation of an incident response plan. No credentials, background, or qualifications are provided for the CIO — the paragraph is about the function and structure, not the person. The CIO title (a cybersecurity-specific role on the IS list) provides one firm-specific fact, but no QV-eligible hard facts reach the two-fact threshold.

thinking:
Let me analyze this paragraph.

The paragraph mentions management's role but then describes the organizational structure and a program. Let me apply the person-vs-function test.

"Management's Role Managing Risk" - header-like opening
"cybersecurity risk management is part of the Company's Information Security Office, led by the Chief Information Officer" - organizational structure with CIO attribution
"Company has implemented an Information Security Incident Response Plan" - process description

The person-vs-function test: Remove the CIO title, and the paragraph still describes the Information Security Office and the incident response plan. The paragraph is about the function/structure, not the person's credentials or background.

The heading frames this as management's role, and the CIO is identified as the leader, but stripping away that attribution doesn't break the core message—it's fundamentally describing where cybersecurity risk management lives organizationally and what processes they've put in place. This is structure and function, not a person's background or qualifications.

The CIO itself is a firm-specific fact since it's on the cybersecurity titles list, so that pushes the category to at least Firm-Specific. The Information Security Office is an organizational unit, and the incident response plan is generic enough that it doesn't add specificity. So I'm looking at a mixed paragraph where the dominant content is Risk Management Process, but the CIO reference gives it a Firm-Specific layer. I need the next thinking to rewrite. You've provided the current rewritten thinking and the guidelines, but I don't see the "next thinking" content that I should be rewriting.

Could you please share the next thinking chunk that needs to be rewritten?

fact: Chief Information Officer leads the Information Security Office


reasoning: The paragraph describes internal cybersecurity processes: security measures, user access controls, periodic security reviews, disaster recovery plans, and use of third-party consultants for breach response. Third-party consultants are mentioned as one component of the internal process, not as a central vendor oversight topic. No named frameworks, cybersecurity-specific roles, named firms, tools, dates, or other facts from the IS list appear — all references ("third party cybersecurity consultants," "disaster recovery plans," "annual basis") fall on the NOT list.

thinking:
Let me analyze this paragraph from Hawaiian Electric Industries' 10-K filing.

The paragraph describes the SLA (Service Level Agreement) between Hawaiian Electric and HEI, covering IT infrastructure support, security measures for unsupported applications, third-party consultants for breaches, and disaster recovery plans.

Content Category: This is about internal cybersecurity processes - security measures, internal controls, user access reviews, disaster recovery plans, and how they handle unsupported applications. It's describing the company's own risk management processes. Third-party is mentioned ("third party cybersecurity consultants") but as one component. → Risk Management Process

Looking at the specificity here, I'm not finding any named frameworks, tools, or dates—just generic descriptions like "disaster recovery plans" and "annual basis" without concrete details. The third-party consultants aren't named, and everything reads as standard boilerplate language for internal processes. → Generic Boilerplate


reasoning: The paragraph primarily describes the company's internal incident response strategies and processes (CIRT activities, forensic data collection, system restoration), with third-party provider oversight as a secondary component rather than the central topic. Applying Rule 3, vendors are mentioned as one component of the internal program. Specificity is Firm-Specific: CIO is a cybersecurity-specific title (IS list) and CONA is a named third-party firm, but only CONA is QV-eligible, falling short of the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content: Describes CIRT incident response strategies, mentions DHS ICS-CERT practices, engaging external experts, CIO meeting with third-party service providers, mentions CONA.

Category analysis:
- Describes incident response strategies (Risk Management Process)
- Mentions third-party oversight by CIO (Third-Party Risk component)
- The dominant content is about internal IR processes and strategies, with third-party oversight as one component

The paragraph starts with CIRT incident response strategies, then mentions DHS ICS-CERT recommended practices, then external experts, then CIO assessing third-party providers. The bulk is about internal processes.

Third-party is a component but not the central topic, so this falls under Risk Management Process. Looking at the specificity: CIRT is a common acronym for Cyber Incident Response Team, while DHS ICS-CERT is a named external standard. The CIO is a cybersecurity-specific role that counts as a firm-specific fact, and CONA appears to be a named third-party firm.

Counting the QV-eligible facts, I only have CONA as a named firm that qualifies, which means this should be classified as Firm-Specific rather than something broader.

fact: CIRT (Cyber Incident Response Team) developed incident response strategies

fact: Chief Information Officer (CIO) periodically meets with third-party service providers

fact: CONA identified as largest external service provider


reasoning: This lengthy paragraph primarily describes VF Corp's cybersecurity program — systems for detection/response, third-party risk processes, training programs, incident response plan, insurance, and use of external service providers. While CISO and COO credentials occupy several sentences, removing those details leaves a complete process description; the paragraph is about the function, not the person. Two QV-eligible facts: CISO's 'over thirty years of experience' and COO's 'nearly twenty years of experience' as specific durations.

thinking:
Let me analyze this paragraph from VF Corp's 10-K filing, Item 1C.

This is a long, multi-topic paragraph covering:
1. Data protection priorities
2. Systems for detecting/responding to incidents
3. Third-party risk management (briefly)
4. Training program
5. Program overseen by CISO and COO
6. CISO credentials (30+ years, CISO of two large retailers, reports to COO)
7. COO credentials (nearly 20 years digital transformation)
8. Team expertise
9. Third-party service providers

10. Cyber insurance

This paragraph spans multiple categories. Let me determine the dominant one.

The paragraph covers Risk Management Process (systems, training, incident response plan), Management Role (CISO credentials, COO credentials, reporting lines), Third-Party Risk (briefly), and Strategy Integration (insurance mention).

The dominant content is Risk Management Process - it describes the company's internal processes, training, systems, and program. The CISO/COO credentials are a significant portion but subordinate to the overall process description. Applying the person-vs-function test: if you removed the CISO/COO titles and credentials, the paragraph still describes a comprehensive cybersecurity program. The paragraph is primarily about what the program does, not who's running it.

Now I'm evaluating the specificity. The CISO role is cybersecurity-specific so it qualifies for the IS list, but the experience numbers are what matter for QV eligibility. Both leaders have specific tenure figures - over thirty years for the CISO and nearly twenty for the COO - which are QV-eligible. The CISO's prior experience at two large retailers adds context but lacks named firms. Cyber insurance gets a mention without any concrete details. The COO's nearly twenty years still counts as a quantified fact even though the role itself is generic—the specific duration is what matters for the QV criteria. So I have two clear quantified-verifiable facts: over thirty years for the CISO and nearly twenty years for the COO, which makes this Quantified-Verifiable overall.

fact: CISO oversees the program

fact: CISO has over thirty years of experience as a cybersecurity professional

fact: CISO previously served as CISO of two large retailers

fact: COO has nearly twenty years of experience enabling digital transformation

fact: CISO reports to COO


reasoning: The paragraph's primary content is a narrative of an actual cybersecurity incident — ransomware in May 2022, detection, response actions (forensic experts, law enforcement), restoration, and remediation steps (MFA, training). While materiality conclusions are present, they are subordinate assessments of the described incident rather than the paragraph's primary communicative purpose. Only one QV-eligible hard fact (specific date 'May 2022'); third-party forensic experts and law enforcement are unnamed and on the NOT list, so specificity is Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes a past cybersecurity incident (ransomware in May 2022), response actions, materiality assessment, and remediation steps.

Content category: This is a mixed paragraph. It describes an actual incident (May 2022 ransomware), response actions, materiality assessment, and remediation. The incident narrative is substantial, but the materiality assessments are also prominent. Let me apply the tiebreaker rules.

The paragraph DESCRIBES what happened: ransomware attack, network disruption, detection, response (forensic experts, law enforcement), restoration. Then it transitions to materiality ("did not materially affect") and remediation actions, and a broader materiality disclaimer.

The core of this is the incident narrative itself—what occurred, when it happened, and how they responded. The materiality conclusions are secondary to that story. So this falls under Incident Disclosure. Looking at specificity, I've got "May 2022" as a concrete date that's QV-eligible, but the other details like the forensic experts and law enforcement involvement are standard incident response language without additional verifiable facts beyond the month and year.


reasoning: The paragraph is entirely about the people on the management team — their roles, career histories, experience duration, and education. This is clearly about the persons, not the function. Two QV-eligible hard facts: '40 year career' and 'over twenty years of experience' are specific quantified durations.

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

The paragraph describes management team members and their qualifications/backgrounds. It's about the people - their roles, experience, career history, education.

Content Category: Management Role - the paragraph is about who these people are, their qualifications, experience, and backgrounds.

Specific facts:
- VP and General Manager of High Performance Products segment (named role)
- Chief Technical Officer (CTO - cybersecurity-specific title)
- 40 year career (specific number)
- Bachelor of Science in Business and Engineering, Masters of Science in Finance (degrees but no named university)

- VP of Managed Services at Technology Solutions segment (named role)
- Over twenty years of technology experience (specific number)

Looking at the quantified-verifiable content: I've got two specific numbers here - the 40 year career and the over twenty years of experience. Both are hard facts that could be verified, so this qualifies as Quantified-Verifiable.

fact: Vice President and General Manager of the High Performance Products segment

fact: Chief Technical Officer (CTO)

fact: 40 year career

fact: over twenty years of technology experience

fact: Vice President of Managed Services at the Technology Solutions segment


reasoning: The paragraph describes the company's internal incident identification, severity assessment, response, and escalation processes. The VP of Tech is mentioned repeatedly but as attribution for process activities — applying the person-vs-function test, removing the title leaves a coherent process description, so this is Risk Management Process rather than Management Role. The specific team composition (IT specialists, accountants, lawyers) and the cybersecurity-specific VP of Tech title are firm-specific facts, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph.

Content: Describes how third-party advisors monitor threats, the VP of Tech's role in incident response, cross-functional team involvement, reporting chain to executive leadership and Audit Committee, and Board notification for material incidents.

Category: This is about the incident response process and how threats flow through the organization. The VP of Tech is mentioned repeatedly but as attribution for process activities. The person-vs-function test: remove "VP of Tech" and replace with "the Company" — the paragraph still describes processes (monitoring, severity assessment, response, reporting). This is Risk Management Process.

Wait - there's also a third-party element (third-party advisors for monitoring and forensics), but that's a component of the internal process, not the central topic.

And the board and audit committee reporting are really just the top of the escalation chain, not the main focus.

Now I'm checking specificity. "VP of Tech" looks like a firm-specific cybersecurity leadership role similar to "VP of IT/Security" on the list, so that counts. The team composition is concrete — information technology specialists, accountants, and lawyers. But "Audit Committee," "third-party advisors," and "Board of Directors" are all too generic to mark as specific. So I've got one specific element here, which isn't enough.

For the QV check, the VP of Tech is a named role but that alone doesn't qualify. The team composition isn't verifiable in the way QV requires — no dates, dollar amounts, named firms, or specific tools mentioned. This doesn't meet the QV threshold.

That puts this at Firm-Specific (3) for specificity.

fact: VP of Tech


reasoning: The paragraph's primary communicative purpose is how the Board and its committees oversee cybersecurity risk — the Board is the dominant subject throughout, with management and the CISO mentioned in the context of reporting upward to board-level committees. The Governance and Compliance Committee and Technology Committee are named non-generic committees unique to this company's governance structure, establishing Firm-Specific specificity; however, no two QV-eligible hard facts (dates, dollar amounts, headcounts, named third-party firms, named tools) are present to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics: ERM integration, board oversight, management responsibility, annual risk assessment, committee oversight, and CISO reporting.

**Content Category Analysis:**
- Board oversight of risk management → Board Governance
- Management team responsible for day-to-day risk → could be Management Role
- CISO reports to Governance and Compliance Committee → Board Governance (reporting TO the board)
- Technology Committee reviews → Board Governance

The primary frame is about how the board and its committees oversee cybersecurity risk. The board is the dominant subject throughout. The CISO is mentioned in the context of reporting to a committee (board governance framing).

Management is mentioned as reporting to committees, which reinforces the Board Governance categorization.

Looking at the specificity, I can identify firm-specific facts: the CISO as a named role, the Governance and Compliance Committee as a named committee, and the Technology Committee as another named committee. However, there aren't any quantifiable facts like dates, dollar amounts, headcounts, or named third-party vendors that would qualify for QV eligibility.

So this falls under Firm-Specific with three identified facts.

fact: CISO reports on threat landscape and security programs

fact: Governance and Compliance Committee oversees compliance programs and data privacy/cybersecurity policies

fact: Technology Committee reviews product-related cybersecurity aspects


reasoning: The paragraph describes the company's internal cybersecurity strategy and processes for identifying, assessing, and managing cyber risks, squarely fitting Risk Management Process. It names NIST CSF as the guiding framework but provides no firm-specific facts beyond that — the 'multi-layered defensive strategy' language and the NIST CSF functions (identify, protect, detect, respond, recover) are standard descriptions, placing this at Sector-Adapted.

thinking:
Let me analyze this paragraph from Norfolk Southern Corp's 10-K filing.

The paragraph describes the company's cybersecurity strategy based on NIST CSF. It's about internal processes and framework adoption.

Content category: Risk Management Process - describes framework adoption and internal cybersecurity strategy.

Specificity: Names NIST CSF framework. But does it contain firm-specific facts? It says "multi-layered defensive cybersecurity strategy" - generic. The NIST CSF reference is a named standard → Sector-Adapted. No firm-specific facts beyond that.

The text appears to cut off mid-sentence with "includes the following: Identify," which suggests there's more detail coming, but based on what's provided, this is clearly Sector-Adapted (2) — it references an industry standard framework without any company-specific implementation details, roles, dates, or tools.

fact: NIST Cybersecurity Framework (NIST CSF)

type: framework


reasoning: The paragraph describes the company's Information Security Program, policies, standards, and controls designed to meet regulatory requirements — these are internal processes. While it mentions regulatory agencies and board/management responsibilities, the primary content is about the company's own compliance program. Named regulations (GLBA, SOX, FFIEC) trigger Sector-Adapted, but no firm-specific facts (no cybersecurity-specific titles, no specific dates, no named tools or firms) elevate it beyond that level.

thinking:
Let me analyze this paragraph.

Content: Discusses regulatory compliance requirements for a financial institution, mentions specific regulations (GLBA, SOX, FFIEC). Describes regulatory expectations for board and management, and the company's Information Security Program designed to meet these requirements.

Category: This is about the company's own internal processes (Information Security Program, policies, standards, controls) designed to meet regulatory requirements. It describes what the company does - implements controls, has policies and standards, gets examined annually. This is Risk Management Process.

Specificity: Let me check for specific facts:
- GLBA, SOX, FFIEC - these are named standards/frameworks → Sector-Adapted at minimum

- The program name, examination cadence, and governance structure are all generic without firm-specific details, named committees, or concrete dates
- No cybersecurity-specific titles, tools, or metrics mentioned

The named regulations push this to Sector-Adapted, but there's nothing unique to this particular firm, so the classification is Risk Management Process, Sector-Adapted.

fact: Gramm-Leach-Bliley Act (GLBA)

fact: Sarbanes-Oxley Act (SOX) of 2002

fact: Federal Financial Institutions Examination Council (FFIEC)


reasoning: The paragraph describes the company's internal incident response process — how threats are identified, assessed for severity, escalated, and remediated. Although 'Sr Director of Tech' appears repeatedly, the person-vs-function test shows this is about the process flow, not the person's qualifications or background. The specific departmental composition ('information technology specialists, accountants, and lawyers') is a firm-specific fact, but no QV-eligible hard facts (dates, dollar amounts, named third-party firms, named tools) are present — 'third-party advisors' is unnamed and generic.

thinking:
Let me analyze this paragraph.

Content: Describes incident response process involving third-party advisors, Sr Director of Tech, cross-functional team, reporting chain to executive leadership, Audit Committee, and Board.

Category: This is primarily about the incident response process - how threats are identified, assessed, escalated, and managed. The Sr Director of Tech is mentioned repeatedly but as attribution for process steps, not for their personal qualifications/background. Applying the person-vs-function test: remove the title and the paragraph still describes a complete process. → Risk Management Process

But wait - there's also a strong third-party component and reporting/escalation chain.

The core focus is really on how incidents flow through the organization internally, with third-party advisors functioning as part of that system rather than being the main subject. That points to Risk Management Process. Now I'm checking whether "Sr Director of Tech" qualifies as cybersecurity-specific. It's a general technology leadership title, similar to "Director of IT" or "Head of IT," which aren't listed as cybersecurity-specific roles.

The team composition detail—information technology specialists, accountants, and lawyers—is specific enough to count as a firm-specific fact. The Audit Committee and Board of Directors are generic governance structures, so they don't add specificity. So the team composition is what makes this Firm-Specific, while the director title and governance bodies are too generic to push it into that category on their own.

Now checking if this meets the QV threshold: I need at least two hard verifiable facts like specific dates, dollar amounts, named firms, or certifications. The team composition alone doesn't qualify as verifiable in that sense, so this doesn't reach QV status.

This falls under Risk Management Process and Firm-Specific.

fact: Sr Director of Tech identified as cybersecurity incident lead

fact: Cross-functional team comprising information technology specialists, accountants, and lawyers


reasoning: The paragraph's primary subject is the VP of IT/Information Security Officer — their qualifications (24 years experience, 2-year tenure), reporting lines (to CFO, to audit committee), and the management committee they sit on. While responsibilities are listed, they are framed as what this person does, not as standalone process descriptions. Two hard verifiable facts (2 years in role + 24 years experience) reach the QV threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the VP of IT/Information Security Officer role, their responsibilities, qualifications, reporting lines, and team composition. Let me apply the person-vs-function test.

Content: The paragraph covers:
1. VP of IT role identification and responsibilities
2. Reporting line (to CFO, to audit committee)
3. IT Executive Steering Committee composition
4. VP of IT's tenure and experience (2 years in role, 24+ years experience)
5. Information security team description
6. VP of IT's broader responsibilities

This is a mixed paragraph. It describes both the person (credentials, tenure) AND functions (budgets, incident preparedness, processes).

The core focus here is the management structure itself—who holds the VP role, their background and qualifications, who they report to, and how the oversight committee is organized. While the paragraph mentions various responsibilities like budget approval and incident preparedness, these are framed as duties of the person rather than detailed program descriptions. This points to a Management Role classification.

Looking at the specific details: the VP title is cybersecurity-focused, the IT Executive Steering Committee is a named body rather than generic, and I've identified two concrete, quantifiable facts—two years in the current role and more than 24 years of relevant experience—that would qualify for QV eligibility. The committee membership includes some generic titles like VP of Operations and General Counsel, but the cybersecurity-specific role and named committee strengthen the case for this being primarily about management structure.

fact: VP of Information Technology and Information Security Officer

fact: IT Executive Steering Committee comprised of VP of IT, CFO, General Counsel, CTO and VP of Operations

fact: CTO

fact: Two years in current role

fact: More than 24 years of relevant experience


reasoning: The entire paragraph describes the qualifications, credentials, education, career history, and tenure of the CISO and CIO — it is squarely about the persons, not the function. Multiple QV-eligible hard facts: named universities (Oakland University, University of Illinois), named prior employer (Comerica Bank), named certifications (CISSP, CRISC, CCISO), and a specific date (early 2023).

thinking:
Classify this paragraph.

Content: About CISO and CIO - their qualifications, degrees, certifications, prior roles. This is clearly about the persons, not the function. → Management Role.

Specificity: Let me count QV-eligible hard facts:
- Named university: Oakland University (credential context) ✓
- Named university: University of Illinois (credential context) ✓
- CISSP certification ✓
- CRISC certification ✓
- CCISO certification ✓

- Specific timeframe: early 2023 ✓
- Named employer: Comerica Bank ✓

That's well over two concrete, verifiable facts across certifications, institutions, and employment history. → Quantified-Verifiable.

fact: CIO has bachelor's in MIS and MBA from Oakland University

fact: CIO was previously Domain CIO at Comerica Bank

fact: CISO has bachelor's in Computer Science from University of Illinois

fact: CISSP certification

fact: Certified in Risk and Information Systems Control (CRISC) certification

fact: Certified Chief Information Security Officer (CCISO) certification

fact: CISO serving in role since early 2023

fact: CISO title

fact: CIO title


reasoning: The paragraph describes the company's incident response plan, team composition, and tabletop exercises — all internal cybersecurity processes. The SDIS and DPO are mentioned as attribution for who leads the team, but the substantive content is about the plan and exercises (person-vs-function test → function). SDIS and DPO are cybersecurity/privacy-specific roles unique to this company's structure, qualifying as firm-specific facts, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) are present.

thinking:
Classify this paragraph.

Content: Describes the company's incident response plan, incident response team composition, and tabletop exercises. The SDIS and DPO are mentioned as leaders but the paragraph is about the process/plan, not about the people's credentials.

Category: Risk Management Process - describes IR plan, IR team, tabletop exercises. Person-vs-function test: remove the role titles and it still describes processes.

Specificity:
- "SDIS" - this is a cybersecurity-specific role title (Senior Director of Information Security or similar) - actually, SDIS likely stands for "Senior Director of Information Security" which would be a cybersecurity-specific title → Firm-Specific

- "DPO" - Data Protection Officer - this is a specific role but is it on the IS list? It's not explicitly listed but it's a cybersecurity/privacy-specific title. I'll count it as a specific fact.
- "periodic table-top exercises" - generic practice + generic cadence
- "incident response plan" - generic program name

Now I'm checking whether SDIS and DPO actually appear on the IS list. SDIS is unusual and could be a Norfolk Southern-specific abbreviation, while DPO is the standard Data Protection Officer title. Both are cybersecurity-specific roles that go beyond generic C-suite positions, so they qualify as firm-specific facts even though they're not explicitly on the IS list.

For the QV check, SDIS and DPO are named roles rather than hard verifiable facts like dates, dollar amounts, or named firms, so they don't meet the QV threshold. Based on these cybersecurity-specific titles, this falls into the Firm-Specific category.

fact: SDIS (Senior Director of Information Security or equivalent) leads incident response team

fact: DPO (Data Protection Officer) co-leads incident response team


reasoning: The entire paragraph is about the CISO as a person — tenure, experience, education, and certifications. This is squarely Management Role per the person-vs-function test. Multiple QV-eligible hard facts: specific join year (2012), specific experience duration (two decades), and four named certifications (CISM, CISA, CDPSE, CCNA) — well exceeding the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: About the CISO - their reporting line, tenure, experience, education, certifications. This is clearly about the person.

Category: Management Role - the paragraph is about the CISO as a person: credentials, experience, education, certifications, tenure, reporting line.

Specificity: Let me count QV-eligible facts:
- CISO (named role → IS list, but not QV-eligible)
- Chief Risk Officer (reporting line - this is a cybersecurity-adjacent role... actually CRO is not on the IS list for cybersecurity-specific titles)

- Joined in 2012 (specific date → QV-eligible)
- "over two decades of experience" (years of experience → QV-eligible)
- MBA in Cybersecurity (degree but no named university → not QV)
- CISM, CISA, CDPSE, CCNA certifications (all named certifications → QV-eligible)

So I'm looking at multiple QV-eligible facts here: the 2012 join date, the decades of experience, and four distinct professional certifications, which easily clears the threshold.

fact: CISO role

fact: Reports to Chief Risk Officer

fact: Joined the Company in 2012

fact: Over two decades of experience

fact: Certified Information Security Manager (CISM)

fact: Certified Information Systems Auditor (CISA)

fact: Certified Data Privacy Solutions Engineer (CDPSE)

fact: Cisco Certified Network Associate (CCNA)


reasoning: The paragraph's primary communicative purpose is describing how cybersecurity fits into the broader enterprise risk management program (ERM integration). The CISO is mentioned as brief attribution for who is responsible, and the reporting line to the IT/Cybersecurity Committee is subordinate context. Applying the person-vs-function test: removing the CISO title and committee name, the paragraph still describes the risk management program structure. Two firm-specific facts (CISO role, named non-generic IT/Cybersecurity Committee) but neither is QV-eligible (no dates, dollar amounts, headcounts, named third-party firms, or named tools), so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes ERM program, mentions cybersecurity as a component, names CISO role, mentions IT/Cybersecurity Committee, and reporting structure.

Category: This is a mixed paragraph. It starts with ERM/risk management, then positions cybersecurity within it, then mentions the CISO and their reporting to a named committee. The primary purpose seems to be introducing the risk management program and how cybersecurity fits in, with the CISO mentioned as attribution and the committee as the reporting destination. The paragraph is setting the stage for the cybersecurity program description.

The dominant content: It's about the risk management program structure and where cybersecurity sits within it.

The CISO is responsible for this area and reports to the IT/Cybersecurity Committee, which creates a clear governance structure. Even though the CISO is named, the paragraph's real focus is on how cybersecurity integrates into the broader ERM framework and the organizational hierarchy that supports it.

For specificity, both the CISO title and the IT/Cybersecurity Committee are firm-specific details—they're named roles and committees rather than generic functions—so this lands in the Firm-Specific category.

fact: Chief Information Security Officer (CISO)

fact: Information Technology/Cybersecurity Committee (IT/Cybersecurity Committee)


reasoning: The paragraph frames the full governance hierarchy with the Board of Directors and Board Risk Committee as the primary subjects overseeing cybersecurity risk, with management roles described as subordinate operational actors and reporting flowing back to the board — fitting Board Governance as the dominant frame. Multiple firm-specific facts (named non-generic committees, cybersecurity-specific titles) place this at Firm-Specific, but no QV-eligible hard facts (dates, dollars, headcounts, named firms/tools) reach the two-fact threshold.

thinking:
Let me analyze this paragraph.

Content: Board of Directors and Board Risk Committee oversee cybersecurity risk. Executive Committee, CLO, CTO, and Information Security Manager manage it operationally. Regular updates provided to Management Risk Committee, Board Risk Committee, and Board.

Category: This spans Board Governance and Management Role. The paragraph starts with Board oversight, then discusses management, then reporting. The board is the opening subject, but management roles get equal treatment. Looking at the dominant category - it covers both board oversight and management structure. The board is mentioned first and last (updates flow to board), framing this as an oversight structure. But management roles are also described.

Actually, rereading this more carefully, the structure is clear: the board sits at the top overseeing, management handles day-to-day operations in the middle, and information flows back up to the board. The board appears as both the grammatical subject and the final recipient of updates, which reinforces the oversight frame. Rule 2 applies here—the board delegates to management and maintains oversight. I'll categorize this as Board Governance.

Specificity: The paragraph names specific committees and roles like Board Risk Committee, CLO, CTO, and Information Security Manager rather than using generic terms.

For the quality verification check, I'm looking for hard facts like dates, dollar amounts, headcounts, or named external firms and tools. The roles mentioned are firm-specific but don't meet that threshold. However, I do have multiple information security-related titles on the IS list—CTO, Information Security Manager, plus the named committees. That gives me three firm-specific facts, which satisfies the Firm-Specific category.

fact: Board Risk Committee

fact: Chief Technology Officer (CTO)

fact: Information Security Manager

fact: Management Risk Committee


reasoning: The paragraph describes organizational structure: who holds the cybersecurity leadership role (ISO), the team composition supporting that role, and the reporting line to the Senior Risk Officer. While it mentions implementing the cybersecurity program, the primary content is about the people and structure rather than processes, tools, or frameworks — the person-vs-function test leans toward the person/structure side. Firm-Specific due to the cybersecurity-specific ISO title and specific departmental team composition, but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Let me analyze this paragraph.

The paragraph describes the ISO (Information Security Officer) role, the team composition, and reporting line. Let me apply the person-vs-function test.

The paragraph tells us:
- ISO implements and maintains the cybersecurity program
- The Information Security team composition: ISO, risk and compliance department members, security staff, IT members
- ISO reports to Senior Risk Officer

This is about organizational structure and reporting lines. It's not about the person's credentials/background. But it's also not really about processes/tools/frameworks. It's about WHO is responsible and HOW they're organized.

When I apply the person-vs-function test—replacing the ISO title with "the Company"—the sentence still works structurally but loses the specific organizational meaning. This is clearly about management roles and reporting structures rather than individual qualifications. The ISO title is cybersecurity-specific and belongs on the IS list, though the Senior Risk Officer reporting line is more general risk management than cybersecurity-specific.

Looking at what's actually verifiable: the ISO role and team composition (ISO, risk and compliance staff, security staff, IT members) are IS-list facts, but neither qualifies as a hard QV fact—no dates, headcounts, named tools, or certifications. That puts this in Firm-Specific territory.

fact: ISO (Information Security Officer)

fact: Team composition: ISO, risk and compliance department members, security staff, and IT members

fact: ISO reports directly to Senior Risk Officer


reasoning: The paragraph primarily narrates a specific cybersecurity incident — the MOVEit Transfer vulnerability exploited via a third-party vendor — describing scope (customer PII potentially copied), response actions (patches, customer notification), and containment. While the final sentences touch on insurance (Strategy Integration) and materiality, the dominant communicative purpose is the incident narrative. Three QV-eligible hard facts: named firm (Progress Software Corporation), named product (MOVEit Transfer), and specific time period (2023 fiscal year).

thinking:
Let me analyze this paragraph carefully.

This describes the MOVEit Transfer incident - what happened, scope, response, and impact. Let me classify it.

Content Category: This paragraph primarily describes a cybersecurity incident - what happened (MOVEit Transfer vulnerability exploited via third-party vendor), scope (customer PII potentially copied), response actions (patches, customer notification, working with vendor). There's also mention of insurance and materiality at the end. The dominant content is the incident narrative.

Wait, let me check the tiebreakers. The paragraph DESCRIBES what happened (the MOVEit incident, how it affected them, response actions) - that's Incident Disclosure.

The bulk of this is the incident narrative itself, with just the final sentences touching on insurance and materiality considerations, so this clearly falls under Incident Disclosure.

Now for specificity - I'm counting the hard verifiable facts here. I've got Progress Software Corporation as a named third-party, MOVEit Transfer as the specific product, and 2023 as the year. That gives me three QV-eligible facts, which means this qualifies as Quantified-Verifiable.

fact: Progress Software Corporation

fact: MOVEit Transfer (named product/platform)

fact: 2023 fiscal year


reasoning: The paragraph describes the company's internal cybersecurity training and exercise activities (awareness training, phishing exercises, tabletop exercises), which are core risk management processes. No named frameworks, cybersecurity-specific roles, named tools, specific dates, or other IS-list facts are present — 'monthly' and 'annual' are generic cadences, and phishing exercises/tabletop exercises are common practices on the NOT list.

thinking:
Classify this paragraph.

Content: describes internal cybersecurity training and exercises - awareness training, phishing exercises, monthly safety meetings, annual cybersecurity awareness update, tabletop exercises.

Category: Risk Management Process - describes internal processes/activities.

Specificity: No named frameworks, no named roles (just "management" and "employees"), no specific dates, no named tools. "phishing exercises", "tabletop exercises", "safety meetings" are common practices. "monthly safety meetings" and "annual cybersecurity awareness update" are generic cadences. No IS-list facts.

→ Generic Boilerplate (1)


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management program — ERM integration, NIST framework alignment, layered strategy, and company-wide policies and procedures. The Board and Audit Committee are mentioned briefly as context but are not the grammatical subjects performing the primary actions; the program and its processes are. NIST is named as a recognized standard, but no firm-specific facts (cybersecurity-specific roles, named tools, specific dates, headcounts) survive the NOT-list filter, keeping this at Sector-Adapted.

thinking:
Let me analyze this paragraph.

Content: Describes cross-departmental approach, mentions Board and Audit Committee briefly, then focuses on the cybersecurity risk management program - ERM integration, NIST framework, layered strategy, policies and procedures.

Category: The primary content is about the company's internal cybersecurity processes - risk management program, NIST framework, policies, procedures. The Board/Audit Committee mention is brief attribution. This is Risk Management Process.

Specificity: NIST framework is named → at least Sector-Adapted. Any firm-specific facts? Let me check the IS list:

Board and Audit Committee references don't count as specific details, and the cross-departmental language is too generic. The only concrete named standard here is NIST, which triggers Sector-Adapted classification.

fact: NIST framework


reasoning: The paragraph describes the company's internal workflow for incident identification, materiality assessment, and escalation — this is a process description, not an actual materiality conclusion (which would be Strategy Integration). The CIEC is a firm-specific named committee with a distinguishing abbreviation, elevating specificity above generic boilerplate, but there are no two hard verifiable facts (no dates, dollar amounts, named firms, or tools) to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the process when a cybersecurity threat/incident is identified - IRT communicates to CIEC, CIEC assesses materiality, recommends to Board, may engage third parties.

Category: This is about the company's internal process for handling incidents and materiality assessment. The IRT and CIEC are named internal programs/teams. This is Risk Management Process - it describes the incident response and materiality assessment workflow.

Wait - could this be Strategy Integration due to materiality assessment? No - this describes the *process* of how they assess materiality, not an actual materiality conclusion.

It's describing the workflow, not making a materiality judgment. Looking at the specificity, CIEC stands out as a firm-specific named committee - likely "Cyber Incident Executive Committee" or similar - while IRT is just a generic abbreviation for Incident Response Team. The other entities mentioned like the Board and third-party consultants are standard, and the SEC's cybersecurity disclosure rule isn't a framework per the list.

So this qualifies as Firm-Specific based on CIEC being a unique named committee. There's no quantitative value here either - no dates, dollar amounts, headcounts, or named third-party firms.

fact: CIEC (Cyber Incident Executive Committee or similar) — named internal committee with unique identifier

fact: IRT (Incident Response Team) — named internal team


reasoning: The paragraph describes the company's internal cybersecurity program — controls assessment, policies, procedures, technologies, training, and phishing simulations. It names two recognized frameworks (Cyber Risk Institute Cyber Profile and NIST CSF) but contains no firm-specific facts from the IS list (no cybersecurity-specific titles, named tools, dates, headcounts, or named third-party firms), keeping it at Sector-Adapted.

thinking:
Let me analyze this paragraph.

Content: Describes RJF's cybersecurity program - risk assessment methodology, framework adoption (Cyber Risk Institute Cyber Profile, NIST CSF), controls, policies, procedures, training. This is about internal processes.

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

Specificity:
- Names "Cyber Risk Institute Cyber Profile" - this is a named framework/standard
- Names "NIST Cybersecurity Framework" - named standard
- The rest is generic practices (training, phishing simulations, access control, etc.)

- The Cyber Risk Institute Cyber Profile is a recognized industry framework for financial services, similar to NIST - it's a named standard but nothing unique to this company. Checking the IS list confirms there's nothing firm-specific: no specialized titles, named committees, dates, products, third-party firms, or specific metrics. This lands at Sector-Adapted.

fact: Cyber Risk Institute Cyber Profile

fact: NIST Cybersecurity Framework


reasoning: The paragraph's primary content is the management-level IT/Cybersecurity Committee's composition (CIO as chair, CISO, specific departmental representation), reporting structure (to Enterprise Risk Committee and board-level IT/Cybersecurity Committee), and organizational role. Per the codebook, 'management committees responsible for cybersecurity' falls under Management Role. While it touches on what the committee oversees, the dominant communicative purpose is describing who comprises the committee and how it reports — organizational structure rather than the processes themselves. Multiple IS-list facts (named committees, cybersecurity-specific roles, specific team composition) but no QV-eligible hard facts yield Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the IT/Cybersecurity Committee, its composition, meeting cadence, and reporting structure. Let me determine category and specificity.

**Category Analysis:**
- The board approved management committees - but the focus is on a management committee (IT/Cybersecurity Committee), not the board itself
- The committee is chaired by CIO, includes CISO and various employees
- It describes what this management committee does - oversight of risk management strategy, policies, etc.
- The CISO reports to the IT/Cybersecurity Committee of the board

This is primarily about management committee structure and composition.

I'm noticing there's actually a distinction here between two separate committees - a management-level IT/Cybersecurity Committee that handles day-to-day oversight, and a board-level IT/Cybersecurity Committee that the CISO reports to. The bulk of the content focuses on the management committee's structure, composition, and responsibilities, with the board committee mentioned only at the end as part of the reporting chain. I'm checking the specificity of the facts mentioned. The committee has named roles like CIO and CISO, and specific team functions across IT, risk, compliance, operations, and HR—all firm-specific details. There are no hard verifiable facts like dates, dollar amounts, or named third-party vendors, so this lands at Firm-Specific level 3.

fact: CIO chairs the committee

fact: CISO

fact: Committee includes information technology, risk, compliance, operations and human resources/training

fact: Enterprise Risk Committee

fact: IT/Cybersecurity Committee of the board of directors


reasoning: The paragraph describes the company's internal cybersecurity risk management program elements — risk assessments, security controls, incident response, training, and third-party oversight — making it squarely Risk Management Process. It names two specific, externally verifiable assessment tools (FFIEC Cybersecurity Assessment Toolkit and the Ransomware Assessment Toolkit with its named developing organizations), which constitute two QV-eligible named tools/systems, reaching the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph from Southside Bancshares' 10-K filing.

Content: Describes the company's information security program, its alignment with business strategy, and lists key elements including risk assessments, Information Security Department, FFIEC Cybersecurity Assessment Toolkit, Ransomware Assessment Toolkit, training, external providers, incident response plan, and third-party risk management.

Category: This is about the company's internal cybersecurity processes and program elements. → Risk Management Process

Specific facts:
- "Information Security Department" - this is a named department, firm-specific

- FFIEC Cybersecurity Assessment Toolkit and Ransomware Assessment Toolkit are both named tools with specific organizational origins, making them firm-specific facts rather than generic practices
- The assessment cadences (biannual and annual) are generic implementation details, but the tools themselves and their use by this particular company are what matter for firm-specific identification
- "Information Security Department" is just a generic title and wouldn't qualify as a cybersecurity-specific identifier on its own

.

Looking at what we have: the FFIEC Cybersecurity Assessment Toolkit and Ransomware Assessment Toolkit are both named assessment tools, and we've got named organizations like the Bankers Electronic Crimes Task Force and U.S. Secret Service. That gives us multiple hard verifiable facts pointing to Quantified-Verifiable status. The FFIEC tool is specific enough—it's a distinct named assessment framework, not just a general standard—and combined with the Ransomware Assessment Toolkit, we have two named tools that should count.

fact: Cybersecurity Assessment Toolkit (developed by the FFIEC)

fact: Ransomware Assessment Toolkit (developed by the Bankers Electronic Crimes Task Force, state bank regulators and the U.S. Secret Service)

fact: Information Security Department responsible for managing cybersecurity


reasoning: The paragraph describes the company's cybersecurity framework adoption and process improvement methodology — squarely Risk Management Process. It names NIST CSF and C2M2/DOE as frameworks (Sector-Adapted), but also references BPU requirements, a named regulatory body specific to New Jersey utilities, which identifies something unique to this company's regulatory context and elevates to Firm-Specific. No QV-eligible hard facts (dates, dollars, headcounts, named third-party firms, named tools) are present.

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity risk management approach, framework adoption (NIST CSF, C2M2), and regulatory alignment (BPU). This is about internal processes and frameworks.

Category: Risk Management Process - describes framework adoption, alignment with standards, and process improvement methodology.

Specificity: Let me check the facts:
- NIST CSF - named framework
- BPU - a regulatory body (Board of Public Utilities - specific to NJ utilities)
- C2M2 (Cybersecurity Capability Maturity Model) from U.S.

Department of Energy - this is a named framework/standard. BPU is a specific regulatory body relevant to this company, C2M2 is a named framework, and NIST CSF is a named framework. Now I'm testing whether these qualify as quantifiable facts: frameworks and standards don't count as hard verifiable facts like dates or dollar amounts, and while BPU requirements are specific to this company's regulatory context, they're still sector-adapted standards rather than company-specific metrics. C2M2 is a Department of Energy framework specific to the energy sector, which signals this company operates in utilities, while BPU is a named regulatory body unique to New Jersey—making both indicators of firm-specific context rather than universal standards. narrows this beyond generic. The combination identifies this as a NJ utility company with critical infrastructure.

Wait, actually re-reading the IS list more carefully: the IS list doesn't explicitly cover named regulatory bodies. But it does include "other_specific" as a fact type. BPU is a named entity that identifies something unique about this company. I think Firm-Specific is reasonable.

Actually, I want to be more careful. C2M2 is a framework like NIST - it's a recognized standard for the energy sector. BPU is a regulatory body. Neither is on the explicit IS list. But the paragraph names three different standards/frameworks (NIST CSF, BPU requirements, C2M2/DOE), which is more detailed than a generic "we follow NIST" paragraph.

I'll go with Firm-Specific (3) because BPU is a named regulatory body specific to NJ utilities, making this more than just sector-adapted.

fact: BPU (Board of Public Utilities) regulatory requirements

fact: Cybersecurity Capability Maturity Model (C2M2) from U.S. Department of Energy


reasoning: The paragraph is about the persons filling cybersecurity leadership roles — their titles, shared responsibility, tenure of experience, and career background at multinational organizations. The person-vs-function test confirms this: the core content is who these leaders are and what qualifies them, not what the program does. Two cybersecurity-specific titles (CDIO, VP of Platforms/Infrastructure/Cybersecurity) are firm-specific facts; 'over 20 years' is the only QV-eligible fact, so only one hard verifiable fact means Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes two management roles (CDIO and VP of Platforms, Infrastructure and Cybersecurity), their shared responsibility, and their experience/background.

Category: This is about the persons - their titles, experience, background. The person-vs-function test: if I remove the titles and credentials, what's left? "Our information security program is administered under the supervision of [people] who share responsibility for assessing and managing the Company's cybersecurity risks." The core content is about WHO these people are and their qualifications. → Management Role

Now I'm checking what qualifies as quantifiable and firm-specific. The two named roles are firm-specific but not quantifiable. The "over 20 years of related experience" is a specific duration that would count as quantifiable. I don't see any other quantifiable facts like named firms, specific dates, dollar amounts, certifications, or tools mentioned.

fact: EVP, Chief Digital and Innovation Officer (CDIO)

fact: Vice President (VP) of Platforms, Infrastructure and Cybersecurity

fact: over 20 years of related experience


reasoning: This paragraph describes an internal cybersecurity practice (annual training for employees handling sensitive data), which is a risk management activity. It contains no named frameworks, firm-specific facts, or verifiable details — 'annual' is a generic cadence and 'cybersecurity management and incident training' is a common practice.


reasoning: The Audit Committee is the grammatical subject throughout, receiving reports and engaging with management on cybersecurity oversight — classic Board Governance. CIO and CISO are cybersecurity-specific titles on the IS list, making this Firm-Specific, but no QV-eligible hard facts (named roles don't count toward QV threshold).

thinking:
Let me analyze this paragraph.

Content: The Audit Committee receives quarterly reports and engages with CIO and CISO on cybersecurity topics. Also mentions internal and third-party audits reported to the Audit Committee.

Category: The Audit Committee is the grammatical subject. This is about board-level oversight. → Board Governance

Specificity:
- "Audit Committee" — NOT list (generic)
- "quarterly" — NOT list (generic cadence)
- "CIO" — IS list (cybersecurity-specific title)
- "CISO" — IS list (cybersecurity-specific title)

- No named frameworks, no specific dates, no dollar amounts, no named firms

Since CIO and CISO are cybersecurity-specific titles on the IS list, this qualifies as Firm-Specific. There are no QV-eligible facts here—just named roles—so the classification is Firm-Specific (3).

fact: Chief Information Officer (CIO)

fact: Chief Information Security Officer (CISO)


reasoning: The paragraph establishes the CDO as the person responsible for information security activities and cybersecurity risk management strategy. While it describes the scope of the role rather than personal credentials, the primary communicative purpose is identifying WHO holds cybersecurity leadership — the CDO — making it Management Role. CDO overseeing cyber is a cybersecurity-specific title on the IS list, yielding Firm-Specific.

thinking:
Classify this paragraph.

The paragraph is about the CDO (Chief Digital Officer) directing cybersecurity activities. Let me apply the person-vs-function test.

The paragraph mentions CDO and then describes what they do - "directs, coordinates, plans, and organizes information security activities" and "leading the development of our cybersecurity risk management strategy."

Person-vs-function test: If I remove "Our CDO" and replace with "The Company," the paragraph still makes sense as a process description. But wait - the paragraph is really about what the CDO does as a role, establishing the CDO as the person responsible. It's describing the role's responsibilities rather than the person's credentials/background.

Looking at the codebook, this is establishing the CDO's responsibilities and leadership functions without detailing specific processes, frameworks, or methodologies. The focus is on the role itself and what it oversees rather than how the work gets done, which points toward Management classification.

For specificity, CDO is explicitly listed in the codebook as a recognized role when overseeing cybersecurity, so this is a Firm-Specific fact.

fact: CDO (Chief Digital Officer) leads cybersecurity activities


reasoning: The paragraph's primary content is an explicit materiality assessment ('prior cybersecurity incidents have not materially affected... our operations, business strategy, results of operations or financial condition') followed by a forward-looking materiality risk acknowledgment. Per Rule 6, materiality disclaimers are Strategy Integration even when boilerplate, and the appended cross-reference to Risk Factors does not change the classification. No firm-specific facts from the IS list are present — 'Enterprise Risk Management program' is a generic program name.

thinking:
Strategy Integration - materiality assessment is the primary content. Cross-reference doesn't change it per Rule 6.

Specificity: No named standards, no firm-specific facts from the IS list. "Enterprise Risk Management program" is a generic program name. The cross-reference is boilerplate.

Generic Boilerplate.


reasoning: The paragraph describes internal cybersecurity processes—designing, implementing, and monitoring safeguards following risk assessments—which squarely fits Risk Management Process. It contains no named frameworks, roles, tools, dates, or any firm-specific details; the language is entirely generic and could apply to any company.

thinking:
Classify this paragraph.

Content: Describes internal processes - designing, implementing, maintaining safeguards, addressing gaps, updating, monitoring. This is about the company's own risk management activities.

Category: Risk Management Process

Specificity: No named frameworks, no named roles, no specific facts. Generic language about safeguards. → Generic Boilerplate


reasoning: The paragraph opens with and frames around the CISO as primary subject — their CISSP certification and team's combined experience — making the person/credentials the primary content (Management Role). The second sentence describes board committee oversight but is subordinate to the CISO framing. Two QV-eligible hard facts: CISSP certification held by an individual and '50 years' combined experience' as a specific number.

thinking:
Let me analyze this paragraph carefully.

The paragraph has two main parts:
1. CISO description with CISSP certification, team experience
2. Board committees (Technology Committee, ERM Committee) oversight

Let me apply the person-vs-function test. The first sentence names the CISO role with CISSP certification and describes the team's combined experience. The second sentence describes board committee oversight.

This is a dual-category paragraph. Let me determine dominance:
- First sentence: CISO + CISSP + team experience → Management Role
- Second sentence: Technology Committee + ERM Committee oversight, receiving updates → Board Governance

Both parts are roughly equal in length.

The paragraph opens with the CISO and team credentials, then transitions to how the board's committees provide oversight. The grammatical subjects shift from "Our CISO" to "The Board of Directors' Technology Committee and its ERM Committee." Since both elements carry similar weight, I'm leaning toward Management Role as the primary category since the paragraph leads with the person and their qualifications before discussing governance structure. I'm identifying the specific, verifiable facts here: the CISO role and CISSP certification are named credentials, the Technology and ERM Committees are specifically named, and the "over 50 years' combined experience" is a quantified metric. That gives me two QV-eligible facts—the certification and the experience number—which points to Quantified-Verifiable.

fact: Certified Information Systems Security Professional (CISSP)

fact: over 50 years' combined experience

fact: Technology Committee

fact: Enterprise Risk Management Committee (ERM Committee)


reasoning: The paragraph describes the company's internal cybersecurity processes — threat monitoring, network surveillance, penetration testing, vulnerability scanning, and 24/7 coverage via an MSSP. Applying the person-vs-function test, the 'Information Security team' is incidental attribution; the substance is about activities and processes. No named frameworks, no named tools/firms, no specific dates or numbers remain after filtering: 'Information Security team' is a generic department name, 'managed security service provider' and 'leading cybersecurity companies' are unnamed entities, and penetration testing/vulnerability scans are common practices on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes what the Information Security team does - monitoring threats, investigating impact, examining controls, monitoring networks, penetration testing, vulnerability scans, MSSP for 24/7 coverage, working with cybersecurity companies.

Category: This is about internal processes - what the team does. The "Information Security team" is the subject, but the content is about processes/activities, not about who the person is. Applying the person-vs-function test: remove the team name and it still describes processes. → Risk Management Process.

Specificity: Let me check facts:
- "Information Security team" - this is a team name but is it specific? It's a generic team name, not a cybersecurity-specific title like CISO. It's more like a generic department name.

- "managed security service provider" - unnamed entity → NOT list
- "leading cybersecurity companies" - unnamed → NOT list
- "penetration testing", "vulnerability scans" - common practices → NOT list
- "24 hours a day, seven days a week" - this is a common description, not a specific fact
- No named frameworks, no named tools, no dates, no dollar amounts, no named firms

After filtering: No specific facts remain. No named standards either. → Generic Boilerplate.

Wait - "Information Security team" - is this a cybersecurity-specific team name? Looking at the IS list: "Specific team/department compositions" like "Legal, Compliance, and Finance." The "Information Security team" is just a generic name for the security team. It's not a specific composition or named department. So this doesn't qualify as a specific fact either.

→ Risk Management Process, Generic Boilerplate.


reasoning: The paragraph introduces the cybersecurity leader (Senior Director of Cybersecurity) with credentials (15 years of experience, areas of expertise) and then details the management-level security steering committee's composition and structure. While process activities are mentioned, the primary content is about who leads cybersecurity and the management committee responsible for it — both Management Role signals. Specificity is Firm-Specific: multiple IS-list facts (cybersecurity-specific title, specific years of experience, specific committee composition), but only one QV-eligible hard fact (15 years), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the cybersecurity team leader (Senior Director of Cybersecurity) with experience details, then describes what the team does, and describes a security steering committee with its composition and meeting cadence.

Category: This is a mixed paragraph. It starts with the person (Senior Director of Cybersecurity, 15 years experience, areas of expertise) - that's Management Role. Then it describes what the team does (implementing cybersecurity, data protection, third-party risk practices) - that's Risk Management Process. Then it describes the security steering committee composition and activities.

The paragraph really centers on the team's functions and governance structure, with the leader's background serving as context. The steering committee details—who sits on it and how often it meets—round out the organizational picture, though that could fit under management structure as well. Looking at the QV-eligible facts more carefully: "over 15 years" is a specific number that counts toward QV, but named roles like "Senior Director of Cybersecurity" don't. I'm not finding any other QV-eligible content—no named firms, tools, dates, dollar amounts, certifications, or universities. So that's just one QV fact, which means this falls into Firm-Specific (3).

fact: Senior Director of Cybersecurity

fact: over 15 years of direct cybersecurity experience

fact: security steering committee composed of Senior Director of Cybersecurity, cybersecurity and product/technology security professionals, and representatives from finance, internal audit, compliance and legal


reasoning: The paragraph contains an explicit materiality assessment ('reasonably likely to materially affect our business strategy, results of operations, or financial condition'), which per Rule 6 makes it Strategy Integration even though the language is boilerplate. The appended cross-reference to Risk Factors does not change the classification. No firm-specific facts, named frameworks, or verifiable details are present.

thinking:
Let me analyze this paragraph.

Content: This discusses cybersecurity risks that could materially affect business strategy/results/financial condition. It includes a materiality assessment and a cross-reference to Risk Factors.

Category: This contains an explicit materiality assessment - "reasonably likely to materially affect our business strategy, results of operations, or financial condition." Per Rule 6, this is Strategy Integration. The cross-reference doesn't change that.

Specificity: No named frameworks, no firm-specific facts from the IS list. "large financial technology provider" is a self-description. Everything else is boilerplate. → Generic Boilerplate.


reasoning: The paragraph describes engaging external parties to conduct assessments, tabletop exercises, and audits for the company's own cybersecurity program. Per Rule 3, external assessors hired to test the company are Risk Management Process, not Third-Party Risk. The firms are unnamed ('an external security firm', 'an audit firm'), so only the specific year reference ('During 2024') qualifies as a firm-specific fact, yielding one IS-list fact and thus Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes engagement of third-party experts for cybersecurity risk management - risk assessments, tabletop exercises, audits. The central topic is about using external parties to supplement internal processes.

Category: This is about engaging third parties to serve the company's own risk management. Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." The third parties here are conducting assessments and exercises FOR the company, not about imposing requirements ON vendors. → Risk Management Process

Specificity:
- "third-party cybersecurity experts" - generic, NOT list

- "During 2024" - specific date (year) → IS list
- "an external security firm" - unnamed → NOT list
- "an audit firm" - unnamed → NOT list
- "tabletop exercises" - common practice → NOT list
- "cybersecurity risk assessments" - generic

Only one IS fact: "During 2024" (specific date). That's one fact → Firm-Specific. Now I'm checking whether "During 2024" qualifies as a hard verifiable fact for QV purposes. Since specific dates like "fiscal 2025" count as IS facts, this year reference should too, but I need to verify it meets the threshold for QV.

fact: During 2024


content_category: Third-Party Risk

reasoning: The paragraph's central topic is managing cybersecurity risks associated with third-party service providers — pre-engagement assessments, periodic risk assessments, and ensuring security standards are maintained. This makes Third-Party Risk the dominant category. No named frameworks, specific roles from the IS list, dates, or quantified facts are present; 'strategic risk management committees' is a generic program name without a unique identifier, so specificity remains Generic Boilerplate.

thinking:
Let me classify this paragraph.

Content: About third-party service provider risk management - pre-engagement assessments, periodic risk assessments, strategic risk management committees review risks.

Category: The central topic is oversight of third-party providers' cybersecurity. → Third-Party Risk

Specificity: Let me check for specific facts:
- "strategic risk management committees" - this is somewhat generic, not a named non-generic committee from the IS list
- No named frameworks, no dates, no named firms, no specific numbers
- No cybersecurity-specific titles

No IS-list facts. No named standards. → Generic Boilerplate


content_category: None/Other

reasoning: This paragraph is a pure cross-reference directing readers to Item 1A and Item 7 for cybersecurity-related discussion. It contains no materiality assessment or substantive cybersecurity disclosure content, so it is None/Other per the codebook's distinction between cross-references and materiality disclaimers.

thinking: Cross-reference paragraph pointing to other sections, no materiality assessment.


reasoning: The Audit and Finance Committee is the primary actor in two of three sentences, describing its oversight scope and the updates it receives. Two cybersecurity-specific roles (CISO, Chief Digital and Technology Officer) are firm-specific facts per the IS list, but named roles do not count toward the QV threshold, so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

The paragraph has three sentences:
1. "Our cybersecurity program is managed by our Chief Digital and Technology Officer and Chief Information Security Officer." - Names who manages the program (management roles)
2. "The Audit and Finance Committee of the Board of Directors has oversight..." - Board committee oversight
3. "As part of this process, the Audit and Finance Committee receives regular updates from the Chief Digital and Technology Officer and Chief Information Security Officer..." - Board receiving updates from management

The primary actor across most of the paragraph is the Audit and Finance Committee (board committee). The first sentence attributes management to specific roles, but sentences 2 and 3 are about the committee's oversight activities.

The board committee is the grammatical subject in the dominant portion, making this a Board Governance issue. I'm checking the specificity of the roles mentioned—the Chief Digital and Technology Officer and Chief Information Security Officer are both cybersecurity-specific titles that belong on the inclusion list, while the Audit and Finance Committee is a variant of the generic Audit Committee that appears on the exclusion list.

For the quantifiable verification threshold, there are no hard facts like dates, dollar amounts, or headcounts. The two named roles don't count toward QV since they're just titles rather than verifiable facts. That leaves me with two inclusion-list items from the cybersecurity roles, which makes this Firm-Specific.

fact: Chief Digital and Technology Officer


reasoning: The paragraph is primarily about the person — the CIO's tenure (~25 years), prior role (CIO of Financial Products Division), appointment date (September 2020), and extensive IT background. While it also describes the team she leads, the dominant content is her qualifications and career history, satisfying the person-vs-function test for Management Role. Two QV-eligible hard facts: specific duration (~25 years) and specific date (September 2020).

thinking:
Let me analyze this paragraph carefully.

The paragraph is about the CIO - her tenure, background, prior role, and what she oversees. It also describes the cross-functional team she leads.

Person-vs-function test: The paragraph spends significant text on the CIO's background (25 years, prior role as CIO of Financial Products Division, appointment date September 2020, extensive IT background). Then it describes the team she leads. The primary content is about the person - her qualifications and experience. → Management Role

Specific facts:
- CIO (cybersecurity-specific title per IS list) → named_role

- Nearly twenty-five years of experience and her September 2020 appointment are both verifiable facts, with the appointment date being particularly concrete. She previously held the CIO position at the Financial Products Division, and now leads a cross-functional team spanning product, cybersecurity, legal, and compliance. → Quantified-Verifiable

fact: CIO (Caterpillar CIO oversees cybersecurity program)

fact: nearly twenty-five years as a Caterpillar employee

fact: appointed as CIO in September 2020

fact: cross-functional team comprised of product, cybersecurity, legal and compliance organizations