reasoning: The paragraph describes an actual cybersecurity incident — unauthorized access to an employee's email account, fraudulent fund diversion, detection, and response. While it includes a materiality conclusion ('immaterial impact'), the dominant content is the incident narrative (what happened, how it was detected, what the threat actor did), making Incident Disclosure the primary category. Specificity is Firm-Specific based on the year reference '2024'; however, no named firms, tools, dollar amounts, or second hard verifiable fact are present to reach Quantified-Verifiable.

thinking:
Classify this paragraph.

Content: Describes an actual cybersecurity incident - unauthorized access to employee email, fraudulent fund diversion, detection timeline, and impact assessment.

Category: This describes what happened (incident narrative) AND includes a materiality/impact assessment. The dominant content is the incident description - what happened, how it was detected, what the threat actor did. The materiality conclusion ("immaterial impact") is subordinate to the incident narrative. → Incident Disclosure

Specificity: Let me check for hard verifiable facts:
- "2024" - this is a year reference but not a specific date (month+year). It's just "2024" which is vague.

The opening "2024, we became aware..." looks like it was truncated from something more specific like "In [month] 2024", but as written it only gives the year. That's borderline on specificity - better than nothing, but not as precise as a full month+year reference.

Looking at what counts as a hard verifiable fact: I have "2024" as a date reference, which is similar to how "fiscal 2025" would count. The unauthorized email access describes the incident type but isn't a named system. There are no named firms, tools, dollar amounts, or headcounts mentioned.

For QV I'd need two hard facts - I only have the year, so that doesn't qualify. But for Firm-Specific, that one date reference is enough to mark it as such.

fact: 2024 (year the incident was discovered)


content_category: Management Role

category_confidence: medium

specificity_confidence: high

reasoning: The paragraph's primary content is about the people — the CEO's 15+ years of IT experience, the acknowledgment that other officers have limited cybersecurity experience, and executive officers' reporting relationship to the board. While board oversight is mentioned in the opening clause, the bulk of the paragraph describes management personnel and their qualifications (person-vs-function test favors Management Role). Specificity is Firm-Specific: '15 years of experience' is a specific quantified fact (QV-eligible), but it is the only hard verifiable fact — CEO is generic C-suite per the NOT list, and no other named firms, tools, dates, or certifications appear.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph carefully.

This is a multi-topic paragraph. Let me break down the content:

1. "board of directors is collectively responsible for oversight of risks from cybersecurity threats" - Board Governance
2. "executive officers oversee the overall processes to safeguard data and comply with relevant regulations and will report material cybersecurity incidents to the board" - Management Role
3. "CEO has more than 15 years of experience in the field of information technology with a focus on software development. Some of his experience and knowledge relates specifically to cybersecurity." - Management Role (person's background/experience)

4. "Other executive officers of the Company have more limited experience in the area of cybersecurity." - Management Role
5. "When and where necessary... will consult with external advisers" - Risk Management Process (minor)
6. "executive officers will promptly inform, update, and seek the instructions of the board" - Management Role/Board Governance

The dominant content here is about management - the CEO's qualifications, executive officers' experience levels, their reporting to the board. The board mention is brief ("collectively responsible for oversight"). The bulk is about the people - CEO's 15 years of IT experience, other officers' limited experience. This is about the persons, not the function.

Person-vs-function test: The paragraph describes WHO these people are (CEO's experience, other officers' limited experience) rather than WHAT the program does. → Management Role

Specificity:
- "CEO" - generic C-suite, NOT on the IS list
- "more than 15 years of experience" - specific number → quantified fact (QV-eligible)
- "board of directors" - generic
- "executive officers" - generic

The CEO falls under generic C-suite roles that don't qualify, but that specific 15-year figure is a concrete data point. That's one QV-eligible fact here, which points to Firm-Specific (3).

fact: CEO has more than 15 years of experience in information technology

type: quantified


content_category: Risk Management Process

category_confidence: high

reasoning: The paragraph describes the company's internal cybersecurity processes — framework adoption, risk assessments, vulnerability management, penetration testing, incident response planning, and training — making it squarely Risk Management Process. NIST CSF is named (triggering Sector-Adapted), but no firm-specific facts from the IS list are present: 'IT security team' is a generic IT title, third parties are unnamed, practices like pen testing and tabletop exercises are common, and the pillar areas listed are standard organizational categories.

thinking:
Classify this paragraph.

Content: Describes the company's cybersecurity program - NIST CSF framework, risk-based approach, IT security team processes, various security activities, incident response plan, training, third-party consultants.

Category: Risk Management Process - clearly about internal processes, tools, methodologies.

Specificity: NIST CSF is named → at least Sector-Adapted. "IT security team" - is this a cybersecurity-specific title? It's generic. No named tools, no named firms, no dates, no headcounts. The pillar areas (security and compliance, application security, infrastructure security, data privacy) are organizational but generic.

The paragraph doesn't contain any firm-specific facts from the IS list, and "IT security team" isn't a cybersecurity-specific title either. All the practices mentioned—pen testing, vulnerability management, and the unnamed third parties—are standard industry approaches. This lands it at Sector-Adapted since NIST CSF is explicitly referenced but nothing else points to this particular organization.

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

type: framework


content_category: Third-Party Risk

reasoning: The paragraph's central topic is oversight of external parties: third-party consultants performing datacenter audits, policies governing third-party service provider risks, and SOX/SSAE-16 auditing of a core technology vendor. While risk assessment is mentioned, the dominant communicative purpose is describing requirements imposed on and oversight of vendors. SSAE-16 is a named attestation standard triggering Sector-Adapted, but no firm-specific facts (no named vendors, no dates, no headcounts) elevate it further.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party consultants/auditors for risk assessment, datacenter audits, policies for third-party service provider risks, and SOX auditing of a core third-party provider with SSAE-16 certification.

Category: This is primarily about third-party risk oversight. The central topic is oversight of external parties - consultants performing audits, policies for third-party service provider risks, and auditing a core third-party provider. While it mentions risk assessment, the dominant theme is vendor/third-party oversight.

Specificity: Let me check for specific facts:

- SSAE-16 is a recognized attestation standard (predecessor to SSAE-18/SOC reports), which qualifies as a named standard → Sector-Adapted
- "Sarbanes Oxley process" is a regulatory requirement, not a cybersecurity framework
- "Datacenter" audit "annually" is a generic cadence
- No named firms, specific dates, headcounts, or tools mentioned
- The core third-party service provider is unnamed, so nothing firm-specific here

The vendor's SSAE-16 certification is naming a standard rather than claiming firm-specific details, so this falls under Sector-Adapted. Overall, this is Third-Party Risk management at the Sector-Adapted level.

fact: SSAE-16 certification required of core third-party service provider


content_category: None/Other

reasoning: This paragraph acknowledges that regulations exist and that non-compliance would be harmful—a truism for every public company. It does not describe any process, program, or framework the company uses to comply, names no specific regulation, and makes no materiality assessment. Per the codebook's Case 9 guidance, generic regulatory compliance language with no company-specific content is None/Other.

thinking: This matches Case 9 from the codebook exactly.


reasoning: The paragraph describes the company's internal incident management processes — tracking, logging, escalation procedures, materiality assessment, and consultation with outside counsel. These are all internal cybersecurity processes, not vendor oversight (vendors are mentioned only as part of incident scope). No named frameworks, cybersecurity-specific roles, dates, tools, or other facts from the IS list appear; 'cross-functional working group,' 'outside counsel,' and 'senior management' are all on the NOT list.

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

Content: Describes incident management teams tracking/logging incidents, cross-functional working group review, escalation processes, materiality assessment, consultation with outside counsel.

Category: This is about internal processes - incident tracking, escalation, review by working groups. It's Risk Management Process. It mentions vendors/third-parties but only as part of the scope of incident tracking, not as the central topic of vendor oversight.

Specificity: Let me check for specific facts:

- "incident management teams" - generic
- "across Alphabet, our vendors, and other third-party service providers" - company self-reference, generic
- "cross-functional working group" - generic (no specific departments named)
- "outside counsel" - unnamed entity
- "senior management" - generic

No named frameworks, no specific roles from the IS list, no dates, no numbers. This is Generic Boilerplate.


reasoning: The paragraph describes internal cybersecurity processes: threat notification, periodic security education, system upgrade communication, and risk identification/assessment responsibilities. The CFO mention is incidental attribution (generic C-suite per the NOT list), and 'expert consultants' are unnamed. No named frameworks, tools, dates, or firm-specific facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes threat notification processes, periodic educational notices, system modification notifications, and responsibility for risk identification residing with expert consultants who report to CFO.

Category: This is about internal processes - threat notification, education, system upgrades, risk identification. The CFO mention is incidental attribution. This is Risk Management Process.

Specificity: Let me check for specific facts:
- "Chief Financial Officer" - this is on the NOT list (generic C-suite: CEO, CFO, COO)
- "expert consultants" - unnamed entities, on the NOT list

- "Periodic educational notices" - generic practice
- No frameworks, no named tools, no dates, no numbers

This is generic boilerplate with no concrete facts or named standards to extract.


reasoning: The paragraph describes the company's internal cybersecurity processes: framework-based controls, a cybersecurity plan, regular reviews, and an information security policy with outside expert meetings. No specific frameworks are named (just 'a combination of cyber security frameworks'), no named roles, no named firms, no dates or numbers — all language is generic and could apply to any company.

thinking:
Let me analyze this paragraph.

Content: Describes the company's internal cybersecurity processes - framework usage, cybersecurity plan development, regular reviews, information security policy, monthly meetings with outside experts.

Category: Risk Management Process - describes internal processes, framework adoption, monitoring. The outside experts are mentioned as a component of internal processes, not as vendor oversight.

Specificity: Let me check for specific facts:
- "cyber security frameworks" - no specific framework named
- "guidelines and best practices" - generic
- "cybersecurity plan" - generic program name
- "reviewed regularly" - generic cadence

- "information security policy" - generic
- "monthly meetings with outside cybersecurity experts" - "monthly" is a generic cadence, "outside cybersecurity experts" is unnamed

No named frameworks, no named roles, no specific facts from the IS list. This is Generic Boilerplate.


reasoning: This paragraph from a self-described 'start-up company with limited operations' contains only generic risk language about cyberattacks affecting companies worldwide. It describes no cybersecurity program, governance structure, management role, or incident — it is a general statement about the threat landscape that could appear in any filing unchanged, with no substantive disclosure content.

thinking:
Let me analyze this paragraph.

This is a start-up company with "limited operations" describing generic cybersecurity risk landscape. No specific program, no specific processes, no named frameworks, no specific facts. It's generic risk language about cyberattacks affecting companies generally.

Content category: None/Other - This is general risk language about cybersecurity threats that could apply to any company. There's no substantive disclosure of any program, process, governance structure, or incident. The company states it has "limited operations" and then describes generic cyber threats.

Specificity: Generic Boilerplate - No named frameworks, no specific facts, nothing firm-specific.


reasoning: The paragraph describes the company's incident response plan processes — escalation, severity assessment, monitoring, and remediation. The Information Security Officer is mentioned as attribution but the substantive content is about the plan and its functions, making this Risk Management Process. Contains two IS-list facts (cybersecurity-specific role + named non-generic committee), but neither is QV-eligible, so Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes monitoring of cybersecurity incidents, incident response plan, reporting structure, and process for identifying/assessing severity.

Category: The paragraph mentions the Information Security Officer but then focuses on the incident response plan and its processes. The ISO is mentioned as attribution. The bulk is about the company's internal processes - incident response planning, escalation, reporting, severity assessment, remediation. This is Risk Management Process.

Specificity:
- "Information Security Officer" - this is a cybersecurity-specific title → IS list → Firm-Specific
- "Operational Risk Committee" - this is a named non-generic committee → IS list → Firm-Specific

- "Board of Directors" and "incident response plan" are generic references, so they don't add firm-specific weight. The two IS facts here—the Information Security Officer and Operational Risk Committee—are firm-specific roles and committees, but they're not QV-eligible, making this overall Firm-Specific (3).

fact: Information Security Officer

fact: Operational Risk Committee


content_category: Board Governance

reasoning: The board of directors is the grammatical subject performing oversight of cybersecurity risk management, making this Board Governance. The paragraph contains no specific facts from the IS list — only generic references to 'board of directors' and 'management,' with no named cybersecurity roles, frameworks, committees, or dates — placing it at Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Board oversight of cybersecurity risk management, board responsibility for monitoring, management responsible for day-to-day.

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

Specificity: Let me check for specific facts.
- "board of directors" - generic governance, NOT list
- "management" - generic, NOT list
- No named frameworks, no specific roles (CISO etc.), no dates, no named committees beyond the board itself
- No firm-specific facts from the IS list

This is Generic Boilerplate. Could be pasted into any company's filing.


reasoning: This paragraph describes the general importance of data integrity, privacy, and IT systems to the company's business operations. It contains no substantive cybersecurity disclosure — no processes, frameworks, governance structures, incidents, or materiality assessments. It is general business language that could appear in virtually any company's filing.

thinking: General business language about IT systems and data security. No cybersecurity-specific disclosure.


reasoning: The paragraph's central topic is oversight of third-party vendors and contractors — their annual assessment for cybersecurity risks and the expectation that they meet security requirements. This is vendor oversight as the primary subject, not a component of an internal process description. No named standards, specific dates, named firms, or other IS-list facts are present; 'annual basis' is a generic cadence and 'certain information security requirements' is vague.

thinking:
Classify this paragraph.

Content: About third-party vendor oversight - annual assessment of vendors, security requirements for vendors with access to sensitive data. Central topic is vendor oversight.

Category: Third-Party Risk

Specificity: No named standards, no named firms, no specific dates, no specific roles. "annual basis" is generic cadence. "certain information security requirements" is vague. No IS-list facts.

Generic Boilerplate.


reasoning: The paragraph's communicative purpose is about how the Audit Committee is kept apprised of cyber risks and enabled to assess program effectiveness — board oversight is the goal, with management reporting as the mechanism. The named 'Enterprise Risk and Compliance Committee' is a non-generic committee unique to this company, triggering Firm-Specific.

thinking:
Let me analyze this paragraph.

The paragraph describes management reporting cybersecurity risks to two committees. The primary action is about reporting/communication flow from management to committees.

Who is the grammatical subject? "Management" - but the paragraph is about the reporting relationship and what the committees receive. The purpose is to keep the Audit Committee apprised and enable assessment of effectiveness.

This is a borderline Board Governance vs Management Role case. The paragraph describes management reporting TO the board committees. Per Rule 2: "Management role reports TO the board → Management Role." But wait - the focus here is on keeping the Audit Committee informed and enabling their assessment. The board committee's oversight function is the purpose described.

I'm reconsidering the classification here. The grammatical subject is "Management," but the real purpose of the paragraph centers on the Audit Committee's information needs and their ability to assess effectiveness—that's the board's oversight function. Rule 2 would normally classify this as a Management Role since management is doing the reporting, but "Management" here is generic rather than a specific management role. The tiebreaker points toward Board Governance because the paragraph's focus is fundamentally about enabling board oversight, not describing a management responsibility.

Looking at the specificity: "Enterprise Risk and Compliance Committee" is a named, non-generic committee that's firm-specific, while "Audit Committee" and "Management" are both generic terms. That gives me one specific fact, making this Firm-Specific.


reasoning: The paragraph describes how the company manages cybersecurity risk through limiting its cyber footprint — restricted system access, no vendor/customer access, isolated website and file server. This is about the company's own internal risk mitigation approach, making it Risk Management Process. It contains multiple specific headcounts (9 total employees, 3 with system access, 1 IT consultant) that are independently verifiable, meeting the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph from Solitario Resources Corp.

Content: This describes how the company mitigates cybersecurity risks through limited cyber exposure. It describes their approach - limited employee access (3 employees + 1 IT consultant out of 9), no vendor/customer access, no public-facing transactions, website maintained offsite and separate from file server.

Category: This is describing the company's risk management approach - how they handle cybersecurity by limiting exposure. It's about their internal processes and risk mitigation strategy. Risk Management Process.

Specificity: Let me check for specific facts:

- "nine employees (six full-time, three part-time)" - specific headcount = quantified
- "three employees plus one third-party information-technology consultant" - specific headcount = quantified
- The IT consultant is named as a role but it's generic ("IT Consultant")
- Website maintained offsite, file server in office - these are firm-specific architectural details but not named systems

I'm seeing two quantified facts here: the total employee count of nine and the specific access count of three employees plus one IT consultant. These are concrete numbers tied to their cybersecurity setup, which makes them QV-eligible facts.

fact: Nine employees total (six full-time, three part-time)

fact: Three employees plus one third-party IT consultant have access to cyber system


reasoning: The paragraph is structured around the CTO as the central figure — naming Mr. Eliran Ben-Zikri, describing his reporting lines (to audit committee, Co-CEOs, CFO), and providing his personal background (Israeli Defense Force, 10+ years experience, prior roles at eToro and SimilarWeb). While mid-paragraph sentences describe report content and cross-functional teams (function), the paragraph's frame and primary communicative purpose is establishing who the CTO is and what makes them qualified. QV-eligible hard facts include specific years of experience, and two named prior employers (eToro, SimilarWeb), exceeding the two-fact threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. The CTO manages the cybersecurity program and what the program covers
2. Reporting to audit committee, CEOs, CFO
3. Cross-functional teams
4. Content of reports to management
5. CTO's background - Israeli Defense Force, 10+ years experience, eToro, SimilarWeb

Person-vs-function test: The paragraph starts by describing what the program does (strategy, policy, standards, architecture, processes), then reporting cadences, then shifts to the CTO's personal background. The last sentence is clearly about the person.

The middle portion describes functions, but I'm noticing the paragraph is actually mixed—it opens with program responsibilities and reporting structure, then pivots to the CTO's credentials and experience. Stripping away the name and title, what's left is still substantive: the program's scope, governance, and reporting cadence. But there's also considerable weight given to the person's background, so it's not purely functional. The reporting structure and CTO's personal credentials are substantial enough to tip this toward Management Role, especially since the CTO serves as the grammatical subject across most sentences and the paragraph frames everything around their role and background.

Looking at the specific facts here: the CTO title itself, the named individual Mr. Eliran Ben-Zikri, over 10 years of experience, and prior roles at eToro and SimilarWeb all point to this being Management Role content. The experience duration and named employers are particularly strong signals.

fact: Chief Technology Officer (CTO)

fact: Mr. Eliran Ben-Zikri

fact: over 10 years of experience in cloud technology

fact: eToro (prior employer)

fact: SimilarWeb (prior employer)


content_category: Strategy Integration

reasoning: The paragraph contains two explicit materiality assessments — one backward-looking ('have not materially affected') and one forward-looking ('reasonably likely to materially affect') — making it 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.


reasoning: The CEO and management are the grammatical subjects actively engaged in cybersecurity oversight, with a reporting structure to update the Board — placing management as the primary actor reporting TO the board (Rule 2). However, no credentials, background, or cybersecurity-specific titles (CISO, CTO, CIO) are provided; 'CEO' is generic C-suite per the NOT list, 'Board of Directors' is generic governance, and 'at least annually' is a generic cadence, leaving no specific facts to elevate beyond boilerplate.

thinking:
Let me analyze this paragraph.

Content: CEO and management oversee strategic direction including cybersecurity risks. Company updates CEO and Board periodically/annually on cybersecurity program.

Category: The grammatical subjects are "CEO and management" and "the Company." This describes management's engagement in oversight and briefing cadence to CEO/Board. The primary actors are management (CEO), not the board. But it also mentions updating the Board.

The paragraph describes management's active engagement in overseeing cybersecurity, and the briefing structure (updating CEO and Board). The CEO is the primary actor here - "CEO and management are actively engaged." The second sentence describes updating both CEO and Board.

This is primarily about management's oversight role and their reporting relationship to the Board. The CEO and management are the active agents driving cybersecurity oversight, while the Board receives periodic updates. Even though both governance and management elements are present, the focus is on what management does rather than how the Board delegates or governs, so this falls under Management Role. The paragraph focuses on governance structure and reporting lines rather than specific risk management processes, so it fits better under Management Role since the CEO and management are the primary subjects describing their oversight responsibilities and relationship with the Board. I'll categorize it as Management Role.

Looking at the specificity now—the language is entirely generic: "CEO" and "Board of Directors" are standard C-suite references, "periodically, and at least annually" is vague timing, and there are no named frameworks, specific facts, or cybersecurity-specific titles like CISO. This is clearly Generic Boilerplate.


reasoning: The paragraph describes the function of a security team — risk assessment, security controls, and incident response — making it about internal processes rather than the person. 'Information technology manager' is a generic IT title (per the NOT list), not a cybersecurity-specific role like CISO, and no frameworks, dates, tools, or other specific facts are present.

thinking:
Classify this paragraph.

Content: Describes a security team led by an IT manager responsible for risk assessment, security controls, and incident response. This is about the function/process, not the person's credentials.

Category: The paragraph describes what the team does (risk assessment, security controls, incident response). The "information technology manager" is mentioned as attribution. Using the person-vs-function test: remove the role and the paragraph still describes processes. → Risk Management Process

Specificity: "information technology manager" — is this a cybersecurity-specific title? The IS list includes "CISO, CTO, CIO, VP of IT/Security, Information Security Officer, Director of IT Security." "Information technology manager" is more like "IT Manager" which is on the NOT list ("Head of IT", "IT Manager", "Director of IT"). So this doesn't count as a specific fact.

There are no named frameworks, specific dates, tools, or metrics present. → Generic Boilerplate


reasoning: This paragraph surveys the company's entire cybersecurity program. While it mentions board oversight (2 sentences) and names the CISO as leader, the dominant content describes internal processes: continual monitoring, advanced security measures, system audits, incident response planning, and management briefings. Applying the person-vs-function test, the CISO/CIO are mentioned as attribution — the paragraph is about what the program does, not who the people are. CISO and CIO are cybersecurity-specific titles on the IS list, reaching Firm-Specific, but named roles do not count toward the QV threshold so it stays at Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

This paragraph covers multiple topics: CISO leadership, board oversight, risk management processes, and incident response. I need to determine the dominant category.

Let me break it down:
- "Led by our CISO, we have a team of skilled internal and external cybersecurity professionals" - Management Role attribution
- "Our Board of Directors has oversight of our cybersecurity and risk management programs" - Board Governance

- The Board receives semiannual updates from leadership and external experts - Board Governance
- Continual monitoring, advanced security measures, and system audits - Risk Management Process
- Incident response planning with immediate actions - Risk Management Process
- Regular meetings between the cybersecurity team and executive leadership - Management Role/Risk Management Process

The dominant theme here is Risk Management Process, since most of the content describes the company's actual security operations and procedures, though board governance is also a significant component throughout. is attribution.

Actually, let me reconsider. The paragraph has roughly equal parts board governance and risk management process. The opening mentions CISO (attribution), then board oversight (2 sentences), then internal processes (2 sentences), then management meetings (1 sentence).

The title "Leadership and Governance" suggests the framing is about oversight structure. But the bulk of content describes processes. Let me apply the person-vs-function test: removing the CISO/CIO titles, the paragraph still describes processes and oversight structure.

I think Risk Management Process is the dominant category - the paragraph describes the company's overall cybersecurity program including monitoring, incident response, and reporting structures. The board mention is a component but not the central topic.

Actually, re-reading more carefully: Board governance gets about 2 sentences, RMP gets about 3 sentences. The paragraph is really a survey of the entire program. The dominant content is the internal processes.

Category: Risk Management Process

Specificity: The CISO and CIO are named roles that appear on the IS list, making them firm-specific facts. These don't count toward the QV threshold since they're identified positions rather than quantifiable metrics.

fact: Chief Information Security Officer (CISO)

fact: Chief Information Officer (CIO)


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected and are not reasonably likely to materially affect us, including our business strategy, results of operations, or financial condition'), making it Strategy Integration per Rule 6. The appended cross-reference to Item 1A Risk Factors does not change the classification. No specific facts are present—the language is standard boilerplate materiality disclaimer.

thinking:
Materiality assessment + cross-reference. Per Rule 6, the materiality assessment is the substantive content → Strategy Integration. The cross-reference doesn't change that.

Specificity: Boilerplate materiality language, no specific facts.


reasoning: The Board and Audit Committee are the grammatical subjects throughout, describing how the Board received a cybersecurity report and delegated oversight to the Audit Committee. 'Fiscal year 2024' is the sole IS-list fact (specific date); Audit Committee is generic per the NOT list, and 'periodic' is a generic cadence, so only one qualifying fact → Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Board received a report, delegated oversight to Audit Committee, Audit Committee receives periodic reports on cybersecurity program and financial reporting controls.

Category: The grammatical subjects are "our Board" and "our Audit Committee" - this is about board/committee oversight. → Board Governance

Specifics:
- "fiscal year 2024" - specific date
- "Audit Committee" - generic (on the NOT list)
- "periodic reports" - generic cadence

Only one fact from the IS list: "fiscal year 2024" as a specific date. That's one fact → Firm-Specific.

Checking the verifiable facts, I've got just the one concrete date here, so this lands in Firm-Specific.

fact: fiscal year 2024


reasoning: The Board and Audit Committee are the grammatical subjects performing oversight of cybersecurity risk, making this Board Governance. All entities mentioned (Board, Audit Committee, management) are on the NOT list as generic governance terms, with no named frameworks, cybersecurity-specific roles, dates, or other specific facts.

thinking:
Classify this paragraph.

Content: Board and Audit Committee oversight of cybersecurity risk, overseeing management's implementation, updates on incidents.

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

Specificity: "Board", "Audit Committee" are generic governance terms on the NOT list. No cybersecurity-specific roles, no named frameworks, no dates, no specific facts. → Generic Boilerplate (1)


reasoning: The paragraph describes how the company maintains a security governance structure to evaluate and address cybersecurity risks, with the CEO consulting others to develop strategies. Applying the person-vs-function test, the content is about the process (maintaining governance structure, consulting experts, developing strategies, aligning with business objectives), not about the CEO's credentials or background. The Board/Audit Committee mention is parenthetical ('as described below'). CEO and CFO are generic C-suite titles (NOT list), 'third-party IT consultants and computer security firms' are unnamed entities (NOT list), and Audit Committee is standard governance — no specific facts remain after filtering.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes a security governance structure. Let me break it down:

- "Under the ultimate direction of our Chief Executive Officer" - CEO directing
- "with oversight from our Board and Audit Committee" - board oversight mentioned
- "we maintain a security governance structure to evaluate and address cybersecurity risks" - process description
- "Our Chief Executive Officer regularly consults with our Chief Financial Officer and third-party IT consultants and computer security firms" - CEO consulting with others
- "leveraging and relying upon these consultants' cybersecurity expertise" - third-party expertise

- "to develop strategies that assess and address threats while aligning cybersecurity efforts with business objectives" - the strategies focus on threat assessment and alignment with business goals

So the company's approach is centered on the CEO directing a governance structure that involves consulting with financial and security experts to create strategies that both manage cybersecurity risks and support the company's broader business objectives.

Looking at what makes this specific or notable: the CEO and CFO are just generic titles, the board and audit committee are standard governance bodies, and the consultants aren't named. There are no specific frameworks, dates, firms, or metrics mentioned anywhere.

This is generic boilerplate language about risk management processes.


reasoning: The board is the grammatical subject overseeing cybersecurity risk, and it formed a specific committee for this purpose, making this Board Governance. The 'cybersecurity risk committee' is a named non-generic committee (not the standard Audit Committee), qualifying as a firm-specific fact, but there are no additional QV-eligible hard facts to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Board formed a cybersecurity risk committee to oversee cybersecurity program. Board is the primary actor.

Category: Board Governance - the board and board committee are the grammatical subjects performing oversight.

Specificity: "cybersecurity risk committee" - this is a named non-generic committee (not Audit Committee), so it's on the IS list → Firm-Specific.

Any QV facts? No specific dates, dollar amounts, headcounts, named firms/tools/certifications. Just one IS fact (named committee).

So this is Firm-Specific.

fact: cybersecurity risk committee


reasoning: This paragraph does not itself make a materiality conclusion — it uses meta-language ('We describe whether and how...') to point the reader to the Item 1A risk factor section where the actual materiality assessment resides. Unlike a paragraph that states 'have not materially affected,' this one only tells you where to find the discussion, making it a cross-reference rather than a substantive disclosure. The named risk factor heading is a section title, not cybersecurity content.

thinking:
Materiality assessment with cross-reference. The paragraph explicitly states "have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations, or financial condition" — this is a materiality assessment. Per Rule 6 and the codebook, a cross-reference appended to a materiality assessment does not change classification to None/Other.

But wait — this paragraph doesn't actually make a materiality *conclusion*. It says "We describe whether and how risks... have materially affected..." — it's saying that the description is located elsewhere (in Item 1A). It's pointing to where the materiality assessment lives, not making one here.

Actually, this is just a pointer to Item 1A using materiality language as framing. The codebook is clear: if it only directs me elsewhere without making a substantive claim about impact, it's None/Other. Since this paragraph doesn't conclude whether risks have or haven't materially affected the business—it just says the assessment exists somewhere else—I'm classifying it as None/Other, Specificity 1.


content_category: Incident Disclosure

specificity_confidence: medium

reasoning: The paragraph references actual past cyber incidents (previously disclosed in specific quarterly filings) and describes post-incident remediation actions (implementing additional safeguards). While thin on incident details, it acknowledges real events and response actions, fitting Incident Disclosure. Two specific quarterly report dates (June 30, 2023 and September 30, 2023) are independently verifiable facts, meeting the QV threshold.

thinking:
Let me analyze this paragraph.

Content: References past cyber incidents (previously disclosed), mentions implementing additional safeguards, and includes a materiality reference.

Category: This describes a past incident and response actions taken. It references real events ("cyber related incidents, as previously disclosed"). The paragraph mentions implementing safeguards after the incident - this is incident response/remediation. The dominant content is about what happened (incident) and what they did about it (remediation). This fits Incident Disclosure.

Wait - let me reconsider. The paragraph references past incidents but doesn't describe what happened. It says "we have implemented additional safeguards designed to detect and prevent cybersecurity events that may have a material adverse effect." This is more about the response to an incident rather than describing the incident itself.

The paragraph does acknowledge real events and the remediation that followed, but the incident details themselves aren't spelled out here—they're referenced elsewhere. The core message is really about the safeguards implemented in response, which leans more toward Strategy Integration or Risk Management Process rather than a full Incident Disclosure. Looking at the tiebreakers, this brief mention of past incidents with the materiality conclusion as the focal point suggests Strategy Integration is the better fit.

Actually, wait—the paragraph does describe response actions explicitly: "we have implemented additional safeguards designed to detect and prevent cybersecurity events." That's a remediation action tied to real incidents, which pushes this toward Incident Disclosure territory. The dates are specific too—quarters ended June 30, 2023 and September 30, 2023. Even though it's thin on incident details and cross-references other filings for the full picture, the fact that it's describing what the company did in response to actual events makes this Incident Disclosure.

For specificity, those two dates are independently verifiable facts—they're specific enough to count as Quantified-Verifiable. So I'm looking at 2 hard facts here, which qualifies it as QV-eligible.

fact: Quarter ended June 30, 2023

fact: Quarter ended September 30, 2023


reasoning: The paragraph discusses cybersecurity insurance as a financial risk mitigation strategy, which is a business/financial consequence of cyber risk — squarely Strategy Integration. However, it names no insurer, no coverage amount, no deductible, and no other specific detail, making it Generic Boilerplate.

thinking: Classify this paragraph about cybersecurity insurance.


reasoning: The Board and its Audit and Risk Committee are the grammatical subjects throughout, describing delegation of cybersecurity oversight and reporting flows — classic Board Governance. The 'Audit and Risk Committee' is a non-generic committee name (distinct from the standard 'Audit Committee'), and the 'Response Team' is a named internal team, providing two firm-specific facts. However, neither qualifies as QV-eligible (no dates, dollar amounts, named third-party firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: Board delegates to Audit and Risk Committee, which oversees cybersecurity programs and receives reports from Response Team. Board is the primary actor.

Category: Board Governance - the board and board committee are the grammatical subjects performing oversight.

Specificity: "Audit and Risk Committee" - is this a named non-generic committee? The codebook says "Audit Committee" is generic/standard, but "Audit and Risk Committee" is a specific committee name unique to this company. Also "Response Team" is mentioned as a named internal team. These are firm-specific facts.

Any QV-eligible facts? No specific dates, dollar amounts, headcounts, named third-party firms, named products/tools.

The committee name and internal team are both firm-specific identifiers, so this falls into Firm-Specific (3) rather than QV.

fact: Audit and Risk Committee (non-generic committee name, distinct from standard 'Audit Committee')

fact: Response Team (named internal team)


reasoning: The paragraph describes the company's own internal cybersecurity program—defense, detection, remediation, policies, and crisis response planning—which are all internal processes. No named frameworks, specific roles, dates, tools, or any firm-specific facts are present; the language is entirely generic and could apply to any company.

thinking:
Classify this paragraph.

Content: Describes the company's cybersecurity program - defense, detection, remediation, policies, crisis response plan. 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 facts. Generic descriptions of "defense, rapid detection and rapid remediation," "cybersecurity policies," "crisis response and management plan" - all generic program names.

This is just generic boilerplate without any substantive detail.


reasoning: This multi-topic paragraph spans Management Role (CIO credentials, team certifications), Board Governance (Sustainability & Safety Committee oversight, briefing cadence), and Risk Management Process (monitoring, incident response). Board Governance is dominant by sentence count (5 of 10 sentences detail the committee structure, oversight transition, and briefing frequency). Multiple QV-eligible hard facts are present: 'over three decades' of experience, named certifications (CISM, CISSP), and a specific date ('Beginning in 2025').

thinking:
This is a long, multi-topic paragraph. Let me analyze it.

The paragraph covers:
1. Team of cybersecurity professionals led by VP of IT / CIO / CISO ("CIO") - with "over three decades of experience" - Management Role content
2. Team certifications: ISA 62443, ISC2, CISM, CISSP - Management Role content
3. Sustainability & Safety Committee oversight beginning in 2025, moved from full Board - Board Governance content
4. Committee receives quarterly updates from CIO - Board Governance

5. Full Board receives annual update - Board Governance
6. Processes for monitoring, security measures, audits - Risk Management Process
7. Incident response plan - Risk Management Process
8. CIO meets with executive management - Management Role/Board Governance

This paragraph is truly multi-category. Let me apply the dominant category rule.

The paragraph spans Management Role (credentials, experience of team and CIO), Board Governance (committee oversight, briefing cadence), and Risk Management Process (monitoring, incident response).

Looking at text allocation:
- Management Role (team, CIO experience, certifications): ~3 sentences
- Board Governance (committee oversight, briefing cadence): ~4 sentences
- Risk Management Process (monitoring, incident response): ~2

The CIO leads a seasoned cybersecurity team with relevant certifications, and oversees a governance structure where the Sustainability & Safety Committee receives quarterly briefings starting in 2025, with the full Board getting annual updates. The team maintains monitoring processes, conducts audits, and has an incident response plan in place, with the CIO also coordinating directly with executive management. The Board Governance section dominates with five sentences covering the Sustainability & Safety Committee's oversight responsibilities, the transition from full Board oversight, and briefing cadences. Management Role and Risk Management Process each contribute fewer sentences, so the paragraph's primary focus is clearly on how board-level governance structures handle cybersecurity oversight.

Looking at the specificity, I've identified several quantified and verifiable facts: the CIO/CISO holds relevant certifications including CISM and CISSP, brings over three decades of experience, and the committee structure takes effect beginning in 2025. These concrete details—the specific certifications, the quantified years of experience, and the defined timeline—meet the threshold for being considered quantified-verifiable claims.

fact: Vice President of Information Technology, Chief Information Officer and Chief Information Security Officer (CIO)

fact: over three decades of experience

fact: ISA 62443 Cybersecurity Expert certification

fact: CISM certification

fact: CISSP certification

fact: Sustainability & Safety Committee

fact: Beginning in 2025


reasoning: The paragraph describes the company's internal cybersecurity controls and tools — MFA, firewalls, IDS/IPS, vulnerability testing, IAM, and a 24x7 SOC. These are all common security practices listed on the ✗ NOT list; no named frameworks, named products/tools, named firms, specific dates, or other IS-list facts are present, so this remains Generic Boilerplate.

thinking:
Classify this paragraph about JELD-WEN's cybersecurity tools and practices.

Content: Describes internal security measures - policies, software, training, hardware, managed services, MFA, firewalls, IDS/IPS, vuln/pen testing, IAM, 24x7 SOC. This is about the company's own internal processes and tools.

Category: Risk Management Process - describes internal cybersecurity processes and controls.

Specificity: Let me check the facts:
- "multifactor authentication", "firewalls", "intrusion detection and prevention systems", "vulnerability and penetration testing", "identity and access management systems" - these are common practices, NOT specific facts

- "24x7 security operations center" is also a standard practice description
- No named frameworks, standards, tools, products, firms, dates, dollar amounts, or headcounts mentioned. This is generic boilerplate language without firm-specific details.


reasoning: The paragraph's dominant content describes the company's general approach to cybersecurity risk management — policies, processes, investments, and security measures. While it includes a materiality disclaimer ('have not materially affected our business to date'), the majority of the text is devoted to describing their risk management posture. Board and management are mentioned only as generic attribution ('Our board of directors and our management actively oversee'), not as the primary subject. No named frameworks, cybersecurity-specific titles, dates, tools, or firm-specific facts appear — everything is interchangeable boilerplate.

thinking:
Let me analyze this paragraph from Luvu Brands, Inc. (LUVU) 10-K filing, Item 1C.

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

1. Generic threat acknowledgment
2. "comprehensive approach to cybersecurity risk management" - generic
3. "Our board of directors and our management actively oversee our risk management program" - generic governance
4. "established policies, standards, processes and practices" - generic RMP
5. "devoted resources to implement and maintain security measures" - generic

6. Materiality assessment: "we do not believe that risks from prior cybersecurity threats have materially affected our business to date" and "past or future attacks will not materially affect us, including our business strategy, results of operations, or financial condition"
7. "Risk management and strategy" - appears to be a section header fragment

The paragraph contains a materiality assessment, which per Rule 6 → Strategy Integration. But the paragraph also has significant RMP and governance content.

What's the dominant category? The paragraph is quite mixed. It touches on board governance briefly, risk management process briefly, and includes a materiality disclaimer. Looking at the dominant content: most of the paragraph describes the company's general approach to cybersecurity risk management (policies, processes, investments), but the materiality statement at the end is a significant disclosure that suggests the company doesn't believe cybersecurity risks will materially impact operations or financial condition.

The tiebreaker rules indicate materiality disclaimers should be categorized as Strategy Integration even when boilerplate, yet the dominant category rule assigns based on text volume. The RMP content occupies more space overall, though the materiality conclusion is explicit and important. Reconsidering the structure: the paragraph leads with generic threat language and RMP description, then concludes with the materiality assessment. Since most of the content focuses on the company's risk management approach rather than strategic implications, Risk Management Process is the dominant category here.

Now I'm checking for specific details—board of directors and management are generic governance references, and there are no named frameworks, specific roles, dates, tools, or metrics mentioned. I see a reference to Risk Factors cross-reference.


reasoning: The paragraph contains an explicit materiality assessment ('Risks from cybersecurity threats have not materially affected us') and a forward-looking materiality statement about potential impact on business strategy, results of operations, or financial condition — placing it squarely in Strategy Integration per Rule 6. The cross-references to named risk factor titles are company self-references (not specific cybersecurity facts per the IS list), and no named frameworks, roles, dates, or verifiable facts are present, so specificity remains Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Opens with a generic disclaimer about information security policies, then makes a materiality assessment ("have not materially affected us"), then a forward-looking materiality statement, then cross-references to specific risk factors.

Category: The paragraph contains an explicit materiality assessment - "Risks from cybersecurity threats have not materially affected us" and "reasonably likely to materially affect us." Per Rule 6, this is Strategy Integration.

Specificity: Let me check for specific facts. The cross-references name specific risk factor titles, but these are just cross-references to other sections. No named frameworks, no dates, no dollar amounts, no named roles, no named firms.

The risk factor titles themselves are just self-referential company language, so this falls into Generic Boilerplate.


reasoning: The entire paragraph describes the qualifications, experience, credentials, and career backgrounds of multiple cybersecurity-relevant personnel (CIO, Director of Cyber Security, Director of Technology Compliance, CLO, CFO) — squarely the person-vs-function test for Management Role. Multiple QV-eligible hard facts: specific years of experience (30, 25, 12, 14, 20) and named professional certifications (CISSP, CISA) easily exceed the two-fact threshold for Quantified-Verifiable.

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

This paragraph describes multiple individuals' qualifications, experience, and backgrounds. It's clearly about the people - their credentials, tenure, prior roles, certifications.

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

Specific facts:
- CIO (cybersecurity-specific title) - 10+ years executive leadership, 30+ years technology experience
- SVP of Consumer Technologies at a large cosmetics company (prior role)

- Director, Cyber Security - 25+ years experience, principal information security engineer background
- Director, Technology Compliance - 12 years experience
- Chief Legal Officer and CFO roles also mentioned with 14 and 20 years experience respectively

QV-eligible facts include the specific tenure numbers (10+, 30+, 25+, 12, 14, 20 years), plus named certifications like CISSP and CISA that appear multiple times across different roles.

fact: CIO with over 10 years executive leadership and over 30 years technology experience

fact: Director, Cyber Security with over 25 years experience

fact: CISSP certification (Director, Cyber Security)

fact: CISA certification (Director, Cyber Security)

fact: Director, Technology Compliance with 12 years experience

fact: CISA certification (Director, Technology Compliance)

fact: Over 30 years of experience in technology (CIO)

fact: Over 25 years in IT/infosec (Director, Cyber Security)

fact: 12 years in IT (Director, Technology Compliance)

fact: Over 14 years managing risks (Chief Legal Officer)

fact: 20 years managing risks (CFO)


reasoning: The board of directors is the grammatical subject performing risk oversight, placing this in Board Governance. However, the language is entirely generic — 'identify, prioritize, assess, manage and mitigate' is standard enterprise risk language with no cybersecurity-specific detail, no named committees, frameworks, or firm-specific facts.

thinking:
Classify this paragraph.

The board of directors is the grammatical subject, overseeing risks. But this is generic risk oversight language, not cybersecurity-specific. However, it's in Item 1C, so it's in the context of cybersecurity disclosure.

Category: Board Governance - the board is the grammatical subject performing oversight of risks. Even though it's generic, it's in Item 1C context.

Specificity: No named frameworks, no specific facts from the IS list. "Board of directors" is on the NOT list. This is completely generic boilerplate.

→ Board Governance, Generic Boilerplate


reasoning: The board of directors is the grammatical subject performing oversight and receiving updates on cybersecurity, making this Board Governance. All elements are generic — 'board of directors,' 'periodic updates,' 'management team' — with no named roles, frameworks, dates, or firm-specific details.

thinking:
Classify this paragraph.

Content: Board oversight, receives periodic updates from management about cybersecurity. Board is the grammatical subject. → Board Governance.

Specificity: "board of directors" - generic. "periodic updates" - generic. "management team" - generic. No named roles, no frameworks, no specific facts. → Generic Boilerplate.


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations or financial condition'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. No firm-specific facts from the IS list are present; the cross-reference names no standard or cybersecurity-specific role.

thinking:
Materiality assessment + cross-reference. Per Rule 6 and the codebook, this is Strategy Integration because it contains an explicit materiality conclusion.

Specificity: The materiality language is boilerplate. No named standards, no firm-specific facts from the IS list. Generic Boilerplate.


reasoning: The CFO is mentioned as attribution, but the paragraph's substantive content describes internal cybersecurity processes — monitoring, risk assessment, escalation protocols. Applying the person-vs-function test: remove the CFO reference and the paragraph still describes processes. CFO is on the NOT list (generic C-suite), third-party vendors are unnamed, and no frameworks, tools, dates, or numbers are provided, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

The paragraph starts by identifying the CFO as responsible for cybersecurity, with third-party vendor assistance. Then it describes what they do - monitoring, evaluating, real-time monitoring, escalation protocols.

Person vs function test: The CFO is mentioned as attribution, then the paragraph describes processes (monitoring, evaluating, risk assessment). Remove "The Company's Chief Financial Officer, or CFO, with assistance from our third-party cybersecurity vendors, is responsible for" and you get process descriptions. This is about the function, not the person.

Now I'm checking the specificity of the claims. The CFO is a generic C-suite title, the vendors are unnamed, and the tools aren't identified. There are no frameworks, standards, dates, or metrics mentioned—just common practices like real-time monitoring. This is generic boilerplate without concrete details.


reasoning: The paragraph is a mixed paragraph spanning program functions and personnel credentials. The most detailed and distinctive content describes two leaders — the CTO (25 years experience in technology strategy, cybersecurity, etc.) and the Head of Technology Infrastructure (20 years in IT risk governance, information security) — making Management Role the dominant category. The program activities in the opening clause are substantial but serve as context for what these leaders manage. Two QV-eligible hard facts (25 years, 20 years) plus named cybersecurity-specific roles and the named C-ROC committee support Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. The cybersecurity program and what it does (monitoring, alert response, vulnerability management, etc.) - Risk Management Process
2. The CTO's background (25 years experience, areas of expertise) - Management Role
3. The Head of Technology Infrastructure's background (20 years experience, focus areas) - Management Role
4. The C-ROC committee meeting and forming teams - could be Management Role or Risk Management Process

The person-vs-function test: The paragraph describes both the program's functions AND the qualifications of two specific leaders. Let me assess dominance.

The first sentence describes the program's activities.

The second sentence is quite long and focuses on two people's qualifications, while the third sentence covers C-ROC operations. The personnel descriptions are substantial—they detail who these leaders are and their experience—but the opening and closing both emphasize program functions and operations. If I strip away the names and titles, the core content remains about the cybersecurity program's responsibilities and enterprise-wide strategy, which suggests this leans toward Risk Management Process despite the significant personnel component.

Actually, looking at it again, the paragraph breaks into three roughly equal sections: the program's functions, the two leaders' qualifications, and C-ROC operations. The credentials and experience details are the most specific and detailed part, which tips this toward Management Role. That's where the emphasis really lands. and the CTO role itself is a named position. So I've identified two quantified-verifiable facts based on the specific year counts, plus the named roles and committee that support the overall profile.

fact: Chief Technology Officer

fact: over 25 years of experience

fact: Head of Technology Infrastructure

fact: over 20 years of experience

fact: C-ROC (cross-enterprise committee)


reasoning: The paragraph contains an explicit materiality assessment ('not aware of any material risks from cybersecurity threats in 2024 that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition'), which per Rule 6 is Strategy Integration regardless of the appended cross-reference to Risk Factors. No named frameworks, firm-specific facts, or verifiable details beyond boilerplate materiality language.

thinking:
Classify this paragraph.

Content: Materiality assessment ("not aware of any material risks... that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition") + cross-reference to Risk Factors.

Per Rule 6 and the codebook: materiality disclaimer → Strategy Integration. The cross-reference doesn't change it.

Specificity: No named frameworks, no firm-specific facts. The cross-reference title is just a generic risk factor heading. → Generic Boilerplate.


reasoning: The paragraph references actual past cyber incidents (previously disclosed in specific quarterly reports) and describes remediation response actions (implementing additional safeguards), making Incident Disclosure the best fit. The specific quarterly filing dates (June 30, 2023 and September 30, 2023) are firm-specific facts identifying when incidents were disclosed, but since they are filing cross-references rather than independent hard verifiable cybersecurity facts (like named tools, firms, or dollar amounts), they support Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: References past cyber incidents (previously disclosed), mentions implementing additional safeguards, and includes a materiality reference.

Category: This paragraph references actual past incidents and describes response actions (implementing additional safeguards). It's primarily about what happened and what was done in response. The incidents are referenced, and the safeguards are remediation actions. This feels like Incident Disclosure - it's describing the aftermath/response to actual incidents.

Wait - let me reconsider. The paragraph doesn't describe what happened in the incidents themselves. It references them and then talks about implementing safeguards. The main point is: we had incidents, and we've since implemented safeguards.

I'm weighing whether this is Strategy Integration, Risk Management Process, or Incident Disclosure. The key distinction is that the paragraph cross-references incident details rather than describing them directly—it's really focused on the company's strategic response through additional safeguards. Looking at the tiebreaker: since this doesn't actually describe what happened in the incidents themselves, just acknowledges them and pivots to remediation measures, the substantive content here is about the safeguards implemented.

But wait—"response actions" is explicitly listed under Incident Disclosure, and implementing additional safeguards after identified incidents absolutely counts as a response action. The paragraph is fundamentally about incidents and how the company responded, even if the incident details are sparse and cross-referenced elsewhere. The materiality language is secondary to the incident narrative itself.

I'm going with Incident Disclosure. The specificity is there too—"quarters ended June 30, 2023 and September 30, 2023" gives concrete dates that would qualify.

Actually, let me reconsider whether these dates themselves count as Quantified-Verifiable. They're specific and verifiable, but they're dates of quarterly filings, not the incidents themselves. The NOT list specifically excludes company self-references and filing form types. These dates are tied to filing references rather than to the cybersecurity events directly, so they probably don't meet the QV threshold on their own.

Looking at the actual substantive content here—the company had incidents and implemented additional safeguards—there are no named tools, firms, or specific numbers. The dates are metadata about filings, not facts about the cybersecurity disclosure itself. I think Firm-Specific is the right call, since the content is about the company's own actions without external specificity.

fact: quarters ended June 30, 2023

fact: quarters ended September 30, 2023


reasoning: The paragraph describes the company's internal data storage and handling practices — where customer data resides, how sensitive information is controlled, and confidentiality safeguards with contractors. Third parties (Google Cloud, AWS, payment processors, accounting consultants) are mentioned as components of the company's own data security approach, not as the central topic of vendor oversight, so this is Risk Management Process rather than Third-Party Risk. Two named third-party firms (Google Cloud, Amazon Web Services) meet the two-fact QV threshold.

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

This describes how customer data is stored and handled - Google Cloud, AWS, data centers, payment processing practices, confidentiality agreements with accounting consultants. It's about data security practices and data handling procedures.

Content category: This is describing internal processes for data storage and protection. It mentions third parties (Google Cloud, AWS, payment processors, accounting consultants) but the central topic is the company's own data handling practices. Third-party services are components of how they manage data. This is Risk Management Process.

Wait - actually, this reads more like a data handling/storage description than a cybersecurity risk management process per se.

It's about where data lives and how it's protected - internal security practices that fit the Risk Management Process category. I'm identifying specific verifiable facts here: Google Cloud and Amazon Web Services are both named platforms, which gives me two concrete, named third-party firms that can be verified. That qualifies as Quantified-Verifiable.

fact: Google Cloud

fact: Amazon Web Services


reasoning: The paragraph describes the company's own internal cybersecurity program — risk assessment, incident response, change management, and confidentiality/integrity/availability goals. It names the NIST CSF as the basis for its policies, which elevates it above Generic Boilerplate, but contains no firm-specific facts (no named roles, dates, tools, headcounts, or third-party firms) to reach Firm-Specific.

thinking:
Classify this paragraph.

Content: Describes the company's cybersecurity program - risk assessment, incident response, change management, NIST CSF framework. This is about internal processes.

Category: Risk Management Process - describes the company's own internal cybersecurity processes, framework adoption, risk assessment.

Specificity: Names NIST CSF framework → at least Sector-Adapted. Any firm-specific facts? No cybersecurity-specific titles, no named committees, no dates, no numbers, no named tools/firms. Just generic program description + NIST framework mention. → Sector-Adapted (2).

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


reasoning: The paragraph names the management team (CEO, COO, CAO) as responsible for cybersecurity but the bulk of the content describes the function: retaining a third-party IT provider for monitoring, incident response workflow, and materiality determination process. Applying the person-vs-function test, removing the titles and brief qualifications note still leaves a substantive process description, so this is about the function, not the people. All titles are generic C-suite (NOT list), the third-party provider is unnamed, no frameworks or firm-specific facts are present, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph carefully.

Content: Describes the management team (CEO, COO, CAO) responsible for cybersecurity, notes they lack specialized cyber backgrounds, describes use of third-party IT provider for monitoring, and describes incident response process.

Category analysis:
- Names CEO, COO, CAO - these are generic C-suite per the NOT list
- Describes what management does - assessing/managing risks, retaining providers, incident response
- The person-vs-function test: The paragraph describes what the management team DOES (assesses risks, retains providers, monitors via third-party, responds to incidents).

The qualifications piece is secondary to the main focus on their processes and procedures. Even setting aside the brief mention of their lack of specialized backgrounds, the core content centers on how they actually manage cybersecurity—through third-party monitoring and their incident response framework. So this reads as primarily about function rather than the people themselves. I'm noticing the paragraph actually centers on the management structure and their qualifications for handling cybersecurity risk, even though it includes process details. The opening establishes who's responsible, describes their backgrounds, and then explains what they do—so this leans toward Management Role rather than Risk Management Process. The process elements are really just supporting what the management team does in their role.


reasoning: The paragraph's primary frame is the board and Audit Committee's oversight of cybersecurity risks—they are the grammatical subjects of most sentences, with management's responsibilities described subordinately within that oversight structure. No facts from the IS list are present: 'Audit Committee' and 'Board of Directors' are generic governance terms, 'Chief Executive Officer' is generic C-suite (NOT list), and cadences like 'regular' and 'periodic' are vague—yielding Generic Boilerplate.

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

The paragraph covers board oversight (Audit Committee designated to oversee cyber risks, receives updates) and management's role. The board/Audit Committee is the primary subject for much of the paragraph, but it also discusses management responsibilities.

The dominant topic: The paragraph starts with board oversight, designates the Audit Committee, describes information flow. Then it shifts to management responsibilities. The board/Audit Committee is the primary frame - they are the ones with oversight, receiving updates. Management's role is described in relation to the board's oversight structure.

Category: Board Governance - the board and Audit Committee are the primary actors/subjects throughout most of the paragraph.

Now I'm checking the specificity of the language used. The paragraph mentions the CEO directing cybersecurity programs, but that's generic C-suite language. The Audit Committee, Board of Directors, and management references are all boilerplate terms without any firm-specific details. There are no named frameworks or concrete facts that would distinguish this from standard governance disclosures, so this reads as generic boilerplate.


reasoning: The paragraph's primary communicative purpose is describing the Board of Directors' expected oversight of cybersecurity risks, including briefing cadence and scope — squarely Board Governance. However, every sentence is aspirational ('We expect...'), indicating no program currently exists. There are no specific facts: no cybersecurity-specific roles (only generic 'senior management' and 'Board of Directors'), no named frameworks, no dates, and no firm-specific details. The language could be pasted into any pre-operational company's filing unchanged, yielding Generic Boilerplate.

thinking:
This is a forward-looking paragraph from a company that apparently doesn't yet have a cybersecurity program in place. Everything is prefaced with "We expect" - indicating future intentions rather than current practices.

The paragraph discusses board oversight expectations but in entirely aspirational terms. No current program exists. This is similar to the SPAC/no-operations pattern.

Let me think about category. The language is all forward-looking ("We expect that..."). There's no substantive current disclosure. However, unlike a pure SPAC that says "we have no program," this company is describing what it expects to do. But it's still not describing anything that currently exists.

So the real question is whether this counts as Board Governance content that's just poorly disclosed, or whether it falls under None/Other because it's entirely forward-looking with no actual program. The codebook treats forward-looking statement disclaimers as None/Other, and this paragraph is essentially all forward-looking - every sentence starts with "We expect." Since nothing substantive currently exists, this should be categorized as None/Other. The paragraph is fundamentally about board oversight of cybersecurity, even though it's entirely forward-looking and generic—no named roles, frameworks, or concrete details. This fits Board Governance at Specificity 1, since the communicative intent is describing expected board governance of cybersecurity risks, just without any substantive specifics to back it up.


reasoning: The paragraph describes the aftermath of an actual cybersecurity breach — public disclosure, customer notifications, and an SEC investigation triggered by failures in Progress software, with a specific date for the SEC's document preservation request. This is incident narrative and response. Two hard verifiable facts (specific date + named software product) reach the QV threshold.

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

Content: Describes public disclosure of a breach, SEC investigation into data breaches from Progress software failures, a specific date for SEC document request, and cooperation statement.

Category: This is about an actual cybersecurity incident - the breach disclosure, SEC investigation, and the company's response. It describes what happened (breach, SEC investigation, document request). This is Incident Disclosure.

Specific facts:
- "February 26, 2024" - specific date
- "Progress software" - named product/system
- "SEC investigation" - this is standard incident language

- The combination of the specific date and named product gives me two hard verifiable facts, which qualifies this as Quantified-Verifiable.

fact: February 26, 2024 — date SEC document request received

fact: Progress software — named third-party product whose failures caused the breach


reasoning: The paragraph describes the company's internal incident response process — team composition, escalation procedures via a severity matrix, and materiality assessment workflow. This is about the function (how the process works), not about any individual person. Multiple named internal programs with unique identifiers (IRT, IRP, CSC) and specific departmental composition make it Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named third-party firms, tools) are present.

thinking:
Let me analyze this paragraph carefully.

Content: Describes an Incident Response Team (IRT), its composition, how it follows the IRP, escalation to CSC, and materiality assessment process.

Category: This is about internal processes - incident response team composition, procedures, escalation. The person-vs-function test: this is about the function/process, not about any individual person. → Risk Management Process

Specific facts:
- "Incident Response Team ("IRT")" - named internal program with unique identifier ✓
- Team composition: "CFC, legal, corporate communications, finance" - specific departmental composition ✓
- "IRP" - named internal program

- "CSC" - named internal body (likely Cybersecurity Steering Committee or similar)
- CEO mentioned - generic C-suite reference, not specific

The IRT is a named internal program with its own identifier, and the specific departmental composition across CFC, legal, corporate communications, and finance represents a concrete team structure. The IRP and CSC are also named programs and committees. For quantitative verification, I'm looking for specific dates, dollar amounts, headcounts, percentages, named third-party firms, products, or certifications—none of which appear here. This doesn't qualify as QV.

IS list

. The named internal programs with unique identifiers and specific departmental compositions point to this being firm-specific information about their Risk Management Process.

fact: Incident Response Team ("IRT") — named internal program with unique identifier

fact: Team composition: CFC, legal, corporate communications, finance

fact: IRP (Incident Response Plan) — named internal program with unique identifier

fact: CSC — named internal body for escalation


reasoning: The paragraph opens with a description of the company's incident response plan (IRP lifecycle, templates, communication methods), which is the primary cybersecurity disclosure content — Risk Management Process. The second half addresses a physical break-in (explicitly not a cybersecurity incident) and a materiality assessment ('no material cybersecurity incidents in the last 24 months'), which leans toward Strategy Integration, but the IRP description is the dominant cybersecurity-specific content. The fiscal year end date 'September 30, 2025' is the one qualifying firm-specific fact; the IRP description itself is generic (no named framework, no unique program identifier), and the physical incident details are not cybersecurity facts.

thinking:
Let me analyze this paragraph carefully.

The paragraph has two parts:
1. Description of an incident response plan (generic - no named framework, no specific details)
2. Description of a physical break-in incident and materiality assessment

The physical break-in is explicitly stated as "an isolated physical security incident" - not a cybersecurity incident. The paragraph also states "We have had no material cybersecurity incidents in the last 24 months."

So what's the dominant category? The paragraph describes:
- An IRP (Risk Management Process)
- A materiality statement about cyber incidents (Strategy Integration)

- A physical security incident that's separate from cybersecurity

The IRP description is generic and takes up roughly half the content. The materiality statement about no material cybersecurity incidents in the last 24 months is a clear Strategy Integration element. The physical break-in, while taking up significant text, is explicitly not a cybersecurity incident, so it doesn't fit the cybersecurity categorization framework I'm working with.

Looking at the dominant purpose: the paragraph opens with the IRP description, then pivots to the materiality assessment ("no material cybersecurity incidents"), and uses the physical incident as supporting evidence that nothing material happened. The materiality assessment actually runs through the second half of the paragraph, including the physical incident's explicit statement that it "did not result in a material impact on our operations, financial condition or results of operations."

The primary communicative intent seems to be establishing both that there's an IRP in place and that there haven't been material incidents—cyber or otherwise. This makes it a hybrid between Risk Management Process and Strategy Integration, but the materiality framing is what ties everything together. I think Strategy Integration is actually the dominant category here since the materiality assessment is the through-line connecting all the pieces. The IRP description is the substantive cybersecurity content here, so Risk Management Process is the right primary category—the materiality assessment about no material incidents is secondary to that. The physical break-in doesn't count as a cybersecurity incident disclosure since it's explicitly physical security, not cyber.

Now I'm evaluating the specificity level. The incident response plan is just a generic program name, and while "last 24 months" gives a timeframe, it's vague. The fiscal year end date of September 30, 2025 is specific, though it's standard filing language. The firemen's access conduit detail is specific but relates to the physical incident rather than the cybersecurity aspects. That fiscal year date pushes this toward Firm-Specific.

fact: fiscal year ended September 30, 2025


reasoning: The paragraph's primary content describes ADT's risk management processes — risk assessment methodology, security posture scoring, vulnerability assessments, tools, and framework alignment. The CISO and CISSP are mentioned as attribution but the bulk of the paragraph details what the program does (person-vs-function test: remove the CISO reference and the paragraph still describes the program). Two QV-eligible hard verifiable facts: CISSP (named certification) and SecurityScorecard (named product/tool).

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

Content Category: This paragraph mentions the CISO and their CISSP certification, but the bulk of the content describes what the cybersecurity program does - risk assessment, tools, procedures, framework alignment. The CISO is mentioned as attribution. Applying the person-vs-function test: if I remove the CISO's title and certification, the paragraph still describes the program's processes. The dominant content is Risk Management Process.

However, the CISO + CISSP certification is notable. But the paragraph's primary communicative purpose is describing the risk management program - tools, assessments, framework alignment, procedures.

→ Risk Management Process

Now I'm identifying the specific verifiable facts here. The CISO title and CISSP certification are both on the IS list, and SecurityScorecard is a named product that qualifies for QV eligibility. NIST cybersecurity framework is a named standard but doesn't meet QV criteria. So I have two hard verifiable facts - the CISSP certification and SecurityScorecard - which puts this in the Quantified-Verifiable category.

fact: CISO role

fact: CISSP certification

fact: SecurityScorecard (named third-party tool)

fact: NIST cybersecurity framework


reasoning: The paragraph describes Avantor's internal cybersecurity policies, risk assessment activities, monitoring, incident response, and employee training—all hallmarks of Risk Management Process. It names NIST 800-171 as the aligned framework, which elevates it to Sector-Adapted, but contains no firm-specific facts (no named roles like CISO, no headcounts, no named tools or third-party firms) to reach Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes internal security policies, risk assessment aligned to NIST 800-171, and a team that monitors/responds. This is about the company's own internal processes.

Category: Risk Management Process - describes policies, risk assessment, framework alignment, monitoring, incident response, training.

Specificity: Names NIST 800-171 (a recognized standard) → at least Sector-Adapted. Any firm-specific facts? "team of information security professionals" is generic (no headcount, no named role like CISO). "annually" is generic cadence. No named tools, no specific dates, no named firms.

The NIST 800-171 reference pushes this to Sector-Adapted level, though the rest remains generic without specific tools, dates, or organizational details.

fact: NIST 800-171 Cybersecurity Framework


reasoning: The paragraph's primary content is the narrative of an actual 2019 wire fraud incident — describing the attack vector (compromised employee email), what happened (fraudulent wire transfer), and remediation actions (MFA implementation, enhanced controls). While it opens with generic risk language and closes with remediation steps, the dominant communicative purpose is incident disclosure. Specificity is Firm-Specific: the year 2019 is one specific date, but there are no additional QV-eligible hard facts (MFA is a common practice, not a named product; no dollar amounts, named firms, or other verifiable specifics are provided).

thinking:
Let me analyze this paragraph carefully.

Content: Describes a past cybersecurity incident (2019 wire fraud), response actions (MFA implementation), and some generic risk language.

Category: The paragraph describes an actual cybersecurity incident - the 2019 wire fraud scheme, what happened, and remediation. The dominant content is the incident narrative. → Incident Disclosure

Specificity: Let me check for facts:
- "in 2019" - specific date (year) → specific_date
- "multi-factor authentication (MFA)" - this is a common practice, not a named product/tool

- "wire fraud scheme" - describes the incident type
- The description of what happened is fairly detailed but counting QV-eligible facts: only "2019" qualifies as a specific hard fact, while details like the compromised email account and wire transfer are part of the incident narrative but don't meet the QV-eligible criteria.

So one specific date → Firm-Specific (3).

fact: 2019 wire fraud incident


reasoning: The paragraph describes the company's internal cybersecurity risk program including controls, monitoring, third-party assessments, employee training, and vendor risk policy — all hallmarks of Risk Management Process. Third-party and vendor mentions are components of the internal program, not the central topic. No named frameworks, no cybersecurity-specific roles (CISO/CIO/CTO), no named firms or tools, no specific dates or numbers appear; 'quarterly' is a generic cadence, 'tabletop exercises,' 'penetration tests,' and 'spear phishing training' are common practices on the NOT list, and 'dedicated staff' and 'third-party providers' are unnamed/vague.

thinking:
Let me analyze this paragraph from Core Natural Resources (CNR) 10-K Item 1C filing.

Content: Describes the company's cybersecurity risk program - controls, monitoring, third-party assessors, training, vendor risk policy. This is about internal processes and methodologies.

Category: Risk Management Process - describes internal cybersecurity processes, monitoring, controls, training, assessments. Third-party mentions are components of the internal program, not the central topic. Vendor risk is mentioned briefly as one component.

Specificity: Let me check for specific facts:
- "CONSOL Energy" - company self-reference (NOT list)

- "dedicated staff of cybersecurity professionals" - vague
- "various third-party providers" - unnamed (NOT list)
- "third-party assessors, consultants and auditors" - unnamed (NOT list)
- "tabletop exercises and network penetration tests" - common practices (NOT list)
- "quarterly" training - generic cadence (NOT list)
- "spear phishing and other awareness training" - common practices (NOT list)

No named frameworks, no named roles (CISO etc.), no specific dates, no named tools, no named firms. Everything here is on the NOT list or is generic.

→ Generic Boilerplate (1)


reasoning: The audit committee (a board committee) is the grammatical subject receiving cybersecurity reports, making this Board Governance. The CIO is a cybersecurity-specific role on the IS list, elevating specificity to Firm-Specific, but 'audit committee,' 'periodic,' and 'incident response plan' are all on the NOT list and do not count.

thinking:
Let me analyze this paragraph.

Content: The audit committee receives reports from CIO about cyber threats/risk and processes. Incident response plan would escalate certain incidents to the board.

Category: The audit committee (board committee) is the grammatical subject receiving reports. This is about board/committee oversight. → Board Governance

Specificity: Let me check facts:
- "audit committee" → generic (on the NOT list)
- "Chief Information Officer" (CIO) → IS list, cybersecurity-specific title
- "periodic" → generic cadence (NOT list)
- "incident response plan" → generic program name (NOT list)

- One IS fact (CIO) means this qualifies as Firm-Specific since there's a named role present and no QV-eligible facts.

fact: Chief Information Officer (CIO)


reasoning: The entire paragraph describes the CTO as a person — their career history, educational background, prior roles, and years of experience. This is squarely Management Role under the person-vs-function test. Two QV-eligible hard facts: 'over 30 years' of experience and 'three public companies' where the person served as a named officer.

thinking:
Let me analyze this paragraph.

This is about the CTO's background, qualifications, experience, and career history. It's clearly about the person, not the function.

Content category: Management Role - the entire paragraph describes the CTO's credentials, experience, and background.

Specific facts:
- CTO (cybersecurity-specific title) - named_role
- "over 30 years" of experience - quantified
- "master's degrees in electrical engineering" - but no named university, so generic degree
- "three public companies" - quantified but vague
- CTO, CIO, Chief Product Officer roles at prior companies

- "over 30 years" and "three public companies" are both specific numbers that can be verified, making this Quantified-Verifiable content

.

fact: Chief Technology Officer (cybersecurity-specific title)

fact: over 30 years of experience in information technology

fact: served as CTO, CIO, or Chief Product Officer of three public companies


reasoning: The paragraph is framed by the Board receiving updates (sentence 1) and management reporting to the Audit Committee (final sentence), establishing a governance/reporting structure as the primary communicative purpose. The middle sentences describe management's responsibilities, but in the context of board-delegated oversight. All entities are generic (Board, Audit Committee, CEO, 'management', 'periodic', 'regularly') — CEO is on the NOT list as generic C-suite, and no cybersecurity-specific titles (CISO, CIO, CTO) appear, so no IS-list facts are present.

thinking:
Let me analyze this paragraph.

The paragraph discusses both Board oversight and Management's role. Let me determine the dominant category.

- "The Board of Directors also receives periodic updates" - Board Governance
- "Management is responsible for identifying, considering and assessing material cybersecurity risks..." - this describes what management does (function)
- "Our cybersecurity programs are under the direction of our Chief Executive Officer" - mentions CEO directing programs
- "Management regularly updates the Audit Committee on our cybersecurity programs" - Board Governance (reporting to Audit Committee)

The paragraph is primarily about management's responsibilities and what they do.

Now I'm reconsidering whether the Board governance elements outweigh the management function descriptions. The core of this paragraph focuses on management's processes—identifying risks, assessing them, monitoring and mitigating—which points to Risk Management Process as the dominant category, even though Board reporting is mentioned alongside it. The paragraph keeps pulling between governance framing and operational substance. Management's core responsibilities—identifying, assessing, and monitoring cybersecurity risks, establishing processes, implementing mitigations—that's the real meat here. The governance elements (Board receives updates, CEO directs, Audit Committee reporting) are the wrapper around it. I think this lands as Risk Management Process because the dominant content describes what management actually does operationally, even though it's all presented through a governance lens.

Looking at the specificity check: everything here is generic—no named frameworks, no specific facts, just standard titles and vague cadences like "periodic" and "regularly." That confirms this isn't pulling from the IS list at all.


reasoning: The paragraph names the CIRT and three leadership roles, then devotes the majority of its content to describing what the CIRT does: managing enterprise-wide policy, detection, assessment, classification, prioritization, escalation, and documentation. Applying the person-vs-function test, removing the role titles and experience leaves a coherent process description, so the paragraph is about the function, not the people. The named internal program with unique identifier (CIRT) and the specific experience duration (over 20 years) are firm-specific facts, but only one is QV-eligible (years of experience), so specificity is Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the Cyber Incident Response Team (CIRT) - who leads it, what it does. Let me apply the person-vs-function test.

The paragraph starts by identifying who manages the cybersecurity program: the CIRT, led by three named roles (Global IT Director, System Infrastructure Manager, Network Infrastructure Manager) with "over 20 years of experience in IT." Then it describes what the CIRT does: managing policy/compliance, detection/assessment, classification, documentation.

Person-vs-function test: If I remove the role titles and experience, does the paragraph still make sense as a process description? Yes - it describes detection, assessment, classification, prioritization, response, escalation, documentation.

The bulk of the content focuses on the CIRT's functions and processes rather than the people themselves. Even though specific roles are mentioned upfront, the substantive part of the paragraph is really about what the team does - the detection, assessment, and response activities. So this falls under Risk Management Process, with the CIRT being a named internal program that should go on the IS list.

Now I'm checking which details qualify as specific facts. The "over 20 years of experience" is a concrete number that meets the IS criteria, but the role titles like "Global IT Director" and the infrastructure managers are too generic for cybersecurity specificity. The CIRT itself is named and has a unique identifier, so it counts for IS, but named internal programs don't trigger QV eligibility - only the experience number would potentially qualify there.

Since I only have one QV-eligible fact, this falls into Firm-Specific rather than QV.

fact: Cyber Incident Response Team (CIRT)

fact: over 20 years of experience in IT


reasoning: The paragraph describes the company's internal cybersecurity capabilities — SOC operations, threat detection, vulnerability scanning, and threat hunting. Although the CISO is mentioned, the person-vs-function test shows this is about what the program does, not who the person is. The CISO title is the sole IS-list fact (cybersecurity-specific role), yielding Firm-Specific; no second QV-eligible hard fact is present.

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity capability including SOC, CISO, and various security processes (threat hunting, vulnerability scanning, threat detection).

Category: The paragraph mentions CISO but the bulk is about what the program/SOC does - processes, technology, capabilities. Apply person-vs-function test: remove CISO mention and the paragraph still describes the SOC and security processes. → Risk Management Process

Specificity:
- "Security Operations Center ("SOC")" - named internal program with unique identifier? It's a common term but with abbreviation. Actually SOC is generic.

- "Chief Information Security Officer ("CISO")" - cybersecurity-specific title → IS list ✓
- No named frameworks, no specific dates, no dollar amounts, no named tools/products, no named firms

IS facts: CISO (cybersecurity-specific title) → Firm-Specific. Only one hard verifiable fact (CISO role), so not QV. SOC is a common practice/generic program name across the industry, so I'll treat it as not specific.

So: Risk Management Process.

fact: Chief Information Security Officer (CISO)