reasoning: The entire paragraph describes two individuals — the CSO and CISO — detailing their educational backgrounds, years of experience, and prior roles. This is squarely about the persons and their qualifications, not about what any program does. Multiple QV-eligible quantified facts (25+ years twice, nearly 8 years) exceed the two-fact threshold.

thinking:
This paragraph describes two people: Apollo's CSO and Apollo's CISO, detailing their credentials, experience, and career history. This is clearly about the persons, not the function.

Content category: Management Role - the entire paragraph is about who these people are, their qualifications, education, experience, and prior roles.

Specific facts:
- CSO (cybersecurity-specific role)
- CISO (cybersecurity-specific role)
- "undergraduate degree in Management Information Systems and Business Administration" - generic degree without named university
- "magna cum laude" - distinction
- "over 25 years" of experience (quantified, QV-eligible)

- Several prior roles including Head of IT Risk Management, Executive Director of IT & Risk Compliance, Global IT Risk Evaluation Lead, and Director of Cybersecurity and Risk
- "nearly eight years" as CISO (quantified, QV-eligible)
- "master's degree in Business Information Systems" - generic degree without named university
- At least three QV-eligible facts: "over 25 years" appears twice and "nearly eight years" once

, all specific durations of experience

fact: CSO role

fact: CISO role

fact: over 25 years of cyber-related experience (CSO)

fact: nearly eight years as Apollo's CISO (CSO's prior tenure)

fact: over 25 years in IT and information security (CISO)


content_category: None/Other

category_confidence: medium

specificity_confidence: high

reasoning: This is a generic, hypothetical risk statement about potential operational disruption from cybersecurity incidents. It describes no actual incident, no process, no governance structure, and makes no materiality assessment — it is boilerplate risk language that could apply to any company. The numbered list format suggests it is part of a generic risk enumeration rather than substantive cybersecurity disclosure.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Classify this paragraph.

This is a generic risk statement about operational disruption from cybersecurity incidents. No actual incident, no specific details, no frameworks, no named entities. It's hypothetical risk language.

This is essentially generic risk language - could apply to any company. No materiality assessment language ("materially affected business strategy, results of operations, or financial condition"). It's just listing a potential consequence.

This looks like None/Other or possibly Strategy Integration. It's discussing potential business impact but in a very generic way. There's no materiality assessment. It's more like risk factor language. The numbered format suggests it's part of a list of risk types.

Since there's no substantive cybersecurity disclosure content—no process, governance, incident, or materiality assessment—this falls into None/Other.


content_category: Risk Management Process

category_confidence: high

reasoning: The paragraph describes internal cybersecurity processes — incident response, business continuity, and disaster recovery programs — including threat assessment, coordinated response, and periodic testing. All terms are generic (no named frameworks, tools, roles, dates, or firm-specific details), placing this squarely at Generic Boilerplate.

thinking:
Classify this paragraph.

Content: Describes incident response, business continuity, and disaster recovery programs - what they do (identify/assess threats, evaluate risk, coordinate response, periodic testing). This is about internal processes.

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

Specificity: No named frameworks, no named roles, no specific dates, no named tools. "Incident response, business continuity, and disaster recovery programs" are generic program names. "Periodic exercises and tests" is a generic cadence. Everything here is generic boilerplate.

Specificity: Generic Boilerplate (1)


reasoning: The paragraph describes the company's own internal cybersecurity strategy — employee training, policies across multiple domains, and engagement of third-party consultants for pen testing and assessments. Third parties are mentioned as a component serving the company's program (Rule 3), not as the central topic. No named frameworks, no named firms/tools, no cybersecurity-specific titles, no dates or numbers — all descriptions are common practices and unnamed entities, placing this at Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes the company's internal cybersecurity strategy - multi-layered approach, employee training, technologies, policies across various areas, and engagement of third-party consultants for pen tests and assessments.

Category: This is about the company's own internal processes - Risk Management Process. Third parties are mentioned as one component serving the company's program, not as the central topic.

Specificity: Let me check for specific facts:
- No named frameworks (NIST, ISO, etc.)
- No cybersecurity-specific titles (CISO, CIO, etc.)
- No named firms, tools, dates, numbers

- The program names and practices mentioned are all generic industry standard terminology without firm-specific details

This falls into Generic Boilerplate - it's describing standard cybersecurity practices and third-party engagement without any distinguishing facts or named standards that would make it company-specific.


content_category: Board Governance

reasoning: The board of directors is the grammatical subject performing oversight of cybersecurity risk management, making this Board Governance. No specific facts from the IS list are present — 'board of directors' is generic governance, 'regularly' is a vague cadence, and the rest is boilerplate language that could appear in any company's filing unchanged.

thinking:
Let me analyze this paragraph.

Content: Board oversight of cybersecurity program, board involvement in risk management oversight.

Category: Board Governance - the board is the grammatical subject performing oversight actions.

Specificity: No named frameworks, no specific facts from the IS list. "Board of directors" is generic. "Regularly" is a generic cadence. No cybersecurity-specific roles, no named committees, no dates, no numbers.

→ Generic Boilerplate (1)


content_category: Strategy Integration

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

thinking:
Materiality assessment present → Strategy Integration. The cross-reference doesn't change that per Rule 6.

No specific facts from the IS list. Boilerplate materiality language.


reasoning: The paragraph opens with generic risk acknowledgment but culminates in an explicit materiality assessment ('have not...experienced an incident materially effecting or reasonably likely to materially affect'), which per Rule 6 makes this Strategy Integration. No named frameworks, cybersecurity-specific roles, dates, or other facts from the IS list are present — 'Cullman Savings Bank' is a company self-reference on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Mix of risk management intro + materiality disclaimer. The last sentence is a materiality assessment ("not...experienced an incident materially effecting or reasonably likely to materially affect"). Per Rule 6, materiality disclaimers → Strategy Integration. The first two sentences are generic risk acknowledgment, but the materiality assessment in the final sentence is the substantive disclosure content.

Category: Strategy Integration (materiality assessment is present)

Specificity: No named frameworks, no specific facts from the IS list. "Cullman Savings Bank" is a company self-reference (NOT list). Everything else is boilerplate.

The rest of this is just generic boilerplate language without substantive detail.


content_category: Management Role

reasoning: The paragraph's primary content is the management committee structure responsible for cybersecurity: the Information Technology Steering Committee's composition (CIO, CTO, Information Security Officer), its charter, and the ISO's reporting line to the board. While it mentions what the committee oversees, the communicative purpose is establishing who at the management level is responsible and how they are organized — consistent with Management Role's coverage of 'management committees responsible for cybersecurity.' Multiple firm-specific facts (named non-generic committee, three cybersecurity-specific titles) but no QV-eligible hard facts (named roles and committees don't count toward QV).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the Information Technology Steering Committee - its composition, meeting cadence, and reporting to the board. Let me determine category and specificity.

**Category Analysis:**
- The paragraph starts with the board approving management committees, but the bulk is about the IT Steering Committee itself - its composition, what it does, who chairs it, how often it meets, and reporting lines.
- The committee includes CIO, CTO, and Information Security Officer - these are management roles.
- The committee is a management-level committee (not a board committee), providing oversight of technology and security programs.
- The primary actor is the management committee, not the board.

The board approves the committee and receives reports from it, but the focus is really on the management structure itself. This is describing an organizational governance structure for cybersecurity oversight - specifically how the IT Steering Committee is composed, what it oversees (technology programs, information security, risk management strategy, policies, and controls), and how it reports back to the board. The paragraph emphasizes the committee's structure and responsibilities rather than individual credentials or specific processes, which points toward a Management Role classification. I'm checking the specificity markers now. The paragraph names specific roles—CIO, CTO, Information Security Officer—and a named committee, all of which count as IS-list facts. There are no QV-eligible details like dates, dollar amounts, headcounts, or third-party vendors mentioned. That gives me Firm-Specific (3) without reaching QV eligibility.

fact: Chief Information Officer

fact: Chief Technology Officer

fact: Information Security Officer


reasoning: The paragraph is primarily about the management team's qualifications, experience, and track record — describing who they are and what makes them capable — rather than detailing specific processes or tools. The 'Director of Information Technology' is a generic IT title (not cybersecurity-specific per the IS list), but the specific quantified experience ('combined 35 years') is a firm-specific fact. Only one QV-eligible fact, so Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the management team including Director of IT, their experience, responsibilities for cybersecurity program, supervision of personnel and consultants, their track record.

Category: This is about the management team and their qualifications/experience. The person-vs-function test: the paragraph describes who the team is (combined experience, track record, adeptness) rather than specific processes. It's about the people's qualifications. → Management Role

Specific facts:
- "Director of Information Technology" — this is a generic IT title, NOT on the IS list (it's "Director of IT" which is listed under ✗ IS NOT)

- "combined 35 years of risk management experience" — this is a quantified number that counts as specific
- "clean audit observations" — this is vague and doesn't qualify as a specific fact

The only QV-eligible fact here is the 35-year figure. Since there's just one specific fact, this falls under Firm-Specific rather than QV.

Specificity: Firm-Specific (3)

type: quantified


reasoning: The paragraph contains two explicit materiality assessments ('have not materially affected' and 'not reasonably likely to materially affect') regarding business strategy, results of operations, and financial condition — this is Strategy Integration per Rule 6. The appended cross-reference to Risk Factors does not change the classification. No firm-specific facts are present; the language is standard boilerplate materiality disclaimer.

thinking: Materiality assessment paragraph with cross-reference.


content_category: Third-Party Risk

specificity_confidence: medium

reasoning: The paragraph's central topic is oversight of external parties — vetting third parties with access to data/infrastructure, reviewing attestations, and including security language in contracts. This is vendor oversight as the primary subject, not a component of internal processes. The specific departmental composition (security staff, legal, procurement/sourcing) qualifies as a firm-specific fact, though the remainder of the description (assessments, attestation review, contract language) uses common practices that don't further elevate specificity.

thinking:
Classify this paragraph.

Content: About third-party risk management - vetting process, assessments, attestation review, contract language, cross-functional collaboration.

Category: Third-Party Risk - the central topic is oversight of external parties' cybersecurity.

Specificity: No named frameworks, no named roles (just "security staff"), no specific dates, no numbers. "legal, procurement/sourcing personnel" - is this a specific team composition? The IS list says "Specific team/department compositions: 'Legal, Compliance, and Finance'" qualifies. Here we have "legal, procurement/sourcing personnel and other stakeholders" - this is a specific departmental composition working on third-party compliance.

This lands at Firm-Specific level 3 based on the identified departmental composition.

fact: Security staff work with legal, procurement/sourcing personnel and other stakeholders


reasoning: The paragraph describes an internal working group that implements a cybersecurity program — protecting systems, monitoring/detecting/mitigating threats, and incident response. While CISO and other roles are named, the paragraph is about the function (what the program does) not the person (credentials, background). Removing the titles, the paragraph still describes processes. The brief mention of reporting to the Board is subordinate to the process description. CISO is a cybersecurity-specific title on the IS list, giving Firm-Specific; CCO and COO are generic C-suite and do not count. No second QV-eligible fact prevents Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes an internal working group with CCO, COO, CISO that implements a cybersecurity program. Also mentions monitoring, prevention, detection, mitigation, remediation, and reporting to the Board.

Category: This is about the internal working group and what it does - processes like protecting systems, responding to incidents, monitoring threats. The CISO and other roles are mentioned but as part of describing the function/program, not the person's credentials. Using the person-vs-function test: remove the titles and the paragraph still describes a program. → Risk Management Process.

The Board reporting element is secondary to the core focus on the working group's operational processes. Looking at the specificity markers, I see generic C-suite titles that don't count, but CISO is on the IS list, making this Firm-Specific. There's only one QV-eligible fact here since named roles don't contribute to QV eligibility, so this lands as Firm-Specific.

fact: CISO is part of the internal working group


reasoning: The Audit Committee is the grammatical subject receiving reports and accessing presentations on cybersecurity — classic board oversight. All elements are generic: 'Audit Committee' is standard governance, 'periodic reports' is a vague cadence, 'management' is generic, and no named frameworks, roles, dates, or firm-specific facts appear.

thinking:
Classify this paragraph.

Content: The Audit Committee receives periodic reports from management about cybersecurity threats/risk and processes. Also has access to various reports/summaries/presentations.

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

Specificity: Let me check the facts:
- "Audit Committee" - on the NOT list (generic governance)
- "Board of Directors" - on the NOT list
- "management" - on the NOT list
- "periodic reports" - generic cadence
- No named frameworks, no specific facts from the IS list

→ Generic Boilerplate (1)


reasoning: The paragraph's primary purpose is identifying WHO is responsible for cybersecurity management — the Senior Director of HR & Infrastructure, CFO, General Counsel, and their Rapid Response Team — along with reporting lines to the audit committee and board. While it touches on Board Governance (quarterly updates to audit committee/board) and Risk Management Process (investigating threats, assessing materiality), the dominant content is the management team's composition, roles, and structure. The specific team composition (Senior Director HR & Infrastructure + CFO + General Counsel) is unique to this company, qualifying as Firm-Specific, though no QV-eligible hard facts (dates, dollar amounts, named third-party firms, named tools) are present.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes who is responsible for cybersecurity risk management, their team composition, and reporting structure. Let me apply the person-vs-function test.

The paragraph mentions:
- Senior Director, Human Resources & Infrastructure - this is the person responsible
- CFO and General Counsel - working with them
- Outside IT and cybersecurity consulting firm (unnamed)
- Rapid Response Team under Incident Response Policy
- Reporting to audit committee and board

Person-vs-function test: The paragraph starts by identifying who has primary responsibility, then describes the team composition and what they do (investigate threats, assess materiality, determine reporting).

So it's really both—the paragraph identifies the responsible roles and team structure while also describing what they actually do. The main point seems to be establishing WHO manages cybersecurity and HOW they're organized, but it can't avoid describing their functions like rapid response protocols, incident investigation, and materiality assessments. Even if I stripped away the role titles, the process itself would still be recognizable, though the paragraph's primary focus is clearly on the people and their organizational relationships.

The opening line makes it clear—"Primary responsibility rests with our Senior Director"—that's the core message. Everything else, including the board governance and risk management processes, supports that central claim about who's accountable. But I notice the Senior Director title itself isn't a typical cybersecurity role like CISO or Director of IT Security, which is worth flagging.

Looking at specificity now: the Senior Director role doesn't match the IS list of recognized titles, the Rapid Response Team lacks a distinguishing identifier or abbreviation, and the consulting firm reference is unnamed. The audit committee and quarterly update cadence are both too generic to count as specific facts.

But wait—the actual team composition here might be the specific detail: HR & Infrastructure plus CFO plus General Counsel is a particular arrangement unique to this organization, which could align with how the IS list recognizes specific team/department compositions like "Legal, Compliance, and Finance."

Let me verify the QV facts: there are no dates, dollar amounts, headcounts, named third parties, products, or certifications—just "quarterly" which is generic. So this lands on Firm-Specific (3) based on that team composition.

For the content category, the paragraph really centers on who owns cybersecurity responsibility—the Senior Director, CFO, and General Counsel—with the Rapid Response Team and board reporting as supporting details. The primary focus is the management structure, so Management Role is the right fit.

fact: Senior Director, Human Resources & Infrastructure has primary cybersecurity responsibility

fact: Core team composed of Senior Director HR & Infrastructure, CFO, and General Counsel


reasoning: Management is the grammatical subject throughout — they monitor, participate in, and report on cybersecurity matters. The paragraph describes management's role in the oversight chain (reporting to the IT Steering Committee quarterly, then to the Board annually), making it about management's reporting lines and responsibilities rather than the processes themselves. The Information Technology Steering Committee is a named non-generic committee qualifying as a firm-specific fact, but no second hard verifiable fact exists to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph discusses "these members of management" and their activities related to cybersecurity. Let me apply the person-vs-function test and category rules.

The paragraph describes what management does: monitors prevention/mitigation/detection/remediation, participates in risk management process, operates incident response plan, reports to IT Steering Committee quarterly, and provides summary to Board annually.

Who is the grammatical subject? "These members of management" - they monitor, they report to the IT Steering Committee, a summary report goes to the Board.

This is about management's role in the process and their reporting lines.

So the key question is whether this is really about the person or the function. Management's activities here are purely functional—monitoring processes, participating in risk management, and establishing reporting cadence to oversight bodies. There's nothing about who these people are, their qualifications, or their background. The paragraph is fundamentally describing management's operational responsibilities and how information flows up the organizational hierarchy. I'm working through whether this is really about the management role or the governance process. The key is that management is doing the monitoring and reporting—they're the active subject here. The paragraph describes their reporting cadence to the IT Steering Committee quarterly and the Board annually, which is clearly about their role in the oversight structure. So this falls under Management Role.

Now I'm checking the specificity: "Information Technology Steering Committee" is a named committee specific to this firm, not a generic governance body, so that's Firm-Specific. The reporting frequencies—quarterly and annually—are also concrete details that point toward Firm-Specific rather than generic.


reasoning: The paragraph's primary purpose is identifying who is responsible for cybersecurity — the management team including the COO — and their scope of responsibility (program oversight, supervising external consultants). This is organizational role assignment, not a description of processes, tools, or methodologies. However, COO is a generic C-suite title (NOT list), 'management team' is generic, and 'external cybersecurity consultants' are unnamed, leaving no specific facts to elevate beyond Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Management team including COO is responsible for assessing/managing cyber risks, oversees the program, supervises external consultants.

Category: This is about management's role. The grammatical subject is "our management team, including our COO." But let me apply the person-vs-function test. The paragraph says the team is "responsible for assessing and managing" risks and "supervises external consultants." It's describing what the team does functionally, but it's more about WHO is responsible (management team, COO) rather than HOW they do it (no processes, tools, frameworks described).

I'm reconsidering whether the COO reference disqualifies this. Even though COO is a C-suite title, the paragraph isn't really about the person's credentials—it's about the functional responsibility assignment. If I strip away the names and titles, what remains is a statement about who owns the cybersecurity risk management function. That's the core of what's being communicated here, so this still fits Management Role.

But looking at the specificity: there's nothing concrete. The management team is unnamed, the external consultants are unnamed, there are no frameworks, methodologies, dates, or specific facts. It's all generic language that could apply to any organization. That's textbook boilerplate.


reasoning: The paragraph is framed by board/audit committee oversight — it opens with 'Our Board has overall oversight responsibility' and closes with management presenting to the Audit Committee annually. Management and the Principal Accounting Officer are described in subordinate roles within this oversight hierarchy. The specific fiscal years (2023, 2022, 2021) for the no-incidents claim are firm-specific dates; however, 'Audit Committee,' '100% independent,' and 'Principal Accounting Officer' are generic governance items (PAO is not a cybersecurity-specific title on the IS list), and 'cybersecurity consultants' is unnamed, so only the fiscal year references qualify as a specific fact.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics: board oversight, management responsibilities, the Principal Accounting Officer's role, incident reporting, and no incidents occurring. Let me determine the dominant category.

Content: Board oversight is mentioned first, then management's role, then the Principal Accounting Officer directing cybersecurity programs, reporting to audit committee, no incidents in fiscal years, and annual assessment to Audit Committee.

The paragraph starts with board oversight but quickly shifts to management responsibilities. The primary actor shifts between board, management, and the Principal Accounting Officer. Let me assess dominant category:

- Board governance: "Board has overall oversight responsibility" + "reported to the audit committee...

The governance structure here is really the key—the board oversees, management identifies and mitigates risks through the Principal Accounting Officer's direction of cybersecurity programs, and everything flows up to the audit committee and board. The paragraph frames this as an oversight hierarchy rather than diving deep into any single risk management process. The mention of no incidents across the three fiscal years is almost incidental to establishing this governance chain. The PAO title is unusual here since it's typically an accounting role, not a cybersecurity one—this firm is using it in a firm-specific way. The specific fiscal years mentioned and the "100% independent" claim about the Audit Committee are concrete details, while "cybersecurity consultants" remains vague and unnamed. The audit committee independence claim is just standard corporate governance boilerplate—every public company has to meet that requirement anyway, so it's not really a cybersecurity-specific disclosure. The fiscal years (2023, 2022, 2021) do count as specific dates, but I need to figure out whether the "Principal Accounting Officer" angle actually ties this back to cybersecurity or if it's still just generic governance.

fact: fiscal 2023, 2022, or 2021 (no cybersecurity incidents)


reasoning: The paragraph describes the company's recognition of cybersecurity risk management (identifying, assessing, managing material risks) and lists generic risk types (operational risks, IP theft, fraud, etc.). This is a generic introductory statement about the company's own risk management approach, fitting Risk Management Process. No named frameworks, roles, dates, or firm-specific facts are present — the regulatory citation to Item 106(a) is a legal reference, not a cybersecurity standard — making this Generic Boilerplate.

thinking:
Classify this paragraph.

This paragraph is a generic statement about recognizing cybersecurity risks. It lists generic risk types but no frameworks, no specific facts, no named roles.

Category: Risk Management Process - it's about recognizing and managing cybersecurity risks (assessment/management). Though it's very generic, it does describe the company's approach to risk management.

Wait - let me reconsider. This is essentially saying "we recognize the importance of managing cyber risks" and listing generic risk types. It's introductory/generic. But it does reference Item 106(a) which is just a regulatory citation. The content is about risk management importance.

The paragraph mentions identifying, assessing, and managing material risks, which qualifies as a substantive claim about their risk management approach even if it's boilerplate. I'll categorize this as Risk Management Process, though it lacks any specific frameworks or concrete details.


reasoning: The paragraph describes the company's cyber risk management program — oversight, administration, prevention, detection, mitigation, remediation, use of threat intelligence, and third-party partners. While it mentions management's 'prior experience,' this is a generic capability claim about an unnamed 'management team' (no CISO, no named individuals, no credentials), making it program-function attribution rather than person-focused content. The brief Audit Committee mention at the end is subordinate. No named frameworks, no cybersecurity-specific roles, no named firms or tools, no dates or numbers — all entities are generic or unnamed.

thinking:
Let me analyze this paragraph.

Content: Describes management team's responsibility for cyber risk management program, their experience, and mentions Audit Committee oversight briefly at the end.

Category: This is about the management team's responsibilities and experience. But let me apply the person-vs-function test. The paragraph describes what the management team does (oversight, administration, informing stakeholders, prevention/detection/mitigation/remediation) and their experience (selecting, deploying, overseeing cybersecurity technologies). It's a mix - talks about experience but also about what they do.

The paragraph says management team has "prior experience selecting, deploying, and overseeing cybersecurity technologies" - this is about qualifications/experience of management. But it also describes the program functions extensively.

Actually, the primary subject is "our management team" and the paragraph describes their responsibilities and experience. The last sentence mentions Audit Committee briefly. The person-vs-function test: if I remove references to the management team's experience and identity, the remaining content describes program functions (prevention, detection, mitigation, remediation, threat intelligence, third-party partners). But a significant portion is about the management team's experience and qualifications.

The paragraph's main focus is establishing who oversees the cybersecurity program and what qualifications they bring, though "management team" is generic rather than a named role like CISO. The communicative purpose centers on the team's qualifications and their program responsibilities, with the Audit Committee mentioned only in passing.

Looking at the substance: the paragraph outlines the cyber risk management program's core functions—oversight, administration, prevention, detection, mitigation, remediation, threat intelligence integration, and third-party partnerships—with the management team presented as the responsible party. The qualifications mentioned are vague and unnamed, with no specific credentials or individual roles identified.

I'm settling on Risk Management Process as the category. The paragraph fundamentally describes what the program does, with management attribution providing context but not being the primary focus. For specificity, there are no concrete details—just generic references to "management team" and unnamed "third-party IT and cybersecurity service providers."

Now checking the next section: Audit Committee is mentioned generically, BIOLASE is a self-reference, and there are no named frameworks, dates, roles like CISO, or specific firms. This confirms Generic Boilerplate.


reasoning: The paragraph's central topic is how the Fund oversees cybersecurity risks arising from its use of third-party service providers, making Third-Party Risk the dominant category. The CCO is mentioned as attribution (and is not a cybersecurity-specific title), while the substantive content is about oversight of external entities. The specific departmental composition ('risk management, legal, information technology, and compliance personnel of the Investment Adviser') qualifies as a firm-specific fact per the IS list, but no second hard verifiable fact is present to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: The fund relies on third parties and its CCO plus personnel from the Investment Adviser to identify/oversee cybersecurity risks from third-party use.

Category: This mentions third-party risk oversight but the focus is on who handles the oversight of third-party risks. The central topic is oversight of risks from third parties. But it's also describing the management structure that handles this. Let me think...

The paragraph says: (1) Fund uses third parties, (2) Fund relies on CCO and Investment Adviser personnel to oversee risks from these third parties.

The central topic is about how they oversee third-party cybersecurity risks.

I'm debating whether this falls under Third-Party Risk or Management Role. The paragraph mentions the CCO and various personnel, but it's not describing their qualifications or roles in general—it's specifically about their function in overseeing external parties' cybersecurity. The people are mentioned as the mechanism for oversight, not as the main subject. So this is fundamentally about third-party risk management.

Now I'm checking the specificity. The CCO title itself is generic corporate terminology, not cybersecurity-specific, so that doesn't add specificity. But the team composition—risk management, legal, IT, and compliance personnel working together—that's a specific organizational structure from the IS list, which pushes this into Firm-Specific territory.

fact: Specific departmental composition: risk management, legal, information technology, and compliance personnel of the Investment Adviser


reasoning: The paragraph describes engaging an external cybersecurity firm to evaluate and test the company's own risk management systems — per Rule 3, an external assessor hired to serve the company is Risk Management Process, not Third-Party Risk (no requirements imposed ON a vendor). Despite the third-party framing, the substantive content is about the company's internal risk management activities (audits, threat assessments, monitoring). No named firms, frameworks, dates, tools, or specific numbers appear — 'a cybersecurity assessment firm' is an unnamed entity and '24-hour monitoring' is a common practice description — so specificity remains Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes engaging a third-party cybersecurity firm to evaluate/test risk management systems. Mentions system audits, threat assessments, 24-hour monitoring, consultation.

Category: This is about engaging an external party to serve the company's own risk management. Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." But also, the central topic is about the third-party engagement itself. Let me re-read...

The paragraph is about engaging a third-party firm to help with risk management. The external expert is serving the company. Per the rules, "External assessor hired to test the company → Risk Management Process." But the central topic IS the third-party relationship. Hmm.

Actually, looking at Rule 3 again—when a company hires an external firm to evaluate and test its systems, that's the firm serving the company's internal risk management needs, not the company managing third-party risk. The distinction is clear: this falls under Risk Management Process, not Third-Party Risk. No specific frameworks or vendors are named.

Checking the specificity: "cybersecurity assessment firm" is generic, "24-hour monitoring" is just standard practice language, no named standards or dates. This is Generic Boilerplate.


reasoning: The paragraph primarily describes the company's risk management process — how risks are assessed, assigned to stakeholders, and remediated. While it names specific roles (VP/CISO, EVP of Global IT) and a reporting line, these serve as attribution for who performs the process steps rather than describing the persons' qualifications or backgrounds. Applying the person-vs-function test: removing the role titles, the paragraph still describes a coherent risk identification, assignment, and remediation workflow. Specificity is Firm-Specific due to the cybersecurity-specific CISO title and the named Risk Subcommittee, but no QV-eligible hard facts (no dates, dollar amounts, named firms, or tools) are present.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes:
1. Senior management meeting regularly to assess IT risks
2. EVP of Global IT and eDiscovery Operations - reports to Board via CEO, member of Risk Subcommittee
3. VP, CISO - responsible for identifying cybersecurity risks and vulnerability assessments
4. Process of assigning risks to stakeholders
5. VP, CISO collaborates with risk owners for remediation

Person-vs-function test: The paragraph names specific roles (EVP of Global IT and eDiscovery Operations, VP/CISO) but primarily describes what the program does - risk assessment, vulnerability identification, remediation process.

The roles are mentioned as attribution for who does what in the process. If I removed the role titles, the paragraph still describes a risk management process. However, there's significant content about reporting lines (EVP reports to Board via CEO) and role responsibilities. The paragraph is mixed - it describes both the management structure and the process. The dominant content seems to be about the process of risk management, with roles mentioned as part of describing who does what. The reporting line (EVP → CEO → Board) is one element, but the bulk is about the risk assessment and remediation process. I'll classify as Risk Management Process since the primary content is about the process (assess, analyze, evaluate, propose, approve, remediate risks).

Looking at the specificity now: I see the Executive Vice President of Global IT and eDiscovery Operations title, which isn't a cybersecurity-specific role, but the Risk Subcommittee is a named non-generic committee and the VP, CISO is a cybersecurity-specific title. There are no named frameworks, dates, dollar amounts, or named firms or tools mentioned. The CISO and Risk Subcommittee are firm-specific facts but not QV-eligible since named roles and committees don't count toward QV. With no dates, dollar amounts, or named firms or tools, this falls into Firm-Specific.

fact: Risk Subcommittee

fact: Vice President and Chief Information Security Officer (VP, CISO)


reasoning: This paragraph describes internal incident response procedures—coordinating IRT activities, developing procedures, responding to and documenting incidents—which are core risk management process activities. No named frameworks, tools, roles, dates, or other specific facts are present; 'IRT' is a generic abbreviation, not a uniquely named program.

thinking:
Classify this paragraph.

This is a brief bullet point describing IRT (Incident Response Team) coordination activities. It's about internal processes - responding to and documenting security incidents.

Content: describes procedures for incident response - this is Risk Management Process.

Specificity: No named frameworks, no firm-specific facts. "IRT" is a generic abbreviation. No named roles, tools, dates, etc. This is Generic Boilerplate.


reasoning: The paragraph contains an explicit materiality assessment ('to date these incidents have not had a material impact on our service, systems or business'), which per Rule 6 classifies it as Strategy Integration. The surrounding text is generic risk language about potential adverse business/financial effects. No named frameworks, dates, roles, or other specific facts are present.

thinking:
Let me analyze this paragraph.

Content: Discusses past attacks (not material), potential future disruptions, and business/financial risks. The key sentence is "to date these incidents have not had a material impact" - this is a materiality assessment. But the paragraph also describes generic risk language about potential future impacts.

Category: The paragraph contains a materiality assessment ("to date these incidents have not had a material impact on our service, systems or business") which per Rule 6 makes it Strategy Integration. The rest is generic risk language about potential adverse effects.

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


reasoning: The paragraph describes the company's internal cybersecurity strategy — employee training, policies across multiple domains, and engagement of third-party consultants for penetration testing and risk assessments. Third parties are mentioned as a component serving the company's own program (Rule 3), not as the central topic. No named frameworks, cybersecurity-specific roles, named firms, tools, dates, or quantified facts appear; the policy area names (Information Security, Data Governance, etc.) are generic program categories, and 'third-party consultants and independent auditors' are unnamed entities.

thinking:
Let me analyze this paragraph.

Content: Describes the company's multi-layered cybersecurity strategy including training, technologies, policies across various areas, and engagement of third-party consultants for pen tests and assessments.

Category: This is about the company's internal processes - risk assessment, training, policies, incident response planning. Third parties are mentioned as one component serving the company's program. → Risk Management Process

Specificity: Let me check for specific facts:
- No named frameworks (NIST, ISO, etc.)
- No cybersecurity-specific titles (CISO, CIO, etc.)
- No named firms, tools, dates, numbers

- Third-party consultants and independent auditors are unnamed
- Penetration testing and employee training are standard practices
- Policy areas like Information Security and Data Governance are generic program names

This is generic boilerplate without any concrete details or named standards.


reasoning: The paragraph contains an explicit materiality assessment ('have not experienced material adverse effects from cybersecurity threats') regarding business strategy, results of operations, and financial condition, making it Strategy Integration per Rule 6. The appended cross-reference to Risk Factors does not change the classification. No firm-specific facts, named standards, or verifiable details are present — all language is boilerplate.

thinking: Materiality assessment present + cross-reference. Per Rule 6 and the codebook, this contains an explicit materiality assessment.


reasoning: The audit committee is the grammatical subject receiving cybersecurity reports, making this Board Governance. No specific facts from the IS list are present — 'audit committee' is generic governance, 'Security Team' is a generic team name, and 'regular reports' is a vague cadence — so this is Generic Boilerplate.

thinking:
Classify this paragraph.

The paragraph is about the audit committee receiving reports about cybersecurity. The audit committee is the grammatical subject → Board Governance.

Specificity: "audit committee" is generic, "Security Team" - is this a cybersecurity-specific title? It's capitalized, suggesting a named team, but "Security Team" is fairly generic. Let me check the IS list... "Specific team/department compositions" would need something like "Legal, Compliance, and Finance." "Security Team" is just a generic team name. "Regular reports" is a generic cadence. No named frameworks, no specific facts from the IS list.

So this lands in Generic Boilerplate.


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


reasoning: The paragraph describes external consultants and firms hired to support the company's own cybersecurity program — designing controls, penetration testing, monitoring, detection, and incident response. Per Rule 3, external assessors hired to serve the company are Risk Management Process, not Third-Party Risk (which requires vendor oversight as the central topic). No named firms, tools, frameworks, dates, or quantified facts are present; all third parties are unnamed ('a third-party consultant', 'a third party', 'third parties'), keeping specificity at Generic Boilerplate.

thinking:
Classify this paragraph.

Content: describes engaging third-party consultants for controls design, penetration testing, monitoring/detection, and incident response. These are third parties serving the company's own security program - they're external assessors/consultants hired to help the company, not vendors whose security the company oversees.

Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)"

The third parties here are all serving the company's cybersecurity program. This is Risk Management Process.

Specificity: No named firms, no named frameworks, no dates, no numbers.

All references to third parties are generic and unnamed, penetration testing appears as a standard practice without being listed as part of a formal framework, and there are no cited standards or methodologies. This falls under Generic Boilerplate.


reasoning: The paragraph describes board-approved committees (ITAC, ERM, ITSC) that provide oversight and governance of cybersecurity, chaired by board members with senior management participation. The board is the authorizing entity and board members chair the committees, making Board Governance the dominant category over Management Role. Multiple named non-generic committees and cybersecurity-specific titles qualify as firm-specific facts, but no QV-eligible hard facts (dates, dollar amounts, headcounts, named third-party firms) are present.

thinking:
Let me analyze this paragraph from First Seacoast Bancorp's 10-K filing.

Content Category: This paragraph describes board-approved management committees (ITAC, ERM, ITSC) and their oversight functions. The board approved these committees, but the committees themselves are management committees. The paragraph describes committee composition, meeting cadence, and reporting. The primary actors are the committees, which include both board members and senior management. The grammatical subject shifts between the committees and their activities.

This is a blend of Board Governance and Management Role. The committees are "management committees" approved by the board, chaired by board members with senior management participation.

Looking at the structure more carefully, these are management committees with board oversight—the board approved them and board members chair them, but they're fundamentally management committees handling oversight and governance functions. The paragraph focuses on what these committees do and how they're structured, which points toward Board Governance since the emphasis is on the oversight and governance framework itself.

For specificity, the named committees ITAC, ERM, and ITSC are specific entities rather than generic references, so these would be IS facts.

Now examining the roles and programs mentioned—the Chief Finance/Information Security Officer, Chief Information Officer, and Senior Technology/Cybersecurity Officer are cybersecurity-specific titles that count as IS facts. The IRP (Incident Response Plan) is a named internal program, though the abbreviation is fairly generic. The quarterly meeting cadence is just a generic timeframe.

There are no QV-eligible facts here—no specific dates, dollar amounts, headcounts, third-party firms, products, or certifications. With multiple IS facts identified, this falls under Firm-Specific classification.

fact: ITAC (management committee focusing on technology impact)

fact: ERM (management committee focusing on business impact)

fact: ITSC (internal management committee for IT strategies)

fact: Senior Technology/Cybersecurity Officer


reasoning: The paragraph describes how the company's cybersecurity function is structured and operated — outsourced to service providers who handle prevention, detection, mitigation, and remediation, with reporting to a financial officer. Third-party providers are a component of the internal program structure (Rule 3), and the paragraph is about the function, not any person's credentials (person-vs-function test). No cybersecurity-specific titles (PFO is a financial role, not on the IS list), no named frameworks, no named firms, no dates or quantified facts — all entities are unnamed ('service providers', 'our organization'), yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes outsourced IT security team, two service providers, one oversees IT/facilities, reports to Principal Financial Officer, describes prevention/detection/mitigation/remediation efforts.

Category: This is about the management structure - specifically who oversees cybersecurity. The Principal Financial Officer oversees the program, and the service provider reports to them. But the paragraph is also about third-party risk (outsourced to service providers) and risk management process.

Let me apply the person-vs-function test. The paragraph mentions the Principal Financial Officer but doesn't describe their qualifications, background, or credentials. It describes what the outsourced team does and the reporting structure.

The core issue here is that this paragraph is really about how cybersecurity is organized through outsourced providers rather than internal staff, with the PFO providing oversight. The third-party arrangement is the defining feature, not the individual overseeing it. The Principal Financial Officer title doesn't fit cybersecurity-specific roles, and the unnamed service providers don't provide concrete details. Without specific facts, frameworks, dates, or named entities that meet the criteria, this falls into generic boilerplate.


reasoning: The paragraph describes Oracle's internal cybersecurity processes—prevention, detection, response, monitoring, vulnerability simulation, and employee training—all hallmarks of Risk Management Process. No named frameworks (only 'industry standard security frameworks'), no named tools, roles, dates, or quantified facts; every element is generic and could appear in any company's filing.

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

Content: Describes internal cybersecurity processes - prevention, detection, response, monitoring, training. No specific person, no board, no vendors as central topic, no incident, no materiality assessment.

Category: Risk Management Process - clearly about internal processes.

Specificity: Let me check for specific facts:
- No named frameworks (just "industry standard security frameworks" - generic)
- No named roles (just "relevant personnel", "subject matter experts")
- No named tools
- No dates, numbers, firms
- All generic practices: monitoring, training, reviews, simulations

- This is generic boilerplate language without concrete details.


reasoning: The paragraph's primary communicative purpose is defining which management roles are responsible for which cybersecurity functions — organizational responsibility assignment rather than detailed process description. While activities are listed, they serve to scope each role's responsibilities. The named 'Cybersecurity Risk Management Committee' is a non-generic committee qualifying as a firm-specific fact; however, CBO, CAO, and Head of Legal are not cybersecurity-specific titles per the IS list, and the third-party IT team is unnamed.

thinking:
Let me analyze this paragraph from Vera Therapeutics' 10-K filing.

Content: Describes what the Chief Business Officer does and a group of officers (CBO, CAO, Head of Legal) responsible for various cybersecurity functions. This is about what these roles DO (hiring, communicating, integrating, maintaining budgets, preparing for incidents, approving processes, reviewing assessments) — it's about the function/process, not about the persons' qualifications or backgrounds.

Person-vs-function test: If I remove the titles, the paragraph describes processes: hiring personnel, communicating priorities, integrating cyber risk into ERM, maintaining budgets, preparing for incidents, approving processes, reviewing assessments. It still makes sense as a process description. → Risk Management Process.

But I'm second-guessing myself—the paragraph is really centered on organizational responsibility assignments, with specific management roles as the grammatical subjects. It's defining who owns what in the cybersecurity structure. The codebook does mention Management Role covers "management committees responsible for cybersecurity" and "reporting lines," which seems to fit here. I need to decide whether this is fundamentally about the roles and their responsibilities in the organizational hierarchy, or about the processes those roles execute. The codebook's person-vs-function test is pretty clear: if the paragraph describes what the role does rather than who the person is, it's a Risk Management Process. Applying that literally, the substantive content here is about activities and responsibilities, not qualifications or backgrounds, so I'm going with Risk Management Process. The Cybersecurity Risk Management Committee is the only firm-specific fact here—it's a named committee rather than a generic one. The other roles mentioned (CBO, CAO, Head of Legal) are standard C-suite titles not on the cybersecurity-specific list, and there are no QV-eligible facts like dates, amounts, or certifications. So this falls under Firm-Specific classification.

fact: Cybersecurity Risk Management Committee


reasoning: The paragraph describes the company's internal cybersecurity processes: access control improvements, penetration testing, simulations, monitoring, risk assessments, and maturity testing. Third-party risk is mentioned as one component of the overall program (not the central topic), keeping this as Risk Management Process per Rule 3. No named frameworks, tools, firms, dates, specific numbers, or cybersecurity-specific roles appear — all references are generic (unnamed consultants, unnamed teams, common practices like pen testing and drills).

thinking:
Let me analyze this paragraph.

Content: Describes internal cybersecurity processes - investments in IT security, access control, simulations, drills, penetration tests, monitoring, risk assessments, and third-party risk as a component. The primary focus is on the company's own internal processes.

Category: Risk Management Process - describes internal processes, tools, methodologies. Third-party risk is mentioned but as ONE component of the internal program (Rule 3).

Specificity: Let me check for specific facts:
- "IT security team" - generic
- "cybersecurity team" - generic
- "penetration tests" - common practice (NOT list)

- "third-party consultants" - unnamed (NOT list)
- "simulations and drills" - common practice
- No named frameworks, no named tools, no specific dates, no named firms, no specific numbers

No IS-list facts. No named standards. → Generic Boilerplate (1)


reasoning: The paragraph is about the people filling cybersecurity leadership roles — the CISO's 31 years of experience and background in satellite/telecom networks, and the SVP Global Security from Inmarsat with UK Ministry of Defence experience. This is squarely about who these individuals are and what qualifies them (person, not function). Multiple hard verifiable facts: 31 years of experience (quantified), named firm Inmarsat, and UK Ministry of Defence as a named organization.

thinking:
Let me analyze this paragraph.

Content: Describes the CISO's experience, background, and the SVP Global Security from Inmarsat joining. It's about the people - their qualifications, experience, background.

Category: Management Role - the paragraph is about the persons (CISO and SVP), their experience, credentials, and background.

Specific facts:
- CISO (cybersecurity-specific role)
- 31 years of experience (specific number)
- Senior Vice President, Global Security of Inmarsat (named role + named firm)
- UK Ministry of Defence and Central Government (prior employer context)

- 31 years is quantified, Inmarsat and UK Ministry of Defence are both named entities, so this qualifies as Quantified-Verifiable with three hard facts.

fact: CISO leads operational cybersecurity team

fact: 31 years of experience in Information Technology and Security

fact: Inmarsat (acquired company, named firm)

fact: Senior cybersecurity and intelligence roles within the UK Ministry of Defence and Central Government


reasoning: Two of three sentences describe internal cybersecurity processes (tabletop exercises, incident response procedures), making Risk Management Process the dominant category over the single sentence on cyber insurance (Strategy Integration). No named frameworks, roles, dates, tools, or specific numbers appear — tabletop exercises and incident response procedures are common practices on the NOT list, and the insurance mention lacks any specifics.

thinking:
Let me classify this paragraph.

Content: Describes tabletop exercises, incident response procedures, and cyber insurance.

Category: Mixed - tabletop exercises and IR procedures are Risk Management Process, cyber insurance is Strategy Integration. The dominant content is about internal processes (2 out of 3 sentences). → Risk Management Process

Wait, let me reconsider. Two sentences about internal processes, one about cyber insurance. Dominant = Risk Management Process.

Specificity: Let me check for facts.
- "table-top simulation exercises" - common practice, NOT list

- "incident response procedures" - generic program name, NOT list
- "cyber insurance" - mentioned but no specifics (no amounts, no named insurers)
- No named frameworks, no named roles, no specific dates, no numbers

→ Generic Boilerplate (1)


reasoning: The paragraph's primary communicative purpose is describing the governance oversight structure: the Board delegates to the Audit Committee, the SVP reports TO the Audit Committee, and the Audit Committee reports back to the full Board. While the SVP's responsibilities occupy significant text, they are framed as part of the Board/Audit Committee oversight flow, making Board Governance the dominant category. For specificity, 'Audit Committee' and 'Board of Directors' are on the NOT list, 'quarterly' is a generic cadence, and 'SVP, Head of Legal and Compliance' is not a cybersecurity-specific title per the IS list (analogous to 'Chief Compliance Officer' on the NOT list), leaving no qualifying specific facts.

thinking:
Let me analyze this paragraph carefully.

The paragraph discusses both board/committee oversight AND a management role (SVP, Head of Legal and Compliance). Let me determine the dominant category.

Sentences:
1. "Our Board of Directors is focused on cyber security." - Board Governance
2. "Specific responsibility for cybersecurity oversight is managed by the Audit Committee." - Board Governance
3-6. The SVP, Head of Legal and Compliance is responsible for... reports to the Audit Committee quarterly... - This is about what the SVP does (management role as subject)
7. "The Audit Committee will report... to the full Board of Directors..." - Board Governance

The SVP, Head of Legal and Compliance is the grammatical subject for most of the paragraph, but that title isn't cybersecurity-specific—it's a general corporate role. The text focuses on the SVP's responsibilities and reporting structure to the Audit Committee rather than on any personal credentials or background, so it's really describing what the function does rather than who the person is.

Looking at the overall structure, the paragraph frames everything around the governance oversight flow: the Board delegates to the Audit Committee, the SVP reports to the Audit Committee, and the Audit Committee reports back to the Board. Even though the SVP is grammatically central, the dominant theme is how information moves through this governance structure. This feels like Board Governance since the oversight structure and the Audit Committee's role as the key governance body are what tie everything together. The Audit Committee is really the central oversight mechanism here, with the SVP reporting to them and them reporting back to the full Board—so this is fundamentally about governance structure rather than a specific management function. The titles and cadences mentioned aren't cybersecurity-specific either, which reinforces that this is about the governance framework itself rather than specialized security roles or processes.


reasoning: The grammatical subject is 'Our IT management team,' making this about who is responsible for cybersecurity risk management rather than what processes they use (person-vs-function test favors Management Role). Board and committee oversight are mentioned subordinately. However, all named roles (COO, CFO, General Counsel) are on the NOT list as generic C-suite, 'IT management team' is not a cybersecurity-specific title, and 'Nominating and Corporate Governance Committee' is a standard board committee — no specific facts survive validation, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

The paragraph describes who is responsible for cybersecurity risk management. Let me break it down:

- "Our IT management team" is the grammatical subject
- Board of Directors and Nominating and Corporate Governance Committee provide oversight
- COO, CFO, General Counsel are mentioned as management team members involved
- They are "primarily responsible for assessing and managing our material risks from cybersecurity threats"

Category: This is about the organizational structure for cybersecurity oversight. The IT management team is the primary subject. It mentions board oversight but the main point is about the management structure responsible for cyber risk. This touches both Board Governance and Management Role.

The key distinction here is whether this is about organizational structure and responsibility assignment versus the actual processes and functions. The paragraph identifies the IT management team as responsible with board oversight, which is fundamentally about who holds the responsibility rather than what specific actions they take. This points toward Management Role since it's defining the management team's accountability for cybersecurity.

Looking at the specificity markers: the Nominating and Corporate Governance Committee is a standard board committee rather than a cybersecurity-specific one, and the roles mentioned—COO, CFO, General Counsel—are generic C-suite titles. The IT management team itself is also a generic designation, not a specialized cybersecurity team. So while the classification is Management Role, the specificity is low because none of these are cybersecurity-focused entities.


reasoning: The paragraph contains both an incident reporting chain (process element) and an explicit materiality assessment ('have not identified any cybersecurity incidents or threats that have materially affected us, including our business strategy, results of operations, or financial condition'). Per Rule 6, materiality disclaimers are Strategy Integration even when boilerplate. The materiality conclusion is the paragraph's primary disclosure purpose; the reporting chain and cross-reference are supporting context. Specificity is Firm-Specific because the reporting chain names a specific team composition (VP of Regulatory and Quality Assurance, GxP Systems Director) that reveals this company's unique organizational structure for incident escalation, beyond generic C-suite titles.

thinking:
Let me analyze this paragraph carefully.

The paragraph has multiple elements:
1. Incident management reporting chain (CFO, VP of Regulatory and Quality Assurance, CEO, GxP Systems Director, board)
2. Materiality disclaimer ("have not identified any cybersecurity incidents or threats that have materially affected us...")
3. Generic threat acknowledgment
4. Cross-reference to Risk Factors

The dominant content: There's a reporting chain description AND a materiality disclaimer. Let me assess which is dominant.

The materiality disclaimer is a full sentence making an explicit materiality assessment. Per Rule 6, materiality disclaimers → Strategy Integration.

But the first sentence describes incident management reporting processes. Looking at the balance: The first sentence is about process (reporting to senior management). The second sentence is the materiality assessment. The third is generic. The fourth is a cross-reference.

The materiality assessment is prominent and is a key SEC disclosure requirement. The reporting chain is part of risk management process. This is a borderline case, but the materiality disclaimer takes up significant space and is the key disclosure conclusion, while the reporting chain is just one sentence. So Strategy Integration is the dominant category here since the materiality assessment is the primary disclosure.

Now I'm examining the specificity of the roles mentioned—looking at whether titles like CFO, VP of Regulatory and Quality Assurance, CEO, and GxP Systems Director are cybersecurity-specific or generic C-suite positions.

The VP of Regulatory and Quality Assurance and GxP Systems Director are firm-specific roles tied to pharmaceutical compliance, not standard cybersecurity titles, so they don't meet the IS list criteria. The cross-reference to Item 1A Risk Factors is on the exclusion list. With no named frameworks, specific dates, dollar amounts, or named firms, and only boilerplate materiality language remaining, this falls into Generic Boilerplate. I need to reconsider whether this qualifies as firm-specific. The roles listed—VP of Regulatory and Quality Assurance and GxP Systems Director—aren't cybersecurity-specific titles, and while they do reveal something about the company's pharma-specific structure, they're not quite the same as the department composition examples in the IS list. I'm leaning toward calling this borderline, but the fact that cybersecurity incidents route through regulatory and GxP functions does suggest a firm-specific organizational pattern worth noting.

fact: Incident reporting chain includes VP of Regulatory and Quality Assurance and GxP Systems Director — a specific organizational composition unique to this company


reasoning: The paragraph centers on the management team's qualifications — their combined experience ('over five decades'), specific certifications (CISM, CRISC), and leadership tenure ('two decades'). This is about the persons, not the function, satisfying the person-vs-function test for Management Role. Multiple QV-eligible hard facts: specific experience durations and named certifications.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph is about the management team - specifically the CIO and CISO, their experience, certifications, and responsibilities. The person-vs-function test: the paragraph tells us about WHO these people are (experience, certifications), not just what the program does. The credentials and experience are the primary content. → Management Role

Specific facts:
- CIO (cybersecurity-specific? CIO is on the IS list) ✓
- CISO ✓
- "over five decades of IT and cybersecurity experience" - specific number ✓

- "two decades in senior-level leadership roles" - specific number ✓
- CISM certification ✓
- CRISC certification ✓
- Information Security Steering Committee - named non-generic committee ✓

I'm seeing multiple quantified and verifiable facts here: the experience metrics in years, plus two named industry certifications that can be independently verified. This clearly qualifies as Quantified-Verifiable content.

fact: CIO

fact: CISO

fact: Certified Information Security Manager (CISM)

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

fact: Information Security Steering Committee


reasoning: The paragraph's primary purpose is a materiality assessment ('we have not experienced any cybersecurity incidents that have materially affected... our business strategy, results of operations or financial condition') combined with mention of cyber liability insurance and general business risk context. Per Rule 6, explicit materiality conclusions are Strategy Integration even with an appended cross-reference. No named insurers, dollar amounts, dates, or other specific facts elevate this beyond boilerplate.

thinking:
Let me analyze this paragraph carefully.

The paragraph has a header "Impact of Cybersecurity Risks on Business Strategy, Results of Operations or Financial Condition" and discusses:
1. Business context (online business)
2. Risk acknowledgment
3. Materiality assessment ("To date, we have not experienced any cybersecurity incidents that have materially affected...")
4. Cyber liability insurance mention
5. Cross-reference to Risk Factors

Primary communicative purpose: This is a materiality assessment with strategy context. Per Rule 6, materiality disclaimers → Strategy Integration. The paragraph makes an explicit materiality conclusion.

Now I'm checking the specificity of the language—there are no concrete dates, dollar amounts, or headcounts, and the cyber liability insurance reference is generic without naming an insurer or coverage limits. This is standard boilerplate materiality language.


reasoning: The Board of Directors and Audit Committee are the grammatical subjects performing oversight actions (overseeing the program, receiving briefings, reviewing incidents). All elements are generic: 'Board of Directors,' 'Audit Committee,' 'periodic briefings,' and 'quarterly' reviews are standard governance language with no firm-specific facts from the IS list.

thinking:
Let me analyze this paragraph.

Content: Board of Directors oversees cybersecurity risk management, delegates to Audit Committee, receives periodic briefings, Audit Committee reviews quarterly.

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

Specificity: Let me check facts:
- "Board of Directors" - generic (NOT list)
- "Audit Committee" - generic (NOT list)
- "periodic briefings" - generic cadence
- "each quarter" - generic cadence
- No cybersecurity-specific roles, no named committees beyond Audit Committee, no specific dates, no named firms/tools

- No IS-list facts, no named standards referenced, so this is generic boilerplate.


reasoning: The CyTOC (a named, non-generic cybersecurity board committee) is the grammatical subject throughout, receiving updates, briefings, and participating in exercises — classic board oversight activities. The paragraph also describes how the CyTOC Chair briefs the full Board and how ERM-level cyber risks flow to the Board and Audit and Finance Committee. Multiple firm-specific facts (CyTOC, CISO, EVP-CDIO/CTO role) but no QV-eligible hard facts (no dates, dollar amounts, headcounts, or named third-party firms).

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

Content Category: This is about a board committee (CyTOC) receiving updates and briefings. The CyTOC is the grammatical subject throughout most of the paragraph. It describes board-level oversight mechanisms. → Board Governance

Specific facts:
- "CyTOC" - named non-generic committee (Cybersecurity Technology Oversight Committee or similar)
- "CISO" - cybersecurity-specific role
- "Executive Vice President – Chief Digital and Information Officer and Chief Transformation Officer" - specific role

- "Audit and Finance Committee" - another named committee variant

Now checking for QV eligibility: I have named roles and committees here, but these are all firm-specific designations rather than hard verifiable facts like dates, dollar amounts, headcounts, or third-party references. So this doesn't meet the QV threshold.

For firm-specific content: Yes, definitely—CyTOC and the Audit and Finance Committee are both named non-generic committees, and the CISO and EVP titles are cybersecurity-specific organizational positions.

This rates as Firm-Specific (3).

fact: CyTOC (named cybersecurity-focused board committee)

fact: Audit and Finance Committee (named variant of standard committee)


reasoning: The Board and its committees (Technology and Cybersecurity Committee, Audit and Finance Committee) are the grammatical subjects performing oversight, receiving reports, and delegating responsibility — classic Board Governance. The CIO and CISO are mentioned subordinately as those who report TO the board committee. Firm-Specific due to the named non-generic Technology and Cybersecurity Committee and cybersecurity-specific roles (CIO, CISO), but these are not QV-eligible facts (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Let me analyze this paragraph from Performance Food Group Co's 10-K filing.

Content Category: The paragraph is about Board oversight - the Board, Technology and Cybersecurity Committee, and Audit and Finance Committee are the primary subjects. Management roles (CIO, CISO) are mentioned but in the context of reporting TO the board. → Board Governance

Specific facts:
- Technology and Cybersecurity Committee (named non-generic committee) ✓
- Audit and Finance Committee (this is a variant of Audit Committee - borderline, but "Audit and Finance Committee" is still essentially the standard audit committee)
- CIO title ✓ (cybersecurity-specific per IS list)

- CISO title ✓ (cybersecurity-specific)
- Named executive roles including Chief Information Officer and Chief Information Security Officer
- Quarterly reporting cadence mentioned but that's generic

Looking at the QV criteria, the named titles and committee structure are firm-specific but don't meet the quantitative threshold - there are no dates, financial figures, headcounts, or named external tools. The specificity level is firm-specific due to the cybersecurity-focused titles and governance structure, but it doesn't qualify as QV.

fact: Technology and Cybersecurity Committee

fact: Chief Information Officer (CIO)

fact: Vice President, Chief Information Security Officer (CISO)


content_category: Incident Disclosure

reasoning: The paragraph narrates two actual cybersecurity incidents with specific dates (December 2021, March 2024), describes what happened, the scope of disruption, and response actions — all hallmarks of Incident Disclosure. The brief materiality statement and post-incident enhancements are subordinate to the incident narrative. Two specific dates plus quantified durations yield multiple hard verifiable facts, reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph describes two actual cybersecurity incidents - December 2021 and March 2024. It details what happened, the timeline, scope, response actions, and impact. The dominant content is incident narrative.

There's a brief materiality statement ("we do not anticipate further material adverse impacts") and mention of post-incident enhancements, but the bulk is incident description.

→ Incident Disclosure

Specificity: Let me count hard verifiable facts:
1. "December 2021" - specific date
2. "March 2024" - specific date

3. "approximately two weeks" - approximate duration (soft)
4. "one week" - duration (soft)
5. "Canadian subsidiary" - not a named firm

QV-eligible: specific dates (December 2021, March 2024) = 2 hard verifiable facts. That's enough for Quantified-Verifiable.

Wait, let me check - are there named firms/tools? "end point protection software" is generic, "third-party monitoring partner" is unnamed. No named firms or tools.

Two specific dates = two hard verifiable facts → Quantified-Verifiable.

fact: December 2021 cyber-attack

fact: March 2024 cybersecurity breach of Canadian subsidiary

fact: approximately two weeks of operational disruption

fact: systems restored within one week (second incident)


reasoning: The paragraph describes how the full Board receives cybersecurity updates from the CFO, making the board the recipient of oversight information — a board-level communication mechanism. The CFO is a conduit, not the focus. DIS (likely Director of Information Security) is a cybersecurity-specific title on the IS list, triggering Firm-Specific. Only one QV-eligible fact, so not Quantified-Verifiable.

thinking:
Classify this paragraph about Eagle Materials Inc.

The paragraph describes the CFO providing updates to the Board, with information coming from DIT and DIS roles. The primary actor is the CFO providing updates to the Board - this is about board-level reporting/oversight.

But wait - the CFO is providing updates TO the Board. The Board is receiving updates. This is about how the board gets informed. The grammatical subject is CFO, but the purpose is board oversight communication.

Per Rule 2: "Board delegates responsibility to management → Board Governance" vs "Management role reports TO the board → Management Role"

The CFO is reporting to the Board on cybersecurity matters, drawing from the Director of Information Technology and Director of Information Security. Even though the CFO is a generic C-suite role on the exclusion list, the paragraph's focus is on the reporting mechanism itself - how cybersecurity information flows to the Board through the CFO as the communication channel. DIS is likely Director of Information Security, which falls under the IS category, so that's a firm-specific cybersecurity role. The CFO reference doesn't change the classification since it's not on the information security list. This gives me one firm-specific fact to categorize.

fact: DIS (Director of Information Security)

fact: DIT (Director of Information Technology)


reasoning: The paragraph describes the company's internal cybersecurity program components — vulnerability management, use of consultants, employee training, and vendor due diligence. Third-party risk is one bullet among four, so the dominant topic is the company's own processes (Rule 3). No named frameworks, no cybersecurity-specific roles, no named firms or tools, no dates or numbers — all items are common practices described in generic terms ('reputable cybersecurity consultants', 'experienced third-party experts', 'continuous vulnerability management').

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity risk management program components - vulnerability management, use of consultants, training, and third-party risk management. This is about internal processes.

Category: Risk Management Process - describes internal cybersecurity processes (vulnerability management, training, third-party oversight as a component). Third-party risk is mentioned but as one component among several.

Specificity: Let me check for specific facts:
- No named frameworks
- No named roles (cybersecurity-specific)
- No named tools/products
- No named firms ("reputable cybersecurity consultants" is generic)

- No dates, dollar amounts, or headcounts
- "legacy systems" lacks any real detail
- All the practices mentioned are standard industry practices

This looks like generic boilerplate without any firm-specific details or named standards.


reasoning: The paragraph's communicative purpose is to describe how the board of directors exercises oversight of cybersecurity through periodic reports from the BDT & MSD CTO — responding to Item 106(c)(1) board oversight requirements. While the CTO is the grammatical subject of the reporting sentence, the paragraph frames the board as the ultimate recipient of oversight information and describes report contents from the board's perspective. Specificity is Firm-Specific: the CTO (cybersecurity-specific title on the IS list) and BDT & MSD (named firm) are specific facts, but only BDT & MSD is QV-eligible, falling short of the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes how cybersecurity risks are evaluated by management and BDT & MSD, the CTO reports to the board, and what those reports include.

Category: The BDT & MSD CTO reports to the board. The board is receiving reports. But the grammatical subject shifts - first sentence is about management/BDT & MSD evaluating risks, second sentence is about the CTO reporting to the board, third sentence describes report contents.

The primary actor here is the CTO reporting TO the board. Per Rule 2: "CISO reports quarterly to the Board on..." → Management Role (management role is primary actor).

The CTO is clearly the primary actor doing the reporting to the board, and the paragraph focuses on the reporting relationship and what management communicates through those reports—controls, procedures, oversight mechanisms, and risk evaluations. This fits the Management Role category based on the tiebreaker rule.

But I'm also noticing the emphasis on board oversight and the cadence of reporting ("no less frequently than annually," "periodically"). The paragraph describes how the board receives and is informed about cybersecurity matters through these CTO briefings. That governance mechanism—the board's access to cybersecurity information—could make this Board Governance instead. the main focus. So Management Role seems right - it's about what the CTO does in their management capacity.

Actually, I think Board Governance is the better fit. The paragraph's core purpose is explaining how the board gets oversight of cybersecurity risks through periodic reporting. That's the disclosure requirement being addressed, not just describing management's role in evaluation.

Now I'm checking the specificity - the CTO title is cybersecurity-specific and appears on the IS list, so that's Firm-Specific.  For the cadence language like "periodically" and "less frequently than annually," those are too generic to count. BDT & MSD is the external manager, which qualifies as a named third-party firm and would be QV-eligible. So I have two potential QV facts here: the named firm and the CTO role, though the CTO itself isn't QV-eligible as a named role.

Actually, reconsidering whether BDT & MSD truly counts as a third-party firm—given that MSD Investment Corp. is externally managed by BDT & MSD Partners, it does seem like a legitimate named firm reference. That gives me one clear QV-eligible fact (the named firm), while the CTO is firm-specific but not QV-eligible. With only one QV fact, this falls into Firm-Specific.

fact: BDT & MSD CTO

fact: BDT & MSD (named external management firm)


reasoning: The paragraph describes the company's own internal cybersecurity processes — automated tools, penetration testing, vulnerability testing, tabletop exercises, employee training, and consulting outside advisors. Third-party vendor oversight is mentioned as one component of the internal program, not the central topic. No named frameworks, tools, firms, roles, dates, or quantified facts appear; all practices listed (pen testing, tabletop exercises, security audits, employee training) are common/generic and fall on the NOT list.

thinking:
Let me analyze this paragraph from Leslie's, Inc. (LESL) 10-K filing, Item 1C.

Content: Describes internal cybersecurity processes - automated tools, technical safeguards, penetration testing, vulnerability testing, security audits, tabletop exercises, employee training, third-party vendor oversight, and consulting with outside advisors.

Category: This is about the company's own internal processes. Third-party risk is mentioned but as one component. The primary topic is the company's cybersecurity processes. → Risk Management Process

Specificity: Let me check for specific facts:
- No named frameworks, no named tools, no named firms, no named roles (just "cybersecurity team"), no dates, no numbers

- The practices listed—penetration testing, vulnerability testing, security audits, tabletop exercises, employee training—are all standard industry approaches with no distinguishing details
- References to "outside advisors and experts" and "third-party vendors, service providers or customers" lack any specificity
- This reads as generic boilerplate with no concrete facts or named standards to anchor it.


reasoning: The paragraph is generic risk-factor language acknowledging the company lacks manpower, expertise, and financial resources for cybersecurity. It describes no program, process, governance structure, or strategic response — it simply states cybersecurity is costly and the company cannot effectively address it. This is analogous to the SPAC/no-operations pattern: the absence of a program is not a description of a program. There is no materiality assessment ('materially affected') that would trigger Strategy Integration, and no substantive disclosure content in any category.

thinking:
Let me analyze this paragraph.

This is from Peak Bio, Inc., a small company filing a 10-K. The paragraph discusses their lack of resources to handle cybersecurity risks. Let me classify it.

Content: The paragraph says they don't have manpower, expertise, or financial resources to handle cybersecurity. It's essentially saying they can't manage cyber risk effectively. This is generic risk language about their inability to address cybersecurity - no program described, no board oversight, no management roles, no incident.

This feels like it could be Strategy Integration (discussing resource constraints and business impact) or None/Other (generic risk language). But actually, it's more like generic risk factor language - "no assurance or guarantee" is boilerplate.

They're acknowledging vulnerability without describing any actual program, process, or strategic response. It's similar to the SPAC case where they explicitly state they lack resources and capability, except they're a biotech company rather than a shell entity. The paragraph contains no substantive cybersecurity disclosure—just risk factor boilerplate about their inability to handle cybersecurity. This leans toward None/Other since there's no program, no process, no specific facts, though the acknowledgment of zero capability does echo that SPAC example.

Looking at the language more carefully, the focus on "extremely costly and time consuming" and "do not have the manpower, expertise or financial resources" is really about the business and financial reality of their cybersecurity posture rather than any actual strategy or governance. It's generic risk language that any small company could deploy. There's no materiality assessment language, no substantive disclosure about any program or strategic decision—just "cybersecurity is hard and we can't do it well." This is clearly None/Other with Generic Boilerplate specificity: no specific facts, frameworks, roles, dates, or anything unique to this company.


reasoning: The paragraph's central topic is oversight of external vendors — security assessments during onboarding and contract review, plus use of a vendor security ratings company — making Third-Party Risk the dominant category. No named firms, frameworks, dates, or quantified details are provided ('industry leading third-party vendor security ratings company' is unnamed), so specificity remains Generic Boilerplate.

thinking:
Classify this paragraph.

Content: vendor security assessments, vendor onboarding, contract review, third-party vendor security ratings company. Central topic is vendor oversight → Third-Party Risk.

Specificity: No named frameworks, no named firms ("industry leading third-party vendor security ratings company" is unnamed), no dates, no numbers. Everything is generic. → Generic Boilerplate.


reasoning: The Audit Committee is the grammatical subject throughout — it oversees information security, receives reports, and reports to the full board. The CSO is mentioned only as the source of reports to the committee, making this Board Governance per Rule 2. The chief security officer title is a cybersecurity-specific role (IS list), yielding Firm-Specific; however, 'Audit Committee,' 'independent directors,' and 'quarterly' are all on the NOT list and do not elevate specificity further. Only one QV-eligible fact (the named role doesn't count toward QV), so it stays at Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: The Audit Committee oversees information security, reports to full board, all directors attend committee meetings, Audit Committee receives quarterly reports from CSO on security risks and mitigation.

Category: Board Governance - the Audit Committee (board committee) is the grammatical subject performing oversight. The CSO is mentioned but only in the context of reporting TO the committee.

Specificity: Let me check facts:
- "Audit Committee" - generic, on the NOT list
- "composed entirely of independent directors" - standard requirement
- "chief security officer" - this is a cybersecurity-specific title (similar to CISO).

The CSO role is a cybersecurity-specific designation, which counts as an IS fact, while "quarterly basis" is just a standard reporting cadence. That gives me one IS fact total, landing this at Firm-Specific level. There are no quantifiable details like dates, amounts, headcounts, or named entities, so this doesn't qualify as QV.

Result: Board Governance, Firm-Specific.

fact: chief security officer (CSO) — cybersecurity-specific leadership title


reasoning: The paragraph describes the company's internal Cybersecurity Plan objectives — risk assessment, infrastructure protection, data security, compliance, and ERM integration — all hallmarks of Risk Management Process. It names NERC CIP as a recognized regulatory standard, triggering Sector-Adapted, but contains no firm-specific facts from the IS list (SCADA is a generic technology term, 'Cybersecurity Plan' lacks a unique identifier, and the infrastructure types described are standard for any utility company).

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

Content: Describes the company's Cybersecurity Plan and its objectives - risk assessment, protecting PII, protecting SCADA systems, securing data, complying with NERC CIP standards, and continuous assessment integrated with ERM.

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

Specificity analysis:
- "Cybersecurity Plan" - generic program name, no unique identifier
- "SCADA systems at electric substations and natural gas plants" - describes specific infrastructure types, but this is sector-typical for utilities

- NERC CIP is a recognized industry standard, so that's sector-adapted rather than firm-specific
- The mention of electric substations and natural gas plants does indicate this company's particular operations, but it's not detailed enough to be considered firm-specific disclosure—it's just describing the types of infrastructure a utility would typically operate
- "Cybersecurity Plan" and the general objectives listed don't provide any unique identifiers that would distinguish this company from others in the sector

This looks like Sector-Adapted (2) overall—it references a named standard but doesn't reveal anything proprietary or uniquely identifying about the company beyond what you'd expect from any utility.

fact: North American Reliability Corporation Critical Infrastructure Protection (NERC CIP) Reliability Standards

type: framework

fact: Bulk Electric System Cyber Systems standards


reasoning: Despite the section header referencing 'Impact of cybersecurity risks on business strategy, results of operations or financial condition,' the paragraph body contains no materiality assessment and no substantive cybersecurity disclosure. It is entirely generic threat landscape language (hackers, nation-state actors, social engineering) that could appear in any company's filing. There is no conclusion about whether these risks have or have not materially affected the company, which would be needed for Strategy Integration. The content is boilerplate risk acknowledgment with no firm-specific detail.

thinking:
Classify this paragraph.

The paragraph discusses cybersecurity threats in general terms - types of threat actors and attack vectors. It has a header about "Impact of cybersecurity risks on business strategy" but the content is generic threat landscape description.

Category: This is generic risk language. The header mentions "Impact of cybersecurity risks on business strategy, results of operations or financial condition" which sounds like Strategy Integration, but there's no actual materiality assessment here - no statement about whether these risks have or haven't materially affected the company. It's just describing the threat landscape generically.

The header frames this as potentially material, but the actual content is just generic threat description with no substantive disclosure, materiality assessment, or company-specific details - so I'm classifying it as None/Other.


reasoning: The paragraph contains an explicit materiality assessment ('not aware of any material risks from cybersecurity threats that have materially affected or are reasonably likely to materially affect the Company, including our business strategy, results of operations, or financial condition'), which per Rule 6 makes this Strategy Integration regardless of the surrounding generic language about attackers and the appended Risk Factors cross-reference. No specific facts remain after filtering — 'management and the Board' are generic governance terms, and the cross-reference is metadata.

thinking:
Let me analyze this paragraph carefully.

The paragraph contains multiple elements:
1. Generic statement about attackers having means/motives/opportunities
2. A materiality assessment: "not aware of any material risks from cybersecurity threats that have materially affected or are reasonably likely to materially affect the Company, including our business strategy, results of operations, or financial condition"
3. A description of controls for incident escalation and disclosure
4. A cross-reference to Risk Factors

The dominant content: The materiality assessment is a key element. Per Rule 6, any paragraph with an explicit materiality assessment → Strategy Integration. The cross-reference doesn't change this.

Now I'm checking for specific facts—no named frameworks, dates beyond the filing date, roles, dollar amounts, firms, or tools. The governance references and cross-references are all boilerplate language, so this falls into Generic Boilerplate.


reasoning: The paragraph is about the person leading the cybersecurity program — their title, certification (CISSP), years of experience (20+), reporting line (VP → CIO → CEO), and the committee they chair. This passes the person-vs-function test as Management Role. Two QV-eligible hard facts: named certification (CISSP) and specific years of experience (over 20 years).

thinking:
Let me analyze this paragraph.

Content: About the VP Global Cybersecurity - their credentials, reporting lines, and the Cybersecurity Management Committee they chair.

Category: Management Role - the paragraph is about the person (credentials, experience, reporting line) and the committee they chair. The person-vs-function test: the paragraph tells us who the person is, their certification, experience, reporting structure. This is about the person.

Specific facts:
- "Vice President, Global Cybersecurity" - cybersecurity-specific title → IS
- "Certified Information Security Professional" (CISSP) - named certification → IS, QV-eligible

- Over 20 years in the field with a CISSP credential makes this QV-eligible, and the reporting structure flows from VP through CIO to CEO. The Cybersecurity Management Committee is also a named entity they chair, which qualifies as IS.

fact: Vice President, Global Cybersecurity

fact: Certified Information Security Professional (CISSP)

fact: over 20 years of cybersecurity experience

fact: Chief Information Officer

fact: Cybersecurity Management Committee