reasoning: The paragraph frames risk oversight as flowing from the board through the Audit Committee, then describes the Cybersecurity Disclosure Committee (CDC) as a governance mechanism that assesses materiality and provides disclosure recommendations to the Audit Committee. While the CDC is a management-level committee, its function is oversight and disclosure governance within a board-delegated structure, making Board Governance the dominant frame. The named CDC with its unique abbreviation and specific departmental composition (IT, Legal, Internal Audit, Accounting and Reporting) are firm-specific facts, but none are QV-eligible hard verifiable facts.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph discusses board oversight, the Audit Committee, and a Cybersecurity Disclosure Committee (CDC). The first sentence is about board/Audit Committee oversight. But the bulk of the paragraph is about the CDC - its composition, responsibilities, and functions.

The CDC is a management-level committee (it includes IT, Legal, Internal Audit, Accounting teams - these are management functions). The board/Audit Committee is mentioned as the oversight body, but the CDC is the primary subject for most of the paragraph.

Actually, let me reconsider. The paragraph starts with board oversight, then introduces the CDC which reports to the Audit Committee.

The CDC handles materiality assessments, provides disclosure recommendations to the Audit Committee, and reviews cybersecurity risks along with controls and strategy. Looking at the grammatical structure, the board and Audit Committee appear in the opening, but the CDC dominates the rest of the text as the main subject. Since the CDC is a management committee rather than a board committee, and most of the paragraph focuses on what it does, this leans toward management governance despite the board framing at the start. The CDC is clearly a management committee, but its described functions—assessing materiality, reviewing risks, providing recommendations—are governance and oversight activities rather than operational processes. The paragraph frames everything around the oversight structure: board establishing oversight, the Audit Committee receiving CDC reports, and the CDC functioning as a governance mechanism within that chain. So this is Board Governance, not Management Role. The CDC itself is specifically named with a unique identifier, which makes it a concrete internal program rather than a generic role.

fact: Cybersecurity Disclosure Committee ("CDC") — named committee with unique identifier

fact: CDC includes representation from Information Technology, Legal, Internal Audit, and Accounting and Reporting teams


content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: This is a SPAC ('Our Sponsor and affiliates' confirms acquisition-company status) presenting generic risk language about cybersecurity threats without any substantive disclosure — no program description, no governance structure, no management roles, no incident details, and no materiality assessment conclusion. The paragraph merely acknowledges that cybersecurity threats exist and could be harmful, which is boilerplate risk language that could appear in any filing unchanged.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph from OceanTech Acquisitions I Corp., a SPAC filing a 10-K.

Content: Generic risk language about cybersecurity threats. No specific program, no specific incident, no materiality assessment conclusion. It's just saying "cyber threats exist and could hurt us." This is general risk language.

The company name includes "Acquisitions" suggesting it's a SPAC. The paragraph mentions "Our Sponsor and affiliates" which confirms SPAC status.

This is generic risk language - no substantive disclosure. No program described, no governance, no management roles.

It's just boilerplate risk acknowledgment with no named frameworks, roles, dates, or specific facts to point to.


content_category: Board Governance

reasoning: The Audit Committee is the grammatical subject overseeing cybersecurity risk, making this Board Governance. The mention of a 'vCIO' is a cybersecurity-specific leadership title unique to this company's structure (not every company uses a virtual CIO), qualifying as a firm-specific fact. No second QV-eligible hard fact exists, so it stays at Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: The Audit Committee oversees cybersecurity risk management, receives reports from management and the vCIO about IT systems and cybersecurity tools.

Category: Board Governance - the Audit Committee (board committee) is the grammatical subject performing oversight.

Specificity: Let me check for specific facts.
- "Audit Committee" - on the NOT list (generic governance)
- "vCIO" - this is a cybersecurity/IT-specific role title. Virtual CIO. This is a firm-specific fact - it's a specific role title unique to this company's structure.
- "management team" - generic

- The vCIO is a distinct role within this organization's structure, making it a firm-specific fact. There are no quantifiable or verifiable facts like dates or dollar amounts. This gives me a Firm-Specific classification.

fact: vCIO (virtual Chief Information Officer) role receives and reports to Audit Committee


content_category: Strategy Integration

specificity_confidence: medium

reasoning: The paragraph's primary purpose is an explicit materiality assessment — stating that no cybersecurity threats have materially affected business strategy, results of operations, or financial condition — which is Strategy Integration per Rule 6. The cross-reference to Risk Factors is appended but does not override the materiality conclusion. 'December 31, 2024' is a specific date anchoring the assessment (one QV-eligible fact), while 'since inception in January 2018' is a company milestone per the NOT list and does not count. One hard fact yields Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: This paragraph makes explicit materiality assessments ("have not experienced any material risks," "not reasonably likely to have such a material effect," "not aware of any cybersecurity or information security incidents that have materially affected us"), mentions no expenses from incidents, then has forward-looking risk language and a cross-reference to Risk Factors.

Category: Strategy Integration — the paragraph's primary purpose is a materiality assessment. Per Rule 6, any paragraph that explicitly assesses whether cybersecurity risks have "materially affected" the company is Strategy Integration.

Looking at the specific dates mentioned — the fiscal year end and an inception date from January 2018 — these are concrete temporal references. While they're more structural metadata than cybersecurity-specific details, the codebook treats specific dates as quantified-verifiable facts, so two dates would qualify.

But I'm realizing the codebook explicitly excludes company milestones like "since inception" from counting as cybersecurity facts. That "January 2018" reference is really just marking when the company started, not disclosing anything about their security posture. So even though I have two dates, one of them doesn't actually count toward the threshold. The inception date in January 2018 is explicitly excluded as a company milestone rather than a cybersecurity fact, leaving only December 31, 2024 as the relevant specific date—making this Firm-Specific at best.

fact: As of December 31, 2024


content_category: Risk Management Process

reasoning: The paragraph describes the company's own cybersecurity assessment processes — external audits, ISMS reviews, penetration testing — which are internal program activities served by external assessors (Rule 3: external assessor hired to test the company → RMP). The person-vs-function test is not at issue since no individual role is foregrounded. Specificity reaches Firm-Specific because the paragraph contains specific dates (2023, 2024) and an ISO 27001 certification claim (holding a certification is more than naming a standard). However, it does not reach Quantified-Verifiable: the only QV-eligible hard fact is the date range (2023/2024); the certification claim is firm-specific but not on the QV-eligible list (it is an organizational certification, not a named third-party firm, named tool, individual certification, dollar amount, or headcount).

thinking:
Let me analyze this paragraph.

Content: Describes external assessments of cybersecurity - audits, ISMS reviews, ISO 27001 certification, penetration testing. This is about the company's own internal processes being assessed by external parties. The external assessors serve the company's program.

Category: Risk Management Process (Rule 3: external assessor hired to test the company → RMP)

Specific facts:
- "2023 and 2024" - specific dates
- "ISO/IEC 27001:2013" - named standard, but also they claim certification which is firm-specific

- "ISMS" - Information Security Management System - generic program name

Now I'm checking the IS list: the specific dates "2023 and 2024" qualify, and the certification claim about ISO 27001 compliance is firm-specific. For QV eligibility, the dates count as one fact type, and while the ISO certification is company-held rather than individual-held, it's still a named certification that the firm claims to possess.

Looking at the QV threshold, I have one hard verifiable fact from the dates. The ISO 27001 certification is firm-specific but doesn't meet the strict QV criteria since it's not held by an individual. That leaves me short of the two facts needed for QV status.

So this lands as Firm-Specific (3) in terms of specificity.

fact: Independent audits conducted in 2023 and 2024

fact: ISO/IEC 27001:2013 certification received


content_category: Management Role

reasoning: The entire paragraph is about the persons filling CIO and CISO roles — their experience, credentials, certifications, education, and reporting line. This is squarely Management Role under the person-vs-function test. Multiple QV-eligible hard facts: specific years of experience (30 years, 9 years, 30 years) and named certifications (CISM, CDPSE, CRISC) easily exceed the two-fact threshold.

thinking:
This paragraph describes two management roles (CIO and CISO) with their qualifications, experience, certifications, and reporting lines. It's clearly about the persons, not the function.

Content category: Management Role - the entire paragraph is about who these people are, their credentials, experience, and reporting structure.

Specific facts:
- CIO (cybersecurity-specific title per IS list)
- CISO (cybersecurity-specific title)
- CISO reports to CIO (reporting line)
- 30 years of IT experience (quantified)

- 9 years in IT leadership (quantified)
- CISM, CDPSE, and CRISC certifications (named credentials)
- 30+ years in infosec (quantified)

QV-eligible: Multiple quantified experience metrics across different domains and three named industry certifications. That's well over 2 hard verifiable facts.

Specificity: Quantified-Verifiable

fact: CIO role

fact: CISO role, reports to CIO

fact: CIO has over 30 years of IT experience

type: quantified

fact: CIO has 9 years in IT leadership roles

fact: CISO has over 30 years of information security experience

fact: CISM certification

fact: CDPSE certification

fact: CRISC certification


reasoning: The paragraph is entirely about the person filling the cybersecurity leadership role — their title, years of experience, and areas of expertise. This is classic Management Role content. VP of IT is a cybersecurity-specific title on the IS list, making it Firm-Specific. 'Over thirty years' is one QV-eligible fact (specific duration), but only one hard verifiable fact is present, so it does not reach Quantified-Verifiable.

thinking:
Classify this paragraph.

The paragraph is about a person - their title, experience, and background. This is Management Role.

Specific facts:
- "Vice President of IT" - this is a cybersecurity-adjacent title... let me check the IS list. "VP of IT/Security" is listed. So this counts.
- "over thirty years" - specific number of years of experience → quantified

QV check: "over thirty years" (specific duration) + ... that's one hard verifiable fact. VP of IT is a named role (firm-specific) but doesn't count toward QV. So only one QV-eligible fact → Firm-Specific? Wait, let me re-check.

Actually, looking at the QV-eligible criteria, "over thirty years" qualifies as years of experience with a specific number, but the VP of IT role itself isn't on the QV list. That gives me just one QV-eligible fact, which means this falls into Firm-Specific rather than QV.

fact: Vice President of IT

fact: over thirty years of IT background


content_category: Third-Party Risk

reasoning: The paragraph's central topic is assessing cybersecurity risks of third-party service providers — their selection and oversight — making it Third-Party Risk rather than a component of internal processes. No named frameworks, roles, tools, dates, or firm-specific details appear; all language is generic and interchangeable across filings.

thinking:
Classify this paragraph.

The paragraph discusses third-party service provider risk assessment as part of their risk management program. The central topic is oversight of external parties' cybersecurity - vendor selection, oversight, risk criteria for third parties.

This is Third-Party Risk - vendor oversight is the central topic.

Specificity: No named frameworks, no named roles, no specific facts from the IS list. Generic language throughout - "third-party service providers", "processes in place", "cybersecurity risk criteria".

→ Generic Boilerplate


reasoning: The paragraph's primary content describes the company's internal cybersecurity program — its governance policy (ISG Policy), security measures (encryption, DLP, authentication, access controls), vulnerability management, monitoring processes, and NIST alignment. While the CTO and Head of Technology Infrastructure are named, they serve as attribution for who manages the program; the person-vs-function test confirms the paragraph is about what the program does, not about the individuals' qualifications or backgrounds. Firm-Specific due to cybersecurity-specific roles (CTO, Head of Technology Infrastructure) and a uniquely named internal program (ISG Policy), but no two QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: Describes Blue Owl's cybersecurity program - ISG Policy, managed by CTO and Head of Technology Infrastructure ("Blue Owl IT Management"), their responsibilities (monitoring, vulnerability management, etc.), security measures (encryption, DLP, authentication, etc.), two types of cyber risk, and NIST framework alignment.

Category: This paragraph describes internal cybersecurity processes, tools, and methodologies. It mentions CTO and Head of Technology Infrastructure, but the bulk is about what the program does. Person-vs-function test: remove the titles and the paragraph still describes the program's processes. → Risk Management Process

Now I'm checking the specific facts for qualification. The CTO is on the IS list, which points to Firm-Specific, and I have the Head of Technology Infrastructure as a cybersecurity-adjacent role, plus the named ISG Policy and NIST CSF reference. That gives me multiple qualifying facts, so this should count as Firm-Specific.

fact: Chief Technology Officer

fact: Head of Technology Infrastructure

fact: Information Security Governance Policy (ISG Policy)

fact: NIST Cybersecurity Framework

type: framework


reasoning: The paragraph describes the company's internal incident response planning processes — detection, analysis, containment, recovery, and coordination. The 'IT Leader' mention is incidental attribution, not a cybersecurity-specific title from the IS list (not CISO/CIO/CTO/VP of Security), and 'cybersecurity incident response plan' is a generic program name. No named frameworks, dates, tools, or firm-specific facts remain after validation.

thinking:
Let me analyze this paragraph.

Content: Describes incident response plan, framework for handling incidents, coordination, structured procedure for detection/analysis/containment/recovery. Mentions "IT Leader" for material incident evaluation.

Category: This is about the company's internal cybersecurity processes - incident response planning, detection, analysis, containment, recovery. The "IT Leader" is mentioned as attribution, not as the focus. → Risk Management Process

Specificity: Let me check for specific facts.
- "IT Leader" - is this a cybersecurity-specific title? No, it's generic IT leadership.

Looking at the IS list, "IT Leader" doesn't match any of the specific titles like CISO, CTO, CIO, or VP of IT/Security—it's just generic IT leadership. The incident response plan itself is a standard program name with no frameworks, dates, firms, or tools mentioned. This is generic boilerplate with no concrete details.


reasoning: The paragraph describes the company's own internal cybersecurity measures (VPN, MFA, EDR, antivirus, password policies, encryption, SIEM) — all internal processes and tools, making it Risk Management Process. Despite the list of measures, every item is a common/generic security practice with no named products, vendors, frameworks, dates, or headcounts. 'Microvast' is a company self-reference and does not count as a specific fact.

thinking:
Let me analyze this paragraph.

Content: Lists specific cybersecurity measures - physical security, VPN, MFA, EDR, antivirus, password policies, encryption, SIEM. All internal processes/tools.

Category: Risk Management Process - describes the company's own internal cybersecurity processes and tools.

Specificity: Let me check for specific facts.
- No named frameworks (NIST, ISO, etc.)
- No named tools/products (just generic categories like "EDR", "SIEM", "VPN")
- No named roles, dates, firms, headcounts
- These are all common practices: MFA, EDR, antivirus, password policies, encryption, SIEM

- The company name "Microvast" appears but it's just a self-reference, not a specific detail about their implementation

Everything here is generic boilerplate - standard security measures without any proprietary details, named products, or concrete specifics about how they're actually implemented.


reasoning: The paragraph's central topic is oversight of third-party service providers — describing the vendor management program's components (risk assessments, security questionnaires, audits, vulnerability scans, contractual obligations). While detailed, it names no specific frameworks, no cybersecurity-specific roles, no named firms or tools, and no quantified facts. The practices listed (risk assessments, security questionnaires, vulnerability scans) are common and appear on the NOT list. The trailing cross-reference to Risk Factors does not change the classification.

thinking:
Let me analyze this paragraph.

Content: Describes third-party vendor management program in detail - risk assessments, security questionnaires, reviews, audits, vulnerability scans, contractual obligations. The central topic is oversight of external parties. The last sentence is a cross-reference.

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

Specificity: Let me check for specific facts:
- No named frameworks
- No cybersecurity-specific titles
- No named firms, tools, dates, dollar amounts
- "vendor management program" - generic program name
- The practices described (risk assessment, security questionnaire, audits, vulnerability scans) are common practices

- No named standards either

The paragraph outlines standard vendor management practices without any firm-specific details or named standards, so this falls into Generic Boilerplate.


reasoning: The paragraph describes the company's own cybersecurity intelligence-sharing processes, benchmarking, audits, and threat intelligence feeds — all internal program components. Third parties (government agencies, consultants) are mentioned as inputs to the company's program, not as vendor oversight targets. Three named government agencies (FBI, CISA, DOE CESER) constitute hard verifiable external organizations, meeting the two-fact QV threshold.

thinking:
Let me analyze this paragraph.

Content: Describes the company's intelligence sharing, collaboration with government agencies, third-party benchmarking, audits, and threat intelligence feeds as part of their cybersecurity program.

Category: This is about the company's own internal cybersecurity processes - intelligence sharing, audits, threat intelligence. Third parties are mentioned as components of the internal program, not as the central topic of vendor oversight. → Risk Management Process

Specific facts:
- FBI (named government agency)
- CISA (named government agency)

- Department of Energy Office of Cybersecurity, Energy Security and Emergency Response (named government agency)

I'm considering whether government agencies count as "named third-party firms" in the same way as commercial vendors like Mandiant or Deloitte. While FBI and CISA partnerships are common in the utility sector, these are still named specific entities that distinguish this company's particular relationships, which aligns with how the codebook treats named entities. I'm wrestling with whether government agencies like FBI, CISA, and DOE CESER count as "named third-party firms" for verification purposes—the examples given are private companies, but these are still named external organizations that are independently verifiable, so I think they should qualify. Government agencies like FBI, CISA, and DOE definitely count as named external organizations, so I'm confident this qualifies as Quantified-Verifiable.

fact: FBI

fact: CISA


reasoning: The paragraph is primarily about the people filling cybersecurity leadership roles — their titles, years of experience, and career histories at named prior employers. While the first sentence attributes processes to them, the bulk of the content describes who these individuals are and what qualifies them, satisfying the person-vs-function test for Management Role. Multiple QV-eligible facts: two specific experience durations plus three named prior employers.

thinking:
Let me analyze this paragraph carefully.

The paragraph has two parts:
1. First sentence: attributes cybersecurity processes to CTO and Senior Director, Information Security
2. Rest: describes their experience and backgrounds

The primary content is about the people - their experience, years of service, and prior employers. This is clearly Management Role.

Specific facts:
- CTO (cybersecurity-specific? CTO is on the IS list)
- Senior Director, Information Security (cybersecurity-specific role)
- 15 years of experience (quantified)

- 20 years of experience (quantified)
- Ticketmaster, Sony Pictures, Warner Bros. (named firms)

That's five hard verifiable facts right there - the experience metrics and those major employers are all concrete details I can point to. This clearly falls into Quantified-Verifiable territory.

fact: Chief Technology Officer (CTO)

fact: Senior Director, Information Security

fact: CTO has over 15 years of experience

fact: Senior Director has over 20 years of experience

fact: Ticketmaster (prior employer)

fact: Sony Pictures (prior employer)

fact: Warner Bros. (prior employer)


category_confidence: medium

reasoning: The paragraph's grammatical subject is 'the management team' but its substantive content is entirely about cybersecurity program functions: setting objectives, resource allocation, policy development, risk assessments, incident response, and compliance. Applying the person-vs-function test, removing 'management team' leaves a complete description of generic program activities — no individual is named, no credentials or qualifications are given, and no reporting lines are described. 'Management' is generic per the NOT list, so this is process description with generic attribution, not Management Role. Specificity is Generic Boilerplate: no named frameworks, no firm-specific facts (company self-reference 'Microvast' doesn't count), and all listed practices are standard boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes management team's role in cybersecurity with bullet points about responsibilities (setting objectives, resource allocation, policy development, risk management, incident response, compliance).

Category: This is about what management does - but applying the person-vs-function test: the paragraph describes functions/responsibilities, not the person's credentials or background. However, there are no specific process details either - it's a generic list of management responsibilities. The grammatical subject is "the management team" and "Microvast management."

The paragraph describes generic management responsibilities - setting objectives, resource allocation, policy development, risk management, incident response, compliance.

These are all functional descriptions, but the primary framing is about management's role. The person-vs-function test shows that if I replace "management team" with "the Company," it reads as a generic list of cybersecurity program elements. The paragraph is really about what management is responsible for, which is a list of generic functions. This is borderline between Management Role and Risk Management Process, but the primary communicative purpose is describing management's role and responsibilities. However, there's nothing about who the person is - no credentials, names, or reporting lines. It's about the management function, not the person, so this doesn't fit the codebook definition of "Management Role — CISO/CTO/CIO identification, qualifications, reporting lines."

The grammatical subject is "management team," which would normally trigger the Management Role category, but the person-vs-function test is decisive here: the substantive content is all about processes and functions that management oversees - risk assessments, incident response, compliance, policy development. "Management" is just generic attribution, and there's no specific role like CISO or CIO mentioned. This is Risk Management Process because the paragraph lists cybersecurity program activities rather than identifying or describing a specific management role.


reasoning: The Board's oversight and the Audit Committee are the grammatical subjects performing the primary action (overseeing cybersecurity risk management), making this Board Governance. 'Audit Committee' is generic governance, 'Director of Information Technology' is a generic IT title (not cybersecurity-specific per the IS list), and 'our Manager' is not a named firm — no specific facts remain after filtering.

thinking:
Classify this paragraph.

The paragraph is about the Board's oversight supported by the Audit Committee, which interacts with the Manager's Director of IT. The grammatical subject is "The Board's oversight" and the Audit Committee is the acting entity.

Category: Board Governance - the board/Audit Committee is the subject performing oversight.

Specificity: Let me check for specific facts.
- "Audit Committee" - NOT list (generic governance)
- "Director of Information Technology" - This is a generic IT title, not a cybersecurity-specific title. Per the IS-NOT list, "Head of IT", "IT Manager", "Director of IT" are generic IT leadership titles.

- "our Manager" - this refers to an external manager (NREF is an externally managed REIT), but it's not a named firm.

No named frameworks or specific facts from the IS list, so this falls into Generic Boilerplate.


reasoning: The paragraph's primary subject is the Board of Directors and its committees overseeing cybersecurity risk, with delegation described across multiple named committees. The Technology and Innovation Committee and Governance Committee are non-generic, firm-specific committee names (beyond the standard Audit Committee), qualifying as Firm-Specific. Named committees do not count toward QV thresholds.

thinking:
Let me analyze this paragraph.

Content: Board/committee oversight of cybersecurity risks, delegation to committees, specific named committees.

Category: Board Governance - the Board and its committees are the grammatical subjects performing oversight.

Specific facts:
- Technology and Innovation Committee (named non-generic committee) ✓
- Governance Committee (named non-generic? Actually "Governance Committee" is fairly standard... but it's a specific named committee beyond just "Audit Committee")
- ERM program mentioned but generic

Wait - "Audit Committee" is on the NOT list. But "Technology and Innovation and Governance Committees" - these are named non-generic committees per the IS list.

The Technology and Innovation Committee qualifies as firm-specific, but named committees themselves don't count toward QV, so this falls under Firm-Specific (3).

fact: Technology and Innovation Committee

fact: Governance Committee


reasoning: The paragraph makes an explicit materiality assessment ('not aware of any material risks... that have materially affected the Company, its business strategy, results of operations or financial condition'), which per Rule 6 is Strategy Integration regardless of the appended cross-reference to Risk Factors. No firm-specific facts from the IS list are present — the date reference is to the filing itself, and the risk factor section titles are generic cross-references, not cybersecurity-specific details.

thinking: Materiality assessment paragraph with cross-reference.


reasoning: The paragraph opens with the CISO's reporting line and general experience, then pivots to describing the information security program's design — ensuring CIA, implementing controls aligned with industry guidelines, identifying threats, and detecting attacks. Applying the person-vs-function test, the bulk of the paragraph describes what the program does (function), not who the person is (credentials, background, career history). 'Extensive experience' is vague, not a substantive credential. The CISO title is a firm-specific fact from the IS list, and the GCSO reporting line adds organizational specificity, but there are no QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Let me analyze this paragraph carefully.

The paragraph has two main parts:
1. First sentence: About the CISO - reports to GCSO, has extensive experience. This is about the person (Management Role).
2. Second sentence: About the information security program - designed to oversee risk, ensure CIA, implement controls aligned with industry guidelines. This is about the function (Risk Management Process).

Person-vs-function test: If I remove "led by its Chief Information Security Officer ("CISO") who reports directly to the GCSO and has extensive experience," the paragraph still describes the program's purpose and design. The second sentence is entirely about the program/function.

The first sentence focuses on the CISO's reporting structure and background, while the second sentence carries the substantive content about what the program actually does. The paragraph structure opens with the person but the bulk of the description centers on the program's design and objectives—overseeing risk, maintaining the CIA triad, and implementing controls aligned with industry standards. The opening really does focus on the person—the CISO's reporting structure and background—but then the second sentence shifts entirely to describing what the program actually does. Since most of the substance is about the program's design and controls, Risk Management Process seems like the right category. For specificity, CISO is clearly on the list as a firm-specific detail, and the reporting line to GCSO adds another concrete organizational fact, though the vague language around "extensive experience" and "industry guidelines" doesn't give me much to work with.

fact: Chief Information Security Officer (CISO)

fact: Reports directly to the GCSO


reasoning: The paragraph opens by naming the Information Security Officer and noting 'over a decade' of experience, but the dominant content by volume describes program activities: simulations, tabletop exercises, annual employee training, and role-based specialized training. Applying the person-vs-function test, removing the ISO's title and experience leaves a coherent process description, indicating the paragraph is about the function rather than the person. Specificity is Firm-Specific because 'Information Security Officer' is a cybersecurity-specific title on the IS list, but 'over a decade' is too vague for a QV-eligible count, and no named frameworks, tools, firms, or specific dates appear.

thinking:
Let me analyze this paragraph carefully.

The paragraph starts by mentioning the Information Security Officer (ISO) and their responsibility, then mentions their experience, then shifts to describing the cybersecurity program activities (simulations, tabletop exercises, training).

**Content Category Analysis:**
- First two sentences: about the ISO role and experience → Management Role signals
- But then the paragraph shifts to program activities: simulations, tabletop exercises, employee training
- Person-vs-function test: If I remove the ISO's title and experience, the paragraph still describes a cybersecurity program with simulations, exercises, and training requirements.

The paragraph is mixed.

The first two sentences focus on the person—their role and their decade of experience—but then the bulk of the content pivots to describing what the program actually does: the simulations, exercises, and training initiatives. By volume, the program activities dominate, even though the ISO's credentials frame the opening. When I apply the person-versus-function test, removing the ISO's name and background doesn't change the core message about what the cybersecurity program entails. So the dominant category here is the Risk Management Process, since that's where most of the text is spent. the role holder's name, title, qualifications, and background from the paragraph and the remaining content still describes substantive cybersecurity activities, processes, or oversight → the paragraph is about the function"

If I remove "The Corporation's Information Security Officer" and "has over a decade of experience leading cyber security oversight, and others on our IT security team have cybersecurity experience or certifications" — the remaining content is about simulations, tabletop exercises, training programs. Yes, it still describes substantive activities.

But this is a close call. The first two sentences are clearly about the person/team. Let me assess by volume: ~2 sentences about the person/team, ~3 sentences about the program. The dominant content is the program.

Actually, I think this is a borderline case. The paragraph does dedicate meaningful space to the ISO's qualifications. But the dominant purpose shifts to describing the program. I'll go with **Risk Management Process** but with moderate confidence.

Let me reconsider once more. The paragraph opens with the ISO, describes their role and experience, mentions team certifications, then describes program activities. It's genuinely split. But by the dominant category rule, the program activities—simulations, tabletop exercises, three types of training—occupy more text.

**Risk Management Process** it is.

Looking at specificity: "Information Security Officer" is a cybersecurity-specific title that belongs on the IS list, making this Firm-Specific. The experience descriptor is vague without concrete numbers, and the certifications aren't named. The program elements like tabletop exercises and simulations are common practices, not list items. There are no named frameworks, tools, specific dates, or dollar amounts.

So I have one hard fact—the ISO title—which qualifies as Firm-Specific. The vagueness of "over a decade" and lack of named certifications or tools means this doesn't meet the Quantified Verification threshold.

fact: Information Security Officer (cybersecurity-specific title)


reasoning: The paragraph opens with an explicit materiality assessment ('have not yet experienced any material impacts from a cyber-attack') and then discusses potential business/financial consequences (loss of trust, reputation, litigation, regulatory costs). Per Rule 6, the materiality assessment makes this Strategy Integration. The remainder is hypothetical risk-factor language about future financial impacts and compliance costs. No named frameworks, specific facts, or firm-specific details appear — all language is generic boilerplate applicable to any company.

thinking:
Let me analyze this paragraph.

Content: Discusses potential future impacts of cyber-attacks (loss of trust, key employee departures, reputation damage, financial losses, litigation, regulatory liability) and mentions evolving market dynamics driving cybersecurity standards compliance costs.

Category: This is about business/financial consequences of cyber risk. It includes a materiality-adjacent statement ("have not yet experienced any material impacts") and discusses potential financial/strategic impacts. The materiality assessment at the start ("have not yet experienced any material impacts from a cyber-attack") makes this Strategy Integration per Rule 6. The rest discusses potential business impacts and costs.

Wait - let me reconsider.

The opening statement "have not yet experienced any material impacts from a cyber-attack" is a direct materiality assessment, which triggers Strategy Integration classification. The paragraph then pivots to discussing hypothetical future impacts and compliance costs, but that materiality determination at the beginning is what drives the categorization. As for specificity, there are no named frameworks or concrete facts from the IS list—just generic language about potential business consequences. → Strategy Integration, Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity training and awareness processes — mandatory training, phishing campaigns, end-user testing — making it Risk Management Process. Despite mentioning a 'Cybersecurity Awareness eCourse' and 'Information Security policies,' these are generic program names without unique identifiers. Phishing simulations and security awareness training are on the NOT list as common practices. No named frameworks, tools, firms, dates, or quantified facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes employee training program, phishing campaigns, security awareness. This is about internal processes.

Category: Risk Management Process - describes internal cybersecurity processes (training, phishing campaigns, testing).

Specificity: Let me check for specific facts.
- "Cybersecurity Awareness eCourse" - this is a named internal program. Does it have a unique identifier? It's a specific course name but fairly generic.
- "Information Security policies" - generic
- Phishing awareness campaigns - common practice (NOT list)
- Training program - generic

- The course name lacks a distinguishing abbreviation or identifier like the codebook examples, so it doesn't meet the threshold for a named internal program. Phishing simulations and security awareness training are standard practices that fall on the NOT list anyway.

This is Generic Boilerplate.


reasoning: This paragraph is generic risk acknowledgment language listing reasons the company faces cybersecurity threats (geographic scope, system complexity, state-sponsored actors, third-party dependencies). It describes no processes, no governance structure, no incident, and makes no materiality assessment — it is general business language about why cyber risks exist, not substantive cybersecurity disclosure content.

thinking:
Classify this paragraph.

This is generic risk language about cybersecurity threats. No specific processes, no materiality assessment, no incident, no board/management details. It's essentially saying "we face cyber risks because of X, Y, Z" - all generic reasons.

Content category: This is general risk language. No materiality assessment ("materially affected"), no process description, no governance. It's just acknowledging cybersecurity risks exist. This feels like None/Other or possibly Risk Management Process context. But it doesn't describe any process. It's not a materiality disclaimer (no "materially affected" language). It's generic risk acknowledgment language.

The references to third-party products and state-sponsored organizations are too generic to be meaningful, and even the capitalized "Clients" is just standard company terminology. This is boilerplate risk language that could apply to almost any organization, with no named standards or specific facts to anchor it - definitely None/Other.


content_category: Incident Disclosure

reasoning: The paragraph primarily describes an actual cybersecurity incident — unauthorized access to 23andMe.com user accounts in October 2023 — and the remediation actions taken (password resets, two-factor verification, SOC enhancements). The materiality mention and cross-reference are secondary. Two QV-eligible hard facts: a specific date (October 2023) and a named product/system (23andMe.com).

thinking:
Let me analyze this paragraph.

Content: Describes a cybersecurity incident in October 2023 involving unauthorized access to user data from 23andMe.com accounts, followed by remediation actions (password resets, two-factor verification, new tools), and a forward-looking risk statement.

Category: This is primarily about an actual cybersecurity incident - what happened, when, and response actions taken. The dominant content is incident narrative and response. → Incident Disclosure

Specific facts:
- "October 2023" - specific date
- "23andMe.com" - named system/product
- Two-factor verification, password resets, SOC enhancements - these are response actions (generic practices)

- Both the date and product name are verifiable and specific, so this qualifies as Quantified-Verifiable.

fact: October 2023


reasoning: The paragraph's primary communicative purpose is materiality assessment — it opens with an explicit materiality conclusion, describes the March 2020 ransomware incident in service of that assessment, then repeatedly evaluates whether consequences are 'reasonably likely to have a material adverse effect.' The incident narrative is substantial but subordinate to the overarching materiality framing. Per Rule 6 and the tiebreaker (past incident + materiality conclusion as main point → Strategy Integration). Specificity is Firm-Specific: 'March 2020' is a specific date (one QV-eligible fact), but only one hard verifiable fact prevents reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

This is a complex paragraph that contains multiple elements:

1. A materiality assessment ("have not identified risks... that have materially affected or are reasonably likely to materially affect us")
2. A description of an actual incident (March 2020 ransomware attack)
3. Discussion of potential consequences of that incident
4. A cross-reference to Risk Factors

The paragraph starts with a materiality disclaimer, then describes a specific past incident (March 2020 ransomware attack), discusses what happened (access to IT systems, confidential information stolen), potential consequences, and ends with a cross-reference.

The key tension here is whether this is primarily an incident disclosure with substantial narrative detail, or a materiality statement that happens to reference an incident. The paragraph contains significant specifics about what occurred—the date, the ransomware attack itself, which systems were accessed, how the company responded, and what was potentially compromised—but it's all framed within a materiality assessment. The opening and closing both emphasize the materiality conclusion, which suggests that's the main point, even though the incident narrative is quite detailed. The incident narrative takes up substantial space here, making this a close call, but the materiality conclusion really is the main point—the paragraph opens and closes with it. I'm going with Strategy Integration. For specificity, I've got one QV-eligible fact: the March 2020 date. No named firms, dollar amounts, or headcounts, so this isn't QV. The date makes it Firm-Specific.

fact: March 2020 ransomware attack


reasoning: The paragraph's dominant focus is board and audit committee oversight: the board adopted a named cybersecurity policy, directors have cybersecurity expertise, the audit committee oversees ERM including cyber risks, and the board receives updates. The CTO is mentioned primarily in the context of reporting to/briefing the board, making the board the primary actor. While the CTO's 25 years of experience is noted (one QV-eligible fact), there is no second QV-eligible hard fact (named roles and named policies don't count toward QV), so specificity is Firm-Specific based on the CTO title, named policy, and quantified experience.

thinking:
Let me analyze this paragraph carefully.

This is a multi-topic paragraph covering board governance, management role, and risk management. Let me identify the dominant category.

Content breakdown:
1. Board adopted a Cyber Security and Personal Data Breach Policy - Board Governance
2. CTO oversees cybersecurity program, reports to CEO, briefs audit committee and board - Management Role (CTO is subject) / Board Governance
3. CTO has over 25 years of experience - Management Role
4. Directors have cybersecurity experience - Board Governance

5. Board receives updates/training - Board Governance
6. Audit committee oversees ERM including cyber risks - Board Governance
7. Audit committee receives assessment updates from outside advisors - Board Governance

The pattern is clear: while the CTO's role and experience are mentioned, the bulk of the content focuses on how the board and audit committee provide oversight through policy adoption, regular updates, training, and external advisor engagement. The CTO functions primarily as a reporting mechanism to these governance bodies rather than as the central focus.

Category: **Board Governance** - The board and audit committee are the primary actors throughout most of the paragraph. The CTO mention is subordinate to the board oversight framing.

Specific facts:
- "Cyber Security and Personal Data Breach Policy" - named internal program with unique identifier

Now I'm checking the CTO against the IS list and evaluating what qualifies as QV-eligible. The CTO title appears on the list, but the "over 25 years" of experience is the only quantified fact that could be QV-eligible. Since there's just one QV-eligible fact, this doesn't meet the QV threshold. The firm-specific elements are the CTO title, the named policy, and the years of experience combined.

fact: Cyber Security and Personal Data Breach Policy (named internal policy)

fact: Chief Technology Officer oversees cybersecurity program

fact: Over 25 years of professional experience (CTO)


reasoning: The paragraph is about the people filling cybersecurity leadership roles — their qualifications, years of experience, certifications, and reporting lines (CISO reports to Director of IT). This is squarely about the persons, not the function. Multiple QV-eligible hard facts: 30 years of experience, 21 years of experience, and certified CISO certification.

thinking:
Let me analyze this paragraph.

Content: Describes the Director of IT and a third-party CISO - their qualifications, experience, certifications, reporting lines. This is about the people, not the function.

Category: Management Role - the paragraph is about who these people are, their qualifications, experience, reporting structure.

Specific facts:
- Director of Information Technology (cybersecurity-specific? It's "Director of IT" which is on the NOT list as generic IT leadership. Hmm, but looking at the IS list: "Director of IT Security" is listed. "Director of Information Technology" is more general IT, not cybersecurity-specific.

The NOT list confirms "Head of IT", "IT Manager", "Director of IT" are generic IT leadership, so Director of Information Technology falls there.
- Third-party CISO - CISO is on the IS list as cybersecurity-specific title
- 30 years of experience - quantified, specific number
- 21 years of experience - quantified, specific number
- Certified CISO - named certification

So I've got at least two quantified-verifiable facts here: the specific years of experience and the named certification. That makes this Quantified-Verifiable.

fact: Third-party CISO role

fact: Over 30 years of IT management, cybersecurity, and information governance experience (Director of IT)

fact: 21 years of cybersecurity, IT management, and infrastructure consulting experience (CISO)

fact: Certified CISO


reasoning: The paragraph primarily describes the Cybersecurity Program's notification/escalation procedures and the process for reviewing incidents for 8-K disclosure materiality. While the Audit Committee and Board appear as recipients/participants, the grammatical subject of the first two sentences is the program and management conducting the process. The final sentence about a board member's IT experience is a subordinate detail. No facts from the IS list are present — 'Audit Committee,' 'Board of Directors,' and 'management' are all generic governance terms, and no cybersecurity-specific roles, named frameworks, dates, tools, or firms appear.

thinking:
Let me analyze this paragraph carefully.

The paragraph has three distinct parts:
1. Notification/escalation procedures for cybersecurity threats with severity thresholds
2. Materiality assessment process for incidents (8-K disclosure consideration)
3. A board member has IT experience in mortgage platform

The first part describes the Cybersecurity Program's notification and escalation procedures - this is Risk Management Process territory. But the notification goes to management, Audit Committee, and Board - touching on governance.

The second part discusses materiality assessment for 8-K disclosure - this could be Strategy Integration or Risk Management Process.

The third part mentions board member expertise - Board Governance.

So the core of this is really about the incident handling and escalation procedures built into the Cybersecurity Program, with the materiality assessment woven in as part of that process, and then a separate note about board expertise. The dominant theme is the procedural framework for managing and disclosing incidents. about the Cybersecurity Program's notification and escalation procedures, with the board and Audit Committee serving as participants in the review process rather than primary actors. The materiality assessment for disclosure decisions is procedural in nature, so this leans toward Risk Management Process as the dominant category.

Now I'm checking the specificity of the language used throughout. The paragraph relies heavily on generic references—the Cybersecurity Program itself, the Audit Committee, the Board of Directors, and the company's self-reference are all non-specific. The filing reference to Item 1.05 of Form 8-K is standard regulatory language, and the severity thresholds mentioned are described generically without concrete examples. There are no named frameworks, specific dates, named roles from the IS list like CISO or CTO, named tools, or specific numerical metrics anywhere in the text.


reasoning: The Board and Audit Committee are the grammatical subjects throughout — reporting to the full Board, receiving briefings, receiving presentations, and having cybersecurity experience. This is squarely about board-level oversight of cyber risk. The CTO is mentioned as a presenter to the Board (subordinate detail), not as the primary actor. Specificity is Firm-Specific because CTO is a cybersecurity-specific title on the IS list, but no second hard verifiable fact exists to reach QV.

thinking:
Let me analyze this paragraph.

Content: The paragraph discusses the Audit Committee reporting to the Board, the Board receiving briefings from management, board members receiving presentations from the CTO and others, and Audit Committee members having cybersecurity experience. The primary actor throughout is the Board/Audit Committee - this is about board-level oversight.

Category: Board Governance - the Board and Audit Committee are the grammatical subjects throughout.

Specificity: Let me check for specific facts:
- "Audit Committee" - generic, on the NOT list
- "Board" - generic

- "CTO" - this is on the IS list as a cybersecurity-specific title
- "internal security staff or external experts" - generic
- No dates, no dollar amounts, no named firms, no named frameworks

CTO is the only concrete detail here, so this qualifies as Firm-Specific (3) rather than Quantified Value.

fact: Chief Technology Officer (CTO)


reasoning: This is general business language stating that cybersecurity is important for commercial success. It contains no substantive cybersecurity disclosure — no description of governance, processes, incidents, strategy, or management roles. It reads as introductory or contextual framing rather than a disclosure fulfilling any specific SEC requirement.

thinking:
Classify this paragraph.

This is generic language about cybersecurity being important to the company. No specific processes, frameworks, roles, dates, or any substantive disclosure content.

It's essentially saying "cybersecurity is important to us" - no disclosure of any program, governance, incident, or strategy.

This could be a Strategy Integration (business impact) or None/Other. Let me think... It's saying commercial success depends on cybersecurity - that's a general business statement. There's no materiality assessment, no specific program description, no governance detail. It's generic business language mentioning cybersecurity incidentally.

This lands in None/Other - it's just boilerplate language without any real cybersecurity disclosure substance.


reasoning: The paragraph describes an actual cybersecurity incident — a ransomware attack in late May 2023 — along with response actions (investigation, engaging experts, law enforcement). The specific date (late May 2023) qualifies as a firm-specific fact, but no named third-party firms, tools, or other hard verifiable facts are present (experts and advisors are unnamed), so it does not reach Quantified-Verifiable.

thinking:
Incident disclosure - describes a real ransomware attack with timing and response actions.

Specific facts: "late May 2023" - specific date. "ransomware attack" - describes nature. But no named firms, no named tools.

"late May 2023" is a specific date (month+year). That's one fact from the IS list.

No named third-party firms (just "cyber-security experts and outside advisors"), no named tools, no dollar amounts, no headcounts.

One specific fact → Firm-Specific.

fact: late May 2023

fact: ransomware attack


reasoning: The paragraph is a bullet-point list of the company's internal cybersecurity processes—vulnerability scans, penetration testing, employee training, incident response planning, and third-party risk management. Third-party risk is one item among many, so Risk Management Process dominates. All items are common practices (vulnerability scans, phishing simulations, tabletop exercises) with no named frameworks, no named tools/firms, no cybersecurity-specific roles, and no specific dates or numbers—everything on this list appears on the ✗ NOT list.

thinking:
Classify this paragraph.

This is a bullet-point list describing internal cybersecurity processes: vulnerability scans, penetration testing, external service providers for security controls, training, incident response plan, third-party risk management. The dominant topic is the company's own internal risk management processes.

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

Third-party risk is mentioned but as one component among many internal processes.

Specificity: Let me check the facts:
- vulnerability scans, penetration testing → common practices (NOT list)
- external service providers → unnamed (NOT list)
- cybersecurity awareness training → common practice (NOT list)

- incident training, phishing simulations, and tabletop exercises → standard practices without specific details (NOT list)
- cybersecurity incident response plan and third-party risk management process → generic program names (NOT list)

No named frameworks, specific roles, or concrete facts from the IS list present. This is Generic Boilerplate (1).


reasoning: The paragraph describes the company's internal cybersecurity processes — ongoing education, monitoring, security measures, system audits, penetration testing, and incident response planning. The CIO is mentioned as attribution for who leads/oversees these activities, but the substantive content is about the function, not the person. Removing the CIO references, the paragraph still describes processes. CIO is a cybersecurity-specific title on the IS list, providing one firm-specific fact, but no second hard verifiable fact for QV.

thinking:
Let me analyze this paragraph.

Content: Describes the CIO leading the cybersecurity team, ongoing education, monitoring processes, security measures, audits, penetration testing, incident response plan.

Category: The CIO is mentioned as attribution, but the paragraph is about what the team/program does - monitoring, security measures, audits, penetration testing, incident response. Apply person-vs-function test: remove "The CIO leads" and "The CIO implements and oversees" - the paragraph still describes processes. → Risk Management Process.

Specificity:
- CIO is a cybersecurity-specific title per the IS list → Firm-Specific

- No named frameworks, tools, dates, or amounts mentioned, just the one IS-list fact about the CIO role, so this stays Firm-Specific with a QV score of 3 since there aren't two hard verifiable facts to check.

fact: CIO leads cybersecurity team


reasoning: The paragraph is entirely about the people filling the cybersecurity leadership role — the departed VP, the interim IT Manager, and the search for a replacement. This is about the persons and their qualifications/tenure, not about what the program does. Two QV-eligible hard facts: a specific date (February 25, 2025) and a specific duration (two years).

thinking:
Let me analyze this paragraph.

Content: Describes leadership transition - VP of Compliance and IT left, IT Manager serving interim, seeking replacement. This is about the people filling cybersecurity leadership roles.

Category: Management Role - it's about who holds the cybersecurity leadership position, their experience, reporting structure, and transition.

Specific facts:
- "Vice President of Compliance and Information Technology" - named role (cybersecurity-specific? It's VP-level overseeing information security/IT)
- "IT Manager" - this is generic IT title per the NOT list

- "February 25, 2025" - specific date
- "two years supporting the cybersecurity function" - specific duration

The VP role qualifies as information security leadership on the IS list, while the IT Manager is generic per the NOT list. I've got two quantified-verifiable elements here: the specific date and the two-year duration, so this would be QV-eligible.

The VP of Compliance and Information Technology title is also firm-specific and cybersecurity-focused, which means this entry qualifies as both a management role and quantified-verifiable.

fact: February 25, 2025


reasoning: The paragraph describes an actual cybersecurity incident — a ransomware attack in late May 2023 — along with response actions (investigation, engaging experts, law enforcement), making it Incident Disclosure. Only one hard verifiable fact exists (the specific date); 'cybersecurity experts and outside advisors' and 'law enforcement' are unnamed/generic per the NOT list, so specificity is Firm-Specific rather than Quantified-Verifiable.

thinking:
Classify this paragraph.

Content: Describes a ransomware attack in late May 2023, response actions taken.

Category: Incident Disclosure - describes what happened (ransomware attack), when (late May 2023), and response actions (investigation, engaged experts, law enforcement).

Specificity:
- "late May 2023" - specific date (month+year) → 1 fact
- "ransomware attack" - describes the type but not a named tool/firm
- "cybersecurity experts and outside advisors" - unnamed entities (NOT list)
- "law enforcement" - standard incident language (NOT list)

- Only one hard fact (the date). No named firms, no named tools, no dollar amounts, no headcounts.

So: Firm-Specific (one specific date).


reasoning: The paragraph describes the qualifications, experience, and career backgrounds of two key people: the CIO (primarily responsible for cybersecurity risk management, with specific years of experience) and the Strategy Committee Chair (with detailed government cyber leadership background at CIA/ODNI). Both sections are fundamentally about the persons' credentials rather than about processes or board oversight mechanics, making Management Role the dominant category over Board Governance, though the Strategy Committee Chair section introduces board-level expertise. Multiple QV-eligible facts include specific years of experience ('nearly four decades,' 'nine years') and named, independently verifiable prior government positions.

thinking:
Let me analyze this paragraph carefully.

The paragraph is about two people: the CIO and the Strategy Committee Chair. It describes their qualifications, experience, and background. This is clearly about the persons, not the function.

Content Category: The paragraph describes the CIO's qualifications and experience, and the Strategy Committee Chair's background. The CIO is a management role. The Strategy Committee Chair sits on the board - this could be Board Governance. But the dominant content is about the people's credentials and backgrounds.

The CIO part is Management Role. The Strategy Committee Chair part - she's a board member (Strategy Committee Chair, sits on boards).

Looking at the next section, the Strategy Committee Chair's extensive government background is clearly relevant to board governance expertise. The paragraph really splits between two distinct roles: the CIO handling cybersecurity risk management, and the Strategy Committee Chair bringing board-level governance experience. Both sections focus on the individuals' qualifications, though the Chair gets more detailed treatment. role is the better fit because the Strategy Committee Chair gets substantially more detailed coverage, even though the CIO is mentioned first as primarily responsible. Both sections describe people's qualifications, but the longer treatment of board member expertise tips the balance toward Board Governance.

Actually, I'm going to stick with Management Role since the paragraph opens by establishing the CIO as the primary responsible party, and both the CIO and Strategy Committee Chair sections are fundamentally about identifying qualified people for cybersecurity roles. The Strategy Committee Chair's expertise serves as supplementary context rather than the main point.

Now I'm checking the specificity of the qualifications mentioned: the CIO has a cybersecurity-specific title, nearly four decades of IT experience, and nine years of infrastructure and cybersecurity leadership at the company. The Strategy Committee Chair is described with a named committee affiliation.

Looking at what qualifies as QV-eligible facts, I see "nine years" and "nearly four decades" as quantified durations, but the CIA reference is a government agency rather than a third-party firm, so that distinction matters for the QV framework.

The two clear QV facts are the specific years of experience mentioned—nearly four decades in IT and nine years in cybersecurity leadership. I should also check if the Strategy Committee Chair's background adds more QV-eligible details, particularly those government titles which are verifiable facts even if they're not quantified metrics.

fact: Chief Information Officer (CIO)

fact: Nearly four decades of overall IT experience

fact: Nine years of infrastructure and cybersecurity leadership at the Company

fact: Strategy Committee Chair

fact: Nearly four decades of technical and organizational leadership experience (Strategy Committee Chair)

fact: Previously held position as Principal Deputy Director of National Intelligence

fact: Previously Senior Advisor to the Director for Cyber and Director of Information Operations for the CIA


reasoning: The Nominating and Governance Committee is the grammatical subject receiving reports and accessing cybersecurity materials, making this Board Governance. The named non-generic committee and CISO role are firm-specific facts, but neither is QV-eligible (no dates, amounts, named firms, or tools), so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph.

The grammatical subject is the Nominating and Governance Committee (a board committee) receiving reports and having access to materials. This is about board-level oversight.

Category: Board Governance - the committee is the subject performing oversight activities.

Specific facts:
- "Nominating and Governance Committee" - this is a named non-generic committee (not just "Audit Committee")
- "CISO Information Security" - cybersecurity-specific role

Neither of these are QV-eligible. No dates, dollar amounts, headcounts, named firms, named tools, or named certifications. So not QV.

Both items appear on the IS-list, which makes this Firm-Specific.

fact: Nominating and Governance Committee

fact: CISO Information Security


reasoning: The paragraph is about the people — their roles, qualifications, years of experience, and certifications — making it Management Role under the person-vs-function test. Multiple QV-eligible hard facts are present: specific years of experience (25+ and 15+) and a named certification (CISSP), yielding at least two verifiable facts for Quantified-Verifiable.

thinking:
Let me analyze this paragraph from Sotera Health Co's 10-K filing.

Content: Describes the CIO, Senior Director of IT Governance, Senior Director of Global Infrastructure, and Senior Information Security Architect - their responsibilities and qualifications. This is about the people - their experience, credentials, and roles.

Category: Management Role - the paragraph is about WHO these people are, their experience levels, and certifications. The person-vs-function test: if you remove the people and their qualifications, there's very little left. The paragraph is about the persons.

Specific facts:
- CIO (cybersecurity-specific title) ✓

- Senior Director of IT Governance, Service Delivery ✓ (cybersecurity-specific role)
- Senior Director of Global Infrastructure ✓
- Senior Information Security Architect ✓ (cybersecurity-specific role)
- "over 25 years of professional experience" - quantified
- "over 15 years of collective experience" - quantified
- CISSP certification - named certification

QV check: The team has over 25 years of professional experience and over 15 years of collective experience, with at least one CISSP certification mentioned - that's multiple hard verifiable facts.

fact: Senior Information Security Architect

fact: over 25 years of professional experience (average)

fact: over 15 years of collective experience at public companies

fact: CISSP certification


reasoning: The paragraph's primary purpose is describing the management oversight structure: the ISMS Governance Committee, who co-chairs it (interim CSO and DPO), its alignment with the Data Protection Governance Committee, and reporting lines to the audit committee. While it mentions what the committee does (review risks, evaluate treatments, monitor remediation), these activities are subordinate to the organizational structure description — committee composition and reporting lines are the dominant content, fitting Management Role. Multiple firm-specific facts (cybersecurity-specific roles, named non-generic committees) place this at Firm-Specific, but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms/tools) reach the two-fact threshold.

thinking:
Let me analyze this paragraph.

Content category: This describes a management-level governance structure. The ISMS governance committee, interim CSO, DPO, their roles and reporting. The grammatical subjects are the governance committee and the interim CSO/DPO. This is about management structure and oversight functions.

Person-vs-function test: The paragraph describes what the committee and roles DO (drive awareness, co-chair, review risks, evaluate treatments, monitor remediation, report to audit committee). It's about the function/process, not about the persons' qualifications or backgrounds. However, the primary framing is organizational structure - who oversees what, committee composition, reporting lines.

The heading "Management Oversight" confirms this is about the organizational structure for cybersecurity governance. The paragraph outlines the ISMS governance committee composition with the interim CSO and DPO as co-chairs, its alignment with the Data Protection Governance Committee, and its responsibilities around risk review, treatment evaluation, and remediation monitoring, with reporting to the audit committee. This is fundamentally about management structure and oversight mechanisms rather than specific risk management processes. I'm identifying the specific roles and committees mentioned: interim CSO, DPO, ISMS Governance Committee, and Data Protection Governance Committee. Since there are no hard verifiable facts like dates or headcounts, this doesn't meet the QV threshold, but the presence of named roles and committees makes it Firm-Specific.

fact: interim CSO

fact: interim Data Privacy Officer (DPO)

fact: ISMS Governance Committee

fact: Data Protection Governance Committee


reasoning: The paragraph describes management-level cybersecurity risk committees and their composition, escalation paths, and reporting lines from the CIO and Head of Operational Risk to board-level committees. Per the codebook, management committees responsible for cybersecurity and reporting lines are Management Role content. The person-vs-function test is borderline—no personal credentials are given—but the primary content is organizational structure (who reports to whom through which committees), not process/methodology. Multiple named non-generic committees (Non-Financial Risk Committee, Firm Risk Committee, BOTC) and cybersecurity-relevant roles (CIO, Head of Operational Risk) place this at Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named third-party firms, etc.) are present.

thinking:
Let me analyze this paragraph carefully.

Content: Describes management-level cybersecurity risk committees at Morgan Stanley, their composition, escalation paths, and reporting to various committees and boards. The CIO and Head of Operational Risk report to various committees. This is about the organizational structure of cybersecurity oversight.

Category analysis:
- This describes management committees and their functions, escalation paths, reporting lines
- The grammatical subjects are committees, CIO, Head of Operational Risk
- It's about the organizational structure - who reports to whom, what committees exist
- The CIO and Head of Operational Risk are management roles reporting up

- The paragraph focuses on the governance structure itself—how risks flow through management committees and escalate upward—rather than on the individuals holding these roles. The CIO and Head of Operational Risk function primarily as conduits for reporting within this oversight framework, and the board appears as the ultimate recipient of these escalated risks. the CIO and Head of Operational Risk to board-level committees. This is Management Role.

Now I'm identifying which facts qualify as IS list items. The CIO is a cybersecurity-specific title, and I've got several named committees here—Non-Financial Risk Committee, Firm Risk Committee, and BOTC. The Head of Operational Risk is also a specific role title. None of these facts have dates, dollar amounts, headcounts, or third-party references, so they don't qualify for QV eligibility.

fact: CIO

fact: Head of Operational Risk

fact: Non-Financial Risk Committee

fact: Firm Risk Committee

fact: BOTC (Board committee acronym)


reasoning: The EROC (a named, non-generic committee) is the grammatical subject overseeing cybersecurity risk and receiving reports — classic Board Governance. The EROC qualifies as a firm-specific fact (non-generic committee), but the rest of the paragraph (regular presentations, vulnerability assessments, third-party reviews, threat environment) is generic language, so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: The EROC (a committee) oversees ERM including cybersecurity. It receives presentations on the Information Security Program covering various topics.

Category: The grammatical subject is "The EROC" - a committee. This is board/committee oversight of cyber risk. EROC = Enterprise Risk Oversight Committee - a named non-generic committee. → Board Governance

Specificity:
- "EROC" - named non-generic committee (Enterprise Risk Oversight Committee) → IS fact
- "Information Security Program" - generic program name? It's just "Information Security Program" without a unique identifier/abbreviation beyond the generic.

The Information Security Program lacks any distinguishing abbreviation or identifier, so it's generic. There are no named frameworks, dates, dollar amounts, named firms, tools, or headcounts mentioned. With just the one IS fact from EROC being a named committee, this rates as Firm-Specific (3), and there are no QV-eligible facts present.

fact: EROC (Enterprise Risk Oversight Committee) — named non-generic committee


reasoning: The paragraph establishes who is responsible for cybersecurity (the management team) and describes their general qualifications ('prior work experience in highly-regulated industries') and the expertise areas of their personnel. This is about the people and their credentials, not about specific processes or tools, making it Management Role. However, no cybersecurity-specific titles (CISO, CIO, CTO), named individuals, named firms, frameworks, dates, or quantified facts appear — everything is generic and interchangeable across companies.

thinking:
Let me analyze this paragraph.

Content: Describes management team's responsibility for cybersecurity, their experience, and internal/external personnel expertise areas.

Category: This is about management's role but uses the person-vs-function test. The paragraph describes "management team" generically - no named roles (no CISO, CTO, CIO), no named individuals, no specific credentials. It talks about what the team does (assesses, manages, supervises) and vaguely about their background ("prior work experience in highly-regulated industries").

The paragraph is somewhat about the people (their experience) but also about the function. There's no specific person identified - it's "our management team." The content describes responsibilities and general qualifications.

The focus here is on establishing who's responsible and their qualifications rather than describing specific processes or frameworks. The paragraph mentions experience in regulated industries and references to both internal staff and external consultants, but everything remains generic without named individuals or specific credentials. This points toward Management Role as the category.

Specificity: All references are generic - "management team," "internal cybersecurity personnel," "retained external cybersecurity consultants," and "highly-regulated industries" - with no concrete details about actual people or their specific qualifications.


reasoning: The paragraph describes the company's internal risk management framework and its guidelines for identifying and estimating costs of protective measures — a process description. It contains no named frameworks, roles, tools, dates, or any firm-specific details, making it generic boilerplate that could appear in any company's filing.

thinking:
Classify this paragraph.

Content: Describes risk management framework with guidelines for identifying and estimating costs of protective measures. This is about internal processes.

Category: Risk Management Process - describes the company's risk management framework and what it includes.

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


reasoning: The board of directors is the grammatical subject performing oversight of cybersecurity risk, both directly and through the audit committee, making this Board Governance. No specific facts from the IS list are present — 'board of directors,' 'executive officers,' and 'audit committee' are all generic governance terms that appear in virtually every public company filing.

thinking:
Classify this paragraph.

The paragraph discusses board oversight of cybersecurity risk, mentioning the board administers oversight directly and through the audit committee. The board is the grammatical subject.

Content category: Board Governance

Specificity: No named frameworks, no cybersecurity-specific roles (just "executive officers" which is generic), "audit committee" is generic. Nothing on the IS list. → Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity program design and employee security awareness training (exercises, simulations, attestation). These are internal processes, making it Risk Management Process. No named frameworks, cybersecurity-specific roles, or other IS-list facts are present; 'Technology Acceptable Use Policy' is a generic program name, and 'quarterly'/'annual' are generic cadences.

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity program design, objectives, and employee training. This is about internal processes - risk management.

Category: Risk Management Process - describes internal cybersecurity processes, training, awareness programs.

Specificity: Let me check for specific facts.
- "quarterly exercises" - generic cadence
- "cyber-event simulations" - common practice
- "training programs" - generic
- "Technology Acceptable Use Policy" - this is a named internal program/policy. Does it have a unique identifier? It's "Technology Acceptable Use Policy" - this is fairly generic name, not a unique identifier like "CIRP".

The Technology Acceptable Use Policy is a common program name that many companies have, and the codebook indicates generic program names don't count as specific facts. Combined with the lack of named frameworks, specific roles, dates, or tools, this looks like generic boilerplate.


reasoning: The paragraph describes the company's incident response and vulnerability management escalation processes — who gets notified, how mitigation works, and reporting lines. The CISO and Nominating and Governance Committee are mentioned as participants in these processes, but the primary content is about the function (escalation and reporting workflows), not about the people. The Nominating and Governance Committee is a non-generic committee (IS-list item), and CISO is a cybersecurity-specific title, yielding Firm-Specific. Neither qualifies as QV-eligible.

thinking:
Let me analyze this paragraph.

Content: Describes incident response and vulnerability management processes, escalation procedures, mentions CISO, Nominating and Governance Committee.

Category: This is about the company's internal processes (incident response, vulnerability management, escalation). The CISO is mentioned as part of the escalation chain, not as the primary subject. The Nominating and Governance Committee is mentioned in context of reporting. The primary content is about processes - escalation, mitigation, remediation, reporting. → Risk Management Process

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

- Nominating and Governance Committee (named non-generic committee) → IS list ✓

Both are named entities rather than generic roles or committees, so neither qualifies for QV eligibility. Since both appear on the IS list, this is classified as Firm-Specific.

fact: CISO


reasoning: The board of directors is the grammatical subject performing oversight and receiving reports, making this Board Governance. The paragraph names a 'cybersecurity committee' — a non-generic, cybersecurity-specific committee on the IS list — which elevates specificity to Firm-Specific. However, the remaining details (annual cadence, generic report topics) are boilerplate, and there are no QV-eligible hard facts.

thinking:
Let me analyze this paragraph.

Content: Board oversight of cybersecurity, receives annual reports from cybersecurity committee, covering updates on risks, projects, assessments, and threats.

Category: Board Governance - the board is the grammatical subject performing oversight, receiving reports.

Specificity: "cybersecurity committee" - is this a named non-generic committee? Yes, "Cybersecurity Committee" is on the IS list as a named non-generic committee. So at least Firm-Specific.

Any QV facts? No specific dates, dollar amounts, headcounts, named firms, named tools, named certifications.

The cadence here is "at least annually," which is generic language, so this stays at Firm-Specific level.

fact: cybersecurity committee


reasoning: The paragraph's primary subject is the Board and Audit Committee's oversight of cybersecurity risks, including delegation structure and briefing cadence. The CIO and CISO are mentioned as briefers to the committee, making them subordinate to the board governance frame. Two cybersecurity-specific roles (CIO, CISO) qualify as firm-specific facts but named roles don't count toward QV, so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Board delegates oversight to Audit Committee, CIO and CISO brief the Audit Committee quarterly, Audit Committee reports to Board quarterly.

Category: The board/Audit Committee is the primary subject - "Board of Directors has overall responsibility," "delegated primary oversight," "Audit Committee monitors." The CIO/CISO are mentioned in the context of briefing the board committee. This is Board Governance.

Specificity:
- CIO: cybersecurity-specific? The IS list includes CIO. Yes.

- CISO: yes, cybersecurity-specific title.
- "Audit Committee": NOT list item.
- "quarterly": generic cadence, NOT list.

I'm seeing two cybersecurity-specific titles here, but named roles like CIO and CISO are firm-specific and don't qualify toward the QV threshold, so this falls into the Firm-Specific category.

fact: Chief Information Officer (CIO)

fact: Chief Information Security Officer (CISO)


reasoning: The paragraph describes the operational impact and response actions of a specific cybersecurity incident (systems suspended, containment, restoration over a week, remediation concluded by a specific date), with financial details woven into the incident narrative. Because it describes what happened — not only financial costs — it meets Incident Disclosure rather than Strategy Integration. Multiple hard verifiable facts (two dollar amounts, two specific dates) clearly reach the QV threshold.

thinking:
Let me analyze this paragraph.

Content: Describes impact of a cybersecurity incident - systems suspended, restored over a week, costs of $1.0M net of insurance, remediation concluded December 30, 2023, insurance proceeds of $0.6M exceeding receivable in Q4 2024.

This paragraph describes what happened (systems suspended, restored) AND financial impact (costs, insurance). The dominant content is mixed - it describes both incident response actions and financial consequences. Let me apply the tiebreaker rules:

"Paragraph DESCRIBES what happened in an incident (dates, access, encryption, scope, response actions) → Incident Disclosure"

"Paragraph ONLY discusses financial cost, insurance, or materiality of an incident WITHOUT describing the event → Strategy Integration"

This paragraph covers both - it describes containment and restoration actions, then discusses costs and insurance. The financial details actually take up most of the space here (three of five sentences), but the incident response actions provide the framing. According to the tiebreaker, when an incident is described alongside costs, I should classify based on what's dominant. The financial impact is more prominent, but the paragraph still fundamentally describes what happened during the incident response.

Looking at this more carefully, the core content is about the operational impact and how it was resolved - systems were suspended, then restored over a week, remediation was completed by a specific date. The financial figures and insurance claim are embedded within that incident narrative rather than standing alone. Since the paragraph describes the actual event and response, not just the financial consequences in isolation, this should be Incident Disclosure.

Now I'm checking the specificity of the facts mentioned: there are hard dollar amounts ($1.0M and $0.6M), specific dates (December 30, 2023 and Q4 2024), and a timeframe reference. That's multiple quantified and verifiable facts, putting this in the highest specificity category.

fact: $1.0 million in incident-related costs net of insurance

fact: December 30, 2023 — remediation concluded

fact: $0.6 million in insurance proceeds exceeding receivable

fact: Fourth quarter of 2024 — insurance proceeds received


reasoning: The paragraph describes the company's internal cybersecurity processes — ERM integration, framework adoption, and third-party testing — making Risk Management Process the dominant category. The Cybersecurity Committee is mentioned as context for oversight but the primary subject is the processes themselves. Specificity is Firm-Specific because the 'Cybersecurity Committee' is a named non-generic committee (per the IS list), elevating beyond Sector-Adapted; however, there are not two QV-eligible hard facts to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes integration of cybersecurity processes into ERM, mentions frameworks (NIST, COSO, ISO 27001), mentions Cybersecurity Committee, and third-party consultants.

Category: This is about the company's internal cybersecurity processes - risk assessment, framework adoption, ERM integration. The Cybersecurity Committee is mentioned but as context, not as the primary subject. The primary topic is the processes themselves. → Risk Management Process

Specificity:
- Named frameworks: NIST, COSO, ISO 27001 → Sector-Adapted at minimum
- "Cybersecurity Committee" → This is a named non-generic committee (per the IS list) → Firm-Specific

- Third-party consultants are unnamed, so they don't add specificity

That gives me one IS fact with the Cybersecurity Committee, making this Firm-Specific (3). No QV facts are present—no dates, dollar amounts, headcounts, named firms, named tools, or named certifications.

fact: Cybersecurity Committee

fact: NIST

fact: COSO


reasoning: The entire paragraph is about the person — Drew Robertson's name, career history (NSA, US Army, Deputy CISO), appointment date, education, and advisory activities. This is squarely Management Role under the person-vs-function test. Specificity is Quantified-Verifiable with multiple hard verifiable facts: specific date (October 2021), named prior employers (National Security Agency, United States Army), and the named individual himself.

thinking:
Let me analyze this paragraph carefully.

Content: This paragraph names Drew Robertson as CISO, describes his background, experience, prior roles (NSA, US Army), education, and current activities. It's clearly about the person.

Category: Management Role — the entire paragraph is about who Drew Robertson is, his qualifications, career history, credentials, and background. The person-vs-function test confirms this.

Specificity: Let me count QV-eligible hard verifiable facts:
1. Named individual: Drew Robertson (named person)
2. "October 2021" - specific date
3. "National Security Agency" - named organization (third-party firm equivalent)

4. "United States Army" - named organization
5. "BA in Organizational Management" - generic degree without named university → NOT QV-eligible
6. "MS in Cybersecurity Policy" - generic degree without named university → NOT QV-eligible
7. "MBA" - generic degree without named university → NOT QV-eligible

So I have the specific date and two named organizations. Now I'm questioning whether government agencies like NSA and US Army count as "named third-party firms" for the QV criteria, since the definition mentions examples like Mandiant and CrowdStrike.

They're definitely named organizations where this person worked, and that's verifiable. The named individual Drew Robertson doesn't qualify on its own, but combining the October 2021 date with NSA and US Army gives me multiple hard verifiable facts that should meet the threshold.

fact: Drew Robertson (named individual)

fact: October 2021 (appointment as CISO)

fact: National Security Agency (prior employer)

fact: United States Army (prior employer)

fact: Deputy CISO (prior role)

fact: BA in Organizational Management, MS in Cybersecurity Policy, MBA (degrees without named university)


reasoning: The paragraph describes the company's own internal cybersecurity program including security monitoring, confidentiality/integrity goals, and a risk-based enterprise-wide risk assessment program. All content is about internal processes. No named frameworks, tools, roles, dates, or any facts from the IS list appear — every phrase is generic boilerplate that could appear in any company's filing unchanged.

thinking:
Classify this paragraph.

Content: Describes the company's internal cybersecurity program - risk assessment, security monitoring, confidentiality/integrity. No named frameworks, no specific roles, no dates, no tools.

Category: Risk Management Process - describes internal processes (security monitoring, risk assessment, ERM integration).

Specificity: No named frameworks, no specific facts from the IS list. Generic language throughout. → Generic Boilerplate (1).


reasoning: The paragraph describes management's organizational structure for cybersecurity oversight — two named committees (IT Operating Committee, IT Steering Committee), their compositions, meeting cadences, and responsibilities. While it details what these committees do, the primary communicative purpose is identifying the management-level structure and roles (Director of IT, CISO, committee memberships, reporting coordination with Audit Committee) rather than describing technical processes, tools, or frameworks. Multiple firm-specific facts (CISO, named non-generic committees, specific team compositions) establish Firm-Specific, but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools) are present.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph describes management-level committees and their roles in cybersecurity oversight. The grammatical subject is "The Director of Information Technology" and the committees. It's about organizational structure and processes.

The person-vs-function test: The paragraph mentions the Director of IT but doesn't describe their credentials, background, or qualifications. It describes what the committees DO - governance, risk management, compliance, reviewing reports, meeting quarterly. Remove the titles and the paragraph still describes processes and committee functions.

However, the primary focus is on the committee structure and oversight mechanisms. The Director of IT is the subject, but the content is about organizational structure (committees, their composition, meeting cadence, responsibilities).

So this is really about management organizational structure - the committees, their compositions, what they oversee, and how they coordinate - rather than about the individuals themselves or their qualifications. The committees' responsibilities—reviewing reports, plans, and policies—point toward Risk Management Process since it's about what these oversight functions actually do. But the paragraph's focus on committee composition, structure, and meeting cadence is fundamentally about how management is organized for cybersecurity, which lands this in Management Role. I'm settling on Management Role since the paragraph emphasizes the organizational framework itself.

Now I'm checking whether "Director of Information Technology" qualifies as a specific cybersecurity role—it's broader than "Director of IT Security," but they're clearly involved in cybersecurity risk oversight.

Looking at the firm-specific elements: CISO is a named role on the list, and both the IT Operating Committee and IT Steering Committee are named, non-generic committees unique to this firm. The meeting cadences (quarterly, monthly) are generic. There are no quantifiable facts like dates, dollar amounts, or headcounts, so nothing qualifies as QV-eligible. This gives me multiple firm-specific facts but no QV-eligible ones, so the classification is Firm-Specific.

fact: CISO

fact: Director of Information Technology

fact: IT Operating Committee

fact: IT Steering Committee

fact: Committee composition: Director of IT, CISO, and department heads (Operating); executives (Steering)


reasoning: The paragraph describes the company's internal escalation process for cybersecurity incidents — monitoring, evaluation, and escalation pathways. The CISO is mentioned as part of the escalation chain, but the paragraph is about the process/function, not the person. Applying the person-vs-function test: removing the CISO title, the paragraph still describes an escalation process. The CISO role is a cybersecurity-specific title on the IS list, providing one firm-specific fact.


reasoning: The paragraph describes the Adviser's incident response plan process — notification guidelines, escalation procedures, and reporting chains. The CISO is mentioned as a recipient of notifications, not as the primary subject; the paragraph is about the function (IRP process), not the person. The CISO title is a cybersecurity-specific role on the IS list, elevating specificity to Firm-Specific, but there is only one such fact (no QV-eligible pair).

thinking:
Let me analyze this paragraph.

Content: Describes an incident response plan developed by "the Adviser," including notification procedures, mentions CISO role, and escalation to audit committee/board.

Category: This is about the incident response plan - a process description. The CISO is mentioned as part of the notification chain, not as the primary subject. The person-vs-function test: remove the CISO mention and the paragraph still describes the IRP process. → Risk Management Process

Specific facts:
- CISO mentioned (cybersecurity-specific title) → IS list item
- "Audit Committee" → NOT list (generic)

- "incident response plan" → NOT list (generic program name)

Looking at specificity, the CISO is a cybersecurity-specific title, but it's a named role rather than a QV-eligible fact, so this lands in Firm-Specific (3).

fact: Chief Information Security Officer (CISO) named as part of incident notification chain


reasoning: The paragraph's primary communicative purpose is introducing the company's cybersecurity risk management approach — its commitment to processes, controls, and technologies to manage material risks. The VP of IT and Board/Audit Committee mentions are brief attributions within a broader framing paragraph dominated by generic threat descriptions and program overview. The VP of IT is a cybersecurity-specific title on the IS list, making this Firm-Specific, but there is no second QV-eligible hard fact.

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

Content: This paragraph covers multiple topics:
- Commitment to governance and oversight of cybersecurity risks
- VP of IT is responsible for information security program
- Board of Directors oversees risks, through Audit Committee
- Generic risk language about cyber threats (hacking, phishing, etc.)
- Brief mention of third-party vendors

The paragraph is primarily a general introduction to their cybersecurity section. It mentions the VP of IT role, board oversight, and then goes into generic risk language about cyber threats.

---

Looking at the structure more carefully, this reads like a Risk Management Process framing that opens with the company's commitment to governance and controls, assigns responsibility to the VP of IT, establishes board oversight through the Audit Committee, and then fills out the rest with standard language about potential cyber threats and their impacts.

The VP of IT is actually on the IS list as a specific role, so that's a firm-specific detail. The board and audit committee references are generic governance language. The third-party mention is brief. Overall, this is fundamentally about how the company approaches cybersecurity risk management, with the threat descriptions serving as context for why the program exists.

fact: Vice President of IT is responsible for Li-Cycle's information security program