reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' by describing a department that evaluates cybersecurity risks of third-party service providers — this is vendor oversight as the central topic, making it TP. Despite mentioning a 'dedicated department within its Enterprise Risk Management division,' this is analogous to 'dedicated cybersecurity team' (not firm-specific per codebook), and all other language ('evaluates cybersecurity risks,' 'manages risks of third-parties') is general ERM vocabulary with no domain terminology passing the ERM test, no named roles/committees, and no verifiable facts.

thinking:
Let me analyze this paragraph.

Content: Describes a dedicated department within ERM that manages third-party risks and evaluates cybersecurity risks of third-party service providers. Examples of third parties are given (bank operations technology, payroll/benefits, professional services).

Category: This is centrally about how third-party cyber risks are managed → Third-Party Risk (TP).

Specificity: Let me scan for facts:
- "dedicated department within its Enterprise Risk Management division" - this is an organizational structure detail. Is it firm-specific? It's describing a specific department, but "dedicated department" is generic. However, placing it within the "Enterprise Risk Management division" is organizational detail.

- "Bank's Information Technology Department" - generic department name
- "bank operations technology, payroll and benefits administrators, and professional service providers" - examples of third parties, somewhat specific but generic categories

No domain terminology that passes the ERM test - "cybersecurity risks," "third-party service providers," "evaluates cybersecurity risks" are all general business language. No QV facts, no named roles at VP+ level, no CISO/CTO, no named committees beyond generic ones. The "dedicated department within its Enterprise Risk Management division" describes an organizational choice, but without a specific name it doesn't meet the firm-specific threshold per the codebook.

This looks like Level 1 - pure generic boilerplate. The language stays in general business and ERM territory with no domain-specific terms like SOC 2 or penetration testing, and no actual firm-specific facts to anchor it.


content_category: Risk Management Process

fact: NIST Cybersecurity Framework

type: framework

fact: Center for Internet Security – Top 18 Critical Security Controls

fact: Phishing tests conducted at least quarterly

fact: Cybersecurity tabletop exercises (with cybersecurity qualifier)

fact: Cyber risk insurance policy

category_confidence: high

specificity_confidence: high

reasoning: The paragraph answers 'What does the cybersecurity program do?' by describing a comprehensive list of program features including risk assessments, training, phishing tests, incident response planning, and insurance — clearly RMP. Specificity reaches Level 2 via named frameworks (NIST CSF, CIS Top 18 Controls) and domain-specific practices (phishing tests, cybersecurity tabletop exercises), but no firm-specific roles or QV-eligible facts (frameworks are referenced/aligned with, not certified; cadences like 'quarterly' and 'biannual' are generic).

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph from IDEXX Laboratories' 10-K filing.

Content Category: This paragraph describes what the cybersecurity program does - risk assessments, training, phishing tests, tools, policies, incident response planning, etc. It answers "What does the cybersecurity program do?" → RMP

Specificity: Let me scan for facts:

Domain terms:
- NIST Cybersecurity Framework → domain term (framework reference)
- CIS Top 18 Critical Security Controls → domain term (framework reference)
- Phishing tests → domain term

- Cybersecurity tabletop exercises → domain term

Firm-specific facts: Not many unique organizational details.

QV-eligible:
- "biannual" employee assessments - this is a cadence, generic
- "at least quarterly" phishing tests - generic cadence
- "NIST CSF" and "CIS Top 18" - these are standards followed/aligned with, not certifications held → Level 2
- "cyber risk insurance policy" - generic mention

The Center for Internet Security's Top 18 Critical Security Controls framework is a named standard referenced here at Level 2, and phishing tests qualify as a domain term.

Looking at what's left, there aren't any specific numbers, dates, or named external firms that would elevate this further. The Code of Ethics is boilerplate—every organization has one. No named leadership positions like CISO or CTO either. This lands at Level 2 based on the domain terminology around NIST CSF, CIS Controls, and phishing testing practices.


content_category: None/Other

reasoning: This paragraph is pure speculative risk language ('could prevent,' 'could cause,' 'could result in') describing hypothetical consequences of a cybersecurity attack without any substantive disclosure of what the company actually does — no program, no oversight, no materiality conclusion. It fails the N/O threshold test: every 10-K could contain this language. No domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

This is speculative risk language - "could prevent," "could cause," "could result in." No actual measures, no materiality assessment conclusion, no program description.

Category: None/Other - pure speculation about what could happen, no substantive disclosure.

Specificity: Level 1 - Generic Boilerplate. No domain terms, no firm-specific facts, no QV facts.


content_category: Strategy Integration

reasoning: The first sentence states a backward-looking and forward-looking materiality conclusion ('have materially affected or are reasonably likely to materially affect'), making this SI under the materiality assessment rule. The remaining sentences are speculation ('no guaranty') and a cross-reference, both subordinate to the assessment. No domain terminology, firm-specific facts, or verifiable claims are present — the negative assertion about no material incidents is not externally verifiable.

thinking:
This paragraph contains a materiality assessment followed by speculation and a cross-reference.

Category: The first sentence states a conclusion about whether cybersecurity has materially affected the company → SI (Rule 5). The rest is speculation and cross-reference, which are subordinate.

Specificity: Let me check for facts.
- "not aware of any material risks... that have materially affected or are reasonably likely to materially affect" → This is a negative self-assertion about materiality. Not externally verifiable.
- "Item 1A 'Risk Factors – Technology Risks'" → cross-reference, not a cybersecurity fact

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

This is generic boilerplate language without substantive detail.


reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing ERM integration, annual risk assessments, and security approach reviews. The Audit Committee mention is subordinate to the process description. All language is generic business/ERM terminology — 'risk management,' 'incident response,' 'business continuity management,' 'annual basis' — none passes the ERM test as cybersecurity domain-specific. 'Audit Committee' is not firm-specific. No domain terms, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

Content category: This paragraph discusses ERM integration of cybersecurity risks, the Audit Committee's oversight of ERM, and annual assessments of security approaches. The primary question it answers is "What does the cybersecurity program do?" - it describes risk assessment methodology and ERM integration. The Audit Committee mention is subordinate to the ERM process description. → RMP

Specificity: Let me scan for facts:
- "enterprise risk management ("ERM")" - general business term, Level 1
- "Audit Committee of the Board" - every public company has one, NOT firm-specific

- "risk management, incident response, business continuity management" - standard industry terminology, Level 1
- "personal data privacy and protection" - generic concept
- "annual basis" - standard review cadence
- "information and physical security" - broad categories

Everything here is boilerplate business language with no domain-specific details or firm-specific facts. → Level 1


fact: Senior Vice President of Information Technology (SVP IT)

reasoning: Person-removal test: removing the SVP IT references leaves a substantive description of monitoring processes, security measures, system audits, and incident response planning — this is about what the program does, not who runs it → RMP. The SVP of Information Technology is a VP-level title with IT portfolio (firm-specific), but the remaining language ('advanced security measures,' 'system audits,' 'incident response plan') is generic business language that fails the ERM test, keeping specificity at Level 3.

thinking:
Let me analyze this paragraph.

Content: Describes the SVP IT's role in monitoring cybersecurity incidents, their knowledge acquisition, implementation of monitoring processes, security measures, system audits, and incident response plan.

Category: The paragraph mentions the SVP IT but the primary content is about what the program does - monitoring, security measures, audits, vulnerability identification, incident response plan. Person-removal test: remove "SVP IT" references → "processes for regular monitoring of information systems, deployment of advanced security measures, regular system audits to identify potential vulnerabilities, well-defined incident response plan" — still substantive. → RMP

The SVP IT title itself is firm-specific, but most of the language here is generic—"advanced security measures," "system audits," "incident response plan" are all standard terminology. The vulnerabilities reference in the context of audits is also generic. This lands at Level 3 because of the SVP IT position.


content_category: Management Role

fact: Chief Information Officer (CIO) as cybersecurity leadership role

reasoning: The paragraph answers 'how is management organized to handle cybersecurity?' — it describes the CIO's responsibilities, the team's oversight of internal personnel and external consultants, and the CIO's qualifications. Person-removal test: removing the CIO and team references leaves little substantive content. Specificity is Level 3 because CIO is a firm-specific cybersecurity leadership role; however, 'many years of experience' is a soft number (not QV), no named external firms or certifications are provided, and the remaining language (risk management program, cybersecurity personnel, consultants) is generic.

thinking:
Let me analyze this paragraph.

Category: The paragraph discusses management's role - CIO responsibilities, team structure, and qualifications. Person-removal test: remove CIO, team references, experience → very little remains. This is MR.

Specificity:
- "Chief Information Officer" (CIO) - firm-specific cybersecurity leadership role at VP+ level
- "many years of experience" - soft number, not QV
- Domain terms: "cybersecurity risk management program" - generic. "cybersecurity personnel" - generic. "security, auditing, compliance" - generic.

- No quantifiable facts, hard numbers, named firms, or certifications present. This lands it at Level 3 due to the CIO reference.


content_category: Board Governance

reasoning: The paragraph primarily answers how the board oversees cybersecurity: Audit Committee oversight, quarterly updates from management, and escalation to a Cybersecurity Sub-Committee for material incidents. The Cybersecurity Sub-Committee is a named non-generic board-level committee that distinguishes this company's governance structure, elevating specificity to Level 3.

thinking:
Let me analyze this paragraph.

Content Category: This answers "How does the board oversee cybersecurity?" - Audit Committee oversight, receiving updates, Cybersecurity Sub-Committee notification process. This is BG.

Specificity: Let me scan for facts.
- "Audit Committee" - NOT firm-specific (every company has one)
- "Cybersecurity Sub-Committee of the Board of Directors" - this is a named non-generic committee → firm-specific (Level 3)
- "at least once per quarter" - generic cadence, not QV

So Level 3 due to the Cybersecurity Sub-Committee.


fact: Chief Risk Officer (CRO) - dedicated cybersecurity-adjacent leadership role

category_confidence: medium

specificity_confidence: medium

reasoning: The paragraph describes a management role (Chief Risk Officer) and their function within the ERM structure, answering 'how is management organized?' However, the content is about broader risk management rather than cybersecurity specifically — the CRO provides 'expertise and oversight in the broader domain of risk management' with no cybersecurity-specific content. The CRO title is borderline for firm-specificity; it's not a cybersecurity-specific title (like CISO), but it is a named leadership role in a risk context within Item 1C. Given the lack of cybersecurity specificity, this is closer to generic ERM language, but appearing in Item 1C gives it MR framing. The CRO role elevates to Level 3 as a dedicated named role in this filing's cybersecurity disclosure context.


fact: CRO role with cybersecurity oversight responsibility

fact: CIO role leading IT strategy

fact: CISO role implementing cybersecurity risk management strategy

fact: RGA's Executive Committee membership for CRO and CIO

fact: Over 15 years experience in managing cybersecurity (CRO, CIO, CISO each)

type: quantified

fact: More than 30 years of experience (CRO)

reasoning: The paragraph is entirely about the qualifications, experience, and responsibilities of three management roles (CRO, CIO, CISO) — the person-removal test leaves no substantive program description, confirming MR. Specificity reaches Level 4 due to quantified lower-bound experience claims ('over 15 years,' 'more than 30 years') which are independently verifiable against resumes/public records.

thinking:
Let me classify this paragraph.

Content: Describes CRO, CIO, and CISO qualifications, experience, and responsibilities. This is clearly about management's organizational role - who holds responsibilities, what qualifies them.

Category: Management Role (MR) - person-removal test: remove all person-specific content and almost nothing remains.

Specificity: Let me scan for facts.
- "over 15 years experience" - quantified lower bound → QV
- "more than 30 years of experience" - quantified lower bound → QV
- CRO, CIO, CISO - named roles → firm-specific

- "RGA's Executive Committee" - named committee → firm-specific
- "Enterprise Risk Management program" - generic
- "Privacy and Security Regulations" - generic

The experience thresholds are lower-bound quantified facts that qualify as QV per the codebook. This lands at Level 4.


reasoning: This paragraph is a general statement about valuing data protection and shared responsibility across the organization. It doesn't substantively answer any of the six cybersecurity disclosure questions — it's aspirational language about confidentiality, integrity, and availability without describing any specific program, process, governance structure, or management role. No domain terminology, firm-specific facts, or verifiable claims are present.


content_category: Incident Disclosure

fact: October 11, 2023 — specific date of incident announcement

fact: approximately three days of business disruption

fact: backlog fulfilled within one week

reasoning: The paragraph primarily describes an actual cybersecurity incident — timeline, response actions, and resolution — making it Incident Disclosure. The closing materiality sentence is subordinate to the incident narrative (Rule 4: incident frame dominates). Specificity is Level 4 due to the specific date (October 11, 2023) and quantified durations (three days disruption, one week to fulfill backlog).

thinking:
Let me analyze this paragraph.

Content: Describes a cybersecurity incident on October 11, 2023, with details about unauthorized access, disruption, remediation, and business impact. The paragraph starts with general vulnerability language but the bulk is about the actual incident.

Category: This is primarily about what happened in a cybersecurity incident → Incident Disclosure. There's a materiality conclusion at the end ("no material financial impact"), but the incident frame dominates.

Specificity:
- "October 11, 2023" - specific date → QV
- "approximately three days" - specific duration → QV

- "within one week" - another specific timeframe → QV
- "Information Technology (IT) infrastructure" - generic descriptor, not specialized terminology
- "cybersecurity incident" / "unauthorized activity" - broad language without technical precision

This lands at Level 4.


content_category: Third-Party Risk

fact: Cross-functional effort involving Legal, Privacy and Information Security teams

reasoning: The entire paragraph answers 'How are third-party cyber risks managed?' — describing vendor security assessments, risk evaluation, due diligence, and ongoing monitoring of service providers, making it clearly TP. The specific named departmental composition ('Legal, Privacy and Information Security teams') is a firm-specific detail per the codebook's team composition rule, elevating to Level 3. The remaining vocabulary (vendor security assessment, IT security, business continuity, risk management) is general ERM language that stays at Level 1.

thinking:
Let me analyze this paragraph.

Content: This is about third-party service provider risk management - vendor security assessments, external risk management software, vendor controls evaluation, cross-functional effort.

Category: This clearly answers "How are third-party cyber risks managed?" → Third-Party Risk (TP). The entire paragraph is about vendor/supplier cybersecurity oversight.

Specificity:
- "external risk management software program" - generic, not named
- "vendor security assessment process" - this is about assessing vendors' cybersecurity
- "IT security" - general term
- "Legal, Privacy and Information Security teams" - specific team compositions by department → firm-specific

- The cross-functional nature with these named departments makes this firm-specific rather than generic

Domain terms: "vendor security assessment" and "IT security" are borderline general terms, but "Privacy" is standard terminology. The codebook indicates that specific departmental compositions like "Legal, Privacy and Information Security teams" count as firm-specific details, similar to how "Legal, Compliance, and Finance" would be classified.

This pushes the overall specificity to Level 3 (Firm-Specific) based on the named team composition.


fact: CISO leads the dedicated team

fact: technical degree in computer science

fact: over 20 years of information technology and cybersecurity experience

fact: experience in financial services and defense industries

fact: team comprises security engineers, detection specialists, and business cybersecurity experts

fact: incident response process

reasoning: The paragraph primarily answers 'how is management organized?' — it describes the CISO's qualifications, team composition, and role responsibilities. Person-removal test: removing the CISO, credentials, and team details leaves only a brief incident response mention. Specificity reaches Level 4 because 'over 20 years of experience' is a verifiable lower-bound claim.

thinking:
Let me analyze this paragraph.

Content Category: This describes the CISO's qualifications, team composition, and what happens when risks are identified. The person-removal test: remove CISO, technical degree, 20 years experience, team composition → "When [we] identify credible risks, we invoke our incident response process to track and manage the details, quickly manage exposures, assess potential customer impact, and facilitate consistent reporting to our CEO and to our Audit Committee." Some process remains but the bulk is about the team and leader. The primary question answered is "How is management organized to handle cybersecurity?" → MR.

Looking at this more carefully, I see three distinct components: the CISO's background and qualifications, the team structure, and the incident response procedures. The first two are clearly about management and reporting structure. The third part about incident response is more process-oriented, but it's still relatively brief compared to the emphasis on leadership and team composition. The bulk of the paragraph focuses on who's in charge and how the team is organized, so this leans toward MR. Now I'm checking the specificity of the details—the CISO is a firm-specific named role, and the technical degree requirement is mentioned but without a specific institution named.

The "over 20 years" experience is a verifiable lower bound, which qualifies as QV. The team composition with security engineers, detection specialists, and business cybersecurity experts is firm-specific, and the mention of financial services and defense industries adds context. The CEO reference doesn't count as firm-specific under the rules. All of this points to Level 4.


fact: firewall maintenance and upgrade initiatives

reasoning: The paragraph primarily describes external parties hired to serve the company's own cybersecurity program (managed IR services, assessments, firewall maintenance) — per Rule 3, third parties serving the company → RMP. The vendor qualification language is subordinate to the program description. 'Firewall' is a cybersecurity-specific security control that passes the ERM test, elevating to Level 2, but no named firms, roles, or verifiable facts are present.

thinking:
Let me analyze this paragraph.

The paragraph discusses two things: (1) external parties hired to help the company's own cybersecurity program (assessors, managed services for IR, firewall maintenance), and (2) vendor risk management of those third parties.

Per Rule 3: Third parties hired to serve the company (assessors, consultants, pen testers) → RMP. The first part is clearly about external parties serving the company's program. The second part about assessing third-party service providers could be TP, but it's about the same service providers mentioned in the first part - ensuring the vendors they hire are qualified.

The central topic is the company's use of external parties to supplement its own cybersecurity program.

The vendor assessment piece is really just supporting detail here. Looking at the specificity, I see domain terminology like "firewall" and "managed services agreement" for incident response, which pushes this toward Level 2. There's nothing firm-specific—no named roles, vendors, or committees—and no QV facts either. This lands at Level 2.


fact: IT Security Team (named team)

fact: PCI compliance

fact: SOC1 and SOC2 level compliance

fact: security certifications from CompTIA

fact: over 20 years of combined infrastructure architecture experience

reasoning: The paragraph primarily describes the Head of Global IT's role, team composition, qualifications, and experience — person-removal leaves only the acquisition due diligence process, which is a minority of the text, so MR wins. Specificity reaches Level 4 via named certification organization (CompTIA) and a quantified lower-bound claim ('over 20 years of combined experience').

thinking:
Let me analyze this paragraph.

Content Category: This paragraph describes the Head of Global IT, their team, qualifications, experience, and some activities. Let me apply the person-removal test.

Remove person-specific content: "performs due diligence on IT security systems and processes of all potential acquisition targets, and newly acquired companies are not permitted access into our IT networks or systems until they have met the necessary security standards."

That's still substantive - it describes M&A security due diligence processes. But the majority of the paragraph is about the Head of Global IT's role, team composition, qualifications, and experience. Let me count the text distribution.

Most of the content focuses on roles, qualifications, team composition, and certifications. When I remove those person-specific elements, what's left is primarily the acquisition due diligence process, which is only a small portion. The codebook indicates "Head of IT" isn't firm-specific, and "Head of Global IT" falls into the same category, so this leans toward MR.

Now I'm checking the specificity of the other elements—"IT Security Team" is fairly generic as a team name, but CompTIA is a named external entity, the "over 20 years" is a quantified metric, and PCI, SOC1, SOC2 are domain standards. The certifications themselves are verifiable, which pushes this toward QV. This looks like a Level 4 classification.


fact: CIO

fact: ISC (Information Security Committee) members

fact: vulnerability management

fact: threat assessments

fact: combined 20 years of risk management experience

reasoning: The paragraph primarily answers 'how is management organized?' by identifying ISC members (CIO and Director of IT Security), their qualifications, and areas of expertise — person-removal leaves only a generic list of domains, so MR wins. Specificity reaches Level 4 because 'combined 20 years' is a specific, verifiable number tied to named individuals' experience.

thinking:
Let me classify this paragraph.

Content: Describes ISC members including CIO and Director of IT Security, Risk and Compliance, their combined experience, and areas of expertise.

Category: This is about management's organizational role - who the people are, their titles, qualifications. Person-removal test: remove CIO, Director of IT Security titles, 20 years experience → left with generic program description of activities. But the primary focus is on WHO these people are and WHAT qualifies them. → MR

Specificity:
- "CIO" - firm-specific cybersecurity leadership role (VP+ level)

- "Director of IT Security, Risk and Compliance" - Director-level position with security qualifier → firm-specific
- "ISC" - named committee (Information Security Committee) → firm-specific
- "20 years of risk management experience" - specific number that's verifiable against resumes → QV-eligible
- "vulnerability management" and "threat assessments" - domain-specific terms
- "cybersecurity insurance" - business/SI term
- "incident response" and "end user awareness" - more generic business terminology

Level 4.


fact: two years of identity protection services offered

reasoning: The paragraph describes ongoing remediation actions from an actual cybersecurity incident — law enforcement engagement, litigation defense, and customer identity protection offerings — answering 'what happened?' Specificity reaches Level 4 because 'two years' is a specific, verifiable duration for the credit monitoring offer.

thinking:
Classify this paragraph.

This describes actions taken after an incident - offering identity protection/credit monitoring to customers, engaging with law enforcement. This is about what happened in response to a cybersecurity incident.

Category: Incident Disclosure - describes remediation actions taken after an actual incident.

Specificity: "two years" is a specific duration that's quantified and verifiable. "identity protection services, including credit monitoring" - these are specific remediation measures but not really cybersecurity domain terms per se. "Credit monitoring" and "identity protection services" are post-breach remediation terms.

"two years" - specific duration of the offering, verifiable.

So this qualifies as a QV fact.


reasoning: The paragraph states a backward-looking conclusion about whether cybersecurity has materially affected business outcomes ('has not experienced any cybersecurity incidents that have had a material impact on its business strategy, financial condition, or results of operations'), which is a materiality assessment → SI. No domain terminology, firm-specific facts, or verifiable claims are present; the negative self-assertion about absence of material incidents is not externally verifiable → Level 1.

thinking:
Materiality assessment - backward-looking negative assertion → SI

Specificity: "has not experienced any material cybersecurity incidents" is a negative self-assertion, not externally verifiable. No domain terms, no firm-specific facts, no QV facts → Level 1.


reasoning: The paragraph describes the Risk Committee providing assurances to management and the Board about cybersecurity risk identification and controls — answering 'how does the board oversee cybersecurity?' The named 'Incident Management and Information Security Plan' is a distinguishing internal program identifier elevating to Level 3, while generic terms like 'mitigating controls' and 'assess, identify, and manage' remain Level 1 ERM language.

thinking:
Classify this paragraph.

The paragraph describes the Risk Committee providing assurances about risk identification and cybersecurity risk management, including an Incident Management and Information Security Plan.

Category: The Risk Committee here is providing assurances to "management and the Board" - this is about oversight structure. But wait - is this a board-level or management-level committee? "Risk Committee" providing assurances to "management and the Board" suggests it's a committee that reports to both. The name "Risk Committee" without "of the Board" qualifier is ambiguous. It provides assurances TO the Board, suggesting it could be a management-level committee.

Since the Risk Committee reports to the Board and provides assurances about how the company identifies and manages cybersecurity risks through its Incident Management and Information Security Plan, this falls under Board Governance. The "Risk Committee" itself could be firm-specific depending on whether it's a named non-generic committee.

Looking at the codebook more carefully: "Risk Committee" is listed as a Board Governance marker, but it's borderline on firm-specificity since many companies have risk committees—not as universal as "Audit Committee," but common enough that I wouldn't flag it as firm-specific. However, the "Incident Management and Information Security Plan" is a named internal program with a distinguishing identifier, which makes it firm-specific. So this lands at Level 3.


fact: System Organization and Control Reports (SOC Reports)

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — it describes processes for overseeing third-party providers including pre-acquisition diligence, contractual obligations, and monitoring, making TP the clear fit. SOC Reports are domain terminology (a security professional's specific evidence type that passes the ERM test), elevating to Level 2, but no firm-specific or verifiable facts push it higher.

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

Facts: SOC Reports (domain term - SOC 2/SOC reports), pre-acquisition diligence, contractual obligations, performance monitoring. The paragraph describes requirements imposed on and monitoring of third-party providers.

Category: Third-Party Risk - the paragraph answers "How are third-party cyber risks managed?"

Specificity: "SOC Reports" is a domain term (Level 2). Nothing firm-specific or QV.


reasoning: The paragraph's central topic is how the company oversees third-party cybersecurity risks — evaluating vendors' policies, imposing contractual safeguards, and reviewing their internal control reports — directly answering 'how are third-party cyber risks managed?' All language is generic business/ERM vocabulary (policies, procedures, practices, contractual safeguards, internal control reports, incident response plans); no cybersecurity domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Third-party risk management is the central topic. Let me check specificity.

Domain terms: "incident response plans" - this is on the NOT domain list. "internal control reports" - general. "cybersecurity policies, procedures, and practices" - general.

Actually, let me re-read. "contractual safeguards" - generic. "internal control reports of such third parties" - this could refer to SOC reports but doesn't name them specifically. "incident response plans" - listed as NOT domain terminology.

No domain terms that pass the ERM test. No firm-specific facts. No QV facts.

The content describes generic vendor oversight processes—evaluating third-party cybersecurity practices annually and establishing contractual requirements—without any specific terminology, firm details, or quantifiable facts. This is Level 1.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing due diligence, security risk assessments of vendors, incident-triggered reassessments, and continuous monitoring of third-party providers. Despite the detail, all language passes the ERM test (due diligence review, risk assessment, additional controls, safeguards, information assets) — a non-security risk professional would naturally use these terms for any vendor oversight program. 'Cybersecurity team' is explicitly not firm-specific per the codebook. No domain-specific practices, tools, frameworks, or verifiable facts are present.

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

Let me check specificity. Domain terms: "third party security risk assessment," "cybersecurity threats and incidents" - the ERM test... "due diligence review" is generic. "third party security risk assessment" - is this domain? It's about security risk assessment of third parties. "vulnerabilities" is somewhat domain. "cybersecurity team" - per the codebook, "dedicated cybersecurity team" is NOT firm-specific and stays Level 1.

Wait, let me re-read. "continuously monitors and addresses cybersecurity threats and incidents at third-party service providers" - this is describing what they do but in fairly generic terms.

Now I'm evaluating whether these phrases demonstrate actual domain expertise or just use industry terminology. "Third party security risk assessment" might resonate with ERM professionals handling vendor risk, but "due diligence review" and "safeguards to protect our information assets" are too broad. Same with "additional controls commensurate to the risk" - that's standard risk language. Even "vulnerabilities" in the context of minimizing risks to systems feels generic. The real question is whether "cybersecurity threats and incidents" shows specialized knowledge or if it's just boilerplate that appears everywhere in these filings.

Looking at the substance, this paragraph is fundamentally about processes - due diligence, risk assessment, monitoring of third parties - but the language never gets specific. No mention of actual security practices, tools, frameworks, or architectural concepts. The category is clearly Third-Party Risk, but the specificity stays at Level 1 because everything reads as generic business language.


reasoning: The paragraph answers 'How does the board oversee cybersecurity?' — describing the Board's oversight role, the lack of committee delegation, and management reporting to the Board. No domain terminology, no firm-specific cybersecurity roles (Board of Directors and 'management' are generic), and no verifiable facts — 'regularly scheduled' is a generic cadence.


fact: ransomware

fact: malware

fact: phishing

fact: cyber-attacks

fact: cyber intrusions

reasoning: The paragraph opens with a materiality assessment ('have not had any material cybersecurity incidents') and mentions cybersecurity insurance — both SI markers per the materiality rule (negative assertion with materiality framing). The generic risk speculation and cross-references are subordinate. Specificity reaches Level 2 via named threat types (ransomware, malware, phishing) which are cybersecurity domain terminology, but the 'December 31, 2023' date anchors a negative self-assertion (not externally verifiable) and no firm-specific or QV facts are present.

thinking:
Let me analyze this paragraph.

Content: States no material incidents as of Dec 31 2023, lists threat types, mentions security efforts, mentions cyber insurance, cross-references risk factors.

Category: The paragraph opens with a materiality assessment ("have not had any material cybersecurity incidents") - that's SI per the materiality rule. It also mentions insurance (SI). The threat types and generic security language are subordinate. The cross-reference at the end is N/O-type but subordinate. Primary question answered: "How does cybersecurity affect the business or finances?" → SI.

Wait - "we have not had any material cybersecurity incidents" is a negative assertion with materiality framing → SI per the rules.

The materiality language and insurance mention dominate the paragraph, though there's also speculative risk language about potential adverse effects. On specificity, the reporting date anchors a negative assertion that isn't externally verifiable, while the threat types themselves are domain-specific terms. The insurance reference is business-general rather than domain-specific, and the cross-references to risk factors are subordinate to the main materiality claim.

Looking at the threat landscape here, ransomware, malware, phishing, and cyber-attacks are clearly domain-adapted terminology that signals Level 2 specificity. There are no firm-specific facts like named roles or committees, and the date-anchored negative assertion doesn't qualify as verifiable, so this lands at Domain-Adapted specificity overall.


reasoning: The paragraph states both a backward-looking materiality conclusion ('not aware of any cybersecurity incidents that have materially affected') and a forward-looking assessment ('do not believe it to be reasonably likely... will materially impact'), making it SI under the materiality assessment rule. 'Since at least January 1, 2021' is a date anchoring a negative self-assertion about the absence of incidents, which is not externally verifiable per codebook rules; no domain terminology or firm-specific facts are present, so specificity remains Level 1.

thinking:
SI - materiality assessment, both backward and forward-looking.

Specific facts: "Since at least January 1, 2021" - this is a specific date tied to a negative assertion. But per the codebook, negative assertions are NOT externally verifiable. "We have not experienced any material cybersecurity incidents" is a negative self-assertion. The date doesn't make it verifiable.

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


reasoning: The paragraph describes contractual cybersecurity requirements imposed ON the Custodian (a third party), including vendor oversight obligations and incident notification duties, directly answering 'how are third-party cyber risks managed?' The language is entirely generic — 'reasonable and appropriate measures,' 'processes to assess, identify and manage risks' — with no domain terminology, firm-specific facts, or verifiable claims. 'MetLife, Inc.' is a company self-reference, and 'the Custodian' is unnamed.

thinking:
Let me analyze this paragraph.

This is about a Custodian's contractual cybersecurity obligations - requirements imposed ON the Custodian (a third party) regarding cybersecurity measures and incident reporting.

Category: Third-Party Risk - requirements imposed on vendors/custodian, contractual security requirements.

Specificity: Let me check for facts.
- "critical vendors" - generic
- "cybersecurity and data protection measures" - generic
- "processes to assess, identify and manage risks" - generic (Level 1)
- "cybersecurity threats" - topic, not domain terminology
- "data security incident" - generic

- No domain terms, no firm-specific facts, no QV facts. The language is entirely generic contractual boilerplate like "reasonable and appropriate measures" and "processes to assess, identify and manage risks" - this is clearly Level 1 specificity.


reasoning: The opening clause states a backward-looking materiality conclusion ('have not experienced a cybersecurity threat or incident that resulted in a material adverse impact to our business or operations'), making this SI under the materiality assessment rule. The remainder is generic speculation ('could adversely affect,' 'could subject us to') found in virtually every 10-K. No domain terminology, firm-specific facts, or verifiable claims are present—the negative materiality assertion is a self-reported claim about absence, which is not externally verifiable—so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: States no material incident has occurred (backward-looking materiality assessment), then speculates about future risks.

Category: The first clause "we have not experienced a cybersecurity threat or incident that resulted in a material adverse impact" is a materiality assessment (SI). The rest is speculation ("could adversely affect," "could subject us to"). The materiality assessment is the substantive disclosure; the speculation is generic risk language every 10-K includes.

→ Strategy Integration

Specificity: Let me scan for facts.

The statement is just a negative self-assertion with no external verification, no domain-specific terminology, and no company-specific or quantifiable facts. This is pure boilerplate materiality language. Level 1.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing policies and processes for assessing, identifying, and managing cybersecurity risks, including incident response, access control, and disaster recovery — all RMP content. Every term used (risk assessment processes, incident response, access control, disaster recovery, policies and standards, annual reviews) belongs to general enterprise risk management vocabulary and fails the ERM test; no domain-specific terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: Describes processes to assess, identify, manage cybersecurity risks. Mentions policies covering information sharing, privacy, data handling, IT processes including incident response, access control, disaster recovery. Policies reviewed annually. Monitors regulations.

Category: "What does the cybersecurity program do?" → RMP. This describes the program's processes and policies.

Specificity: Let me scan for facts.
- "incident response, access control, disaster recovery and testing" — these are general IT/ERM terms, not domain-specific
- "privacy and information security policies" — generic

- "processes to help assess, identify and manage cybersecurity risks" — generic ERM language
- "at least annually" — generic cadence

Nothing here passes the ERM test for domain terminology. "Access control" is borderline but fairly generic. "Incident response" is listed as NOT domain terminology. "Disaster recovery" is NOT domain. This is Level 1 - Generic Boilerplate. All the language here could appear in any enterprise risk management document.


reasoning: The paragraph contains a backward-looking materiality assessment ('we have not experienced any material adverse events related to a security breach or cyber-attack'), which per Rule 5 is a negative assertion with materiality framing → SI. The remaining text is general IT-dependence language and speculative consequences ('could cause delays'), which are not substantive cybersecurity disclosure. No domain terminology, firm-specific facts, or verifiable claims are present — all language is general business/IT risk that any company could use — so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: General business language about IT systems reliability, mentions precautions taken, no material adverse events from breaches, and potential consequences of system failures.

Category: This contains "we have not experienced any material adverse events related to a security breach or cyber-attack" - this is a negative assertion about materiality → SI per Rule 5. But let me check - the bulk of the text is about IT system reliability and potential consequences (speculation). The materiality statement is embedded. The paragraph primarily discusses IT system dependence and potential risks. The materiality assessment ("have not experienced any material adverse events related to a security breach or cyber-attack") is a backward-looking negative assertion → SI.

The materiality statement about not experiencing adverse events from breaches is the key disclosure here—that's a conclusion about cybersecurity's impact on business outcomes, which triggers SI classification. The speculative language about potential delays doesn't change that. Looking at specificity, the negative self-assertion about material adverse events isn't externally verifiable, so there's no concrete factual support here. This is SI.

Now examining the language more closely: there's no domain-specific terminology, no firm-specific details like named roles or committees, just generic business risk language throughout. This is Level 1 boilerplate.


fact: FFIEC framework

fact: NIST

fact: confidentiality, integrity, and availability (CIA triad)

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing framework adoption (FFIEC, NIST) for designing the Information Security Program, with speculative risk language and a cross-reference as subordinate content. Specificity is Level 2: FFIEC and NIST are named cybersecurity frameworks (domain terminology), but the company only says it 'refers to' and 'utilizes' them — not that it holds certification — so they remain Domain-Adapted rather than QV. No firm-specific facts elevate beyond Level 2.

thinking:
Let me analyze this paragraph.

Content: Describes their Information Security Program referencing FFIEC and NIST frameworks, then has speculative risk language and a cross-reference.

Category: The primary question answered is "What does the cybersecurity program do?" — framework adoption for program design. This is RMP.

Specificity:
- FFIEC → named framework, domain terminology (Level 2)
- NIST → named framework, domain terminology (Level 2)
- "Information Security Program" — generic program name
- "confidentiality, integrity, and availability" — CIA triad, domain concept

- The cross-reference at the end is tangential but doesn't elevate the specificity. Beyond these frameworks, there are no firm-specific facts or quantifiable details—just references to standards they follow rather than certifications they hold. This lands at Level 2.


fact: penetration testing

reasoning: The first sentence describes an external pen test (RMP), but sentences 2–5 are entirely about vendor security assessments, monitoring programs, and contractual requirements imposed on third-party service providers — TP dominates by text volume. 'Penetration testing' is domain terminology elevating to Level 2, but no firm-specific or verifiable facts are present (the 'vendor management group' is a generic organizational label, and no named firms, certifications, or quantified facts appear).

thinking:
Let me analyze this paragraph.

Content: External pen testing, vendor security assessments, vendor monitoring, contractual requirements.

Category: This paragraph covers both RMP (external pen testing) and TP (vendor management). The first sentence is about the company's own security (pen testing by a third party serving the company → RMP). But sentences 2-5 are all about third-party vendor oversight. By text volume, TP dominates.

→ Third-Party Risk

Specificity:
- "penetration testing" → domain term (Level 2)
- "vendor management group" → could be firm-specific? It's a named internal group.

Looking at the rest of the language, "vendor management group" is just a standard organizational unit name, not something unique to this firm. The other terms like "information security risk assessments," "privacy and cybersecurity measures," and "third party service provider monitoring program" are all generic business terminology without any distinguishing details. The only domain-specific language here is penetration testing.

→ Level 2, Domain-Adapted


reasoning: The paragraph primarily answers 'how does the board oversee cybersecurity?' — describing the Board's risk oversight role, the audit committee's responsibility for IT governance and data security, and year-round briefings on cybersecurity risks. The complaint reporting procedures and Employee Self Service portal are subordinate to the governance-structure frame. Specificity remains Level 1 because all terminology is general business/governance language (risk oversight, audit committee, disclosure committee, briefings, complaint procedures) — none passes the ERM test as cybersecurity domain terminology, and no firm-specific cybersecurity roles (CISO, CTO, etc.) or QV-eligible facts are present. 'Disclosure committee' and 'audit committee' exist at every public company and are not firm-specific.

thinking:
Let me analyze this paragraph.

Content: Describes a cybersecurity governance structure including disclosure committee, Board oversight, audit committee responsibility, briefings, complaint procedures, and an Employee Self Service portal.

The primary question: "How does the board oversee cybersecurity?" - The paragraph describes the board's risk oversight role, audit committee's responsibility for IT governance and data security, board briefings throughout the year. There's also mention of a disclosure committee and complaint reporting procedures.

This is primarily about Board Governance - the oversight structure from Board → Audit Committee, briefings, etc.

The latter part about complaint procedures and the Employee Self Service portal drifts, but the dominant frame is board/committee oversight.

Now I'm looking at what's actually firm-specific here. Most of these governance structures are standard for public companies—the disclosure committee, audit committee, and board roles are pretty generic. The general counsel and chief compliance officer aren't cybersecurity-specific either. What stands out is the Employee Self Service portal as a named internal system, and there's a specific date of 2022 tied to its development, though the independent organization they used isn't identified. So this paragraph has limited firm-specific details beyond the portal itself. "Disclosure committee" is a generic governance structure found at most companies, so it's not firm-specific. The "Employee Self Service portal" is named but fairly generic too—many organizations have similar systems. Looking at the language overall, I'm seeing mostly general business terminology without specialized cybersecurity domain terms like penetration testing or SIEM. This paragraph doesn't seem to contain the specific, distinguishing details that would mark it as firm-specific information.

I'm settling on Level 1 - Generic Boilerplate. The content is framed around board oversight and governance, which is clear, but the language stays at a general business level without firm-specific facts or domain expertise. I'd rate my confidence on the Board Governance category at 0.85.


reasoning: This is a cross-reference pointing to Item 1A Risk Factors for materiality discussion, not itself stating a conclusion about materiality. Per the N/O vs SI rule, cross-references are N/O. No substantive cybersecurity disclosure is present.


reasoning: The entire paragraph answers 'how are third-party cyber risks managed?' — covering vendor due diligence, contractual security requirements, ongoing reassessment, data use restrictions, and incident notification obligations imposed on service providers. Despite its length and detail, the vocabulary remains general business/risk management language (due diligence, risk-based approach, appropriate security controls, contractual requirements) that any ERM professional could write about non-cyber vendor risk; no cybersecurity domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph about Darden Restaurants' third-party risk management.

Category: This is clearly about Third-Party Risk (TP) - the entire paragraph is about how they manage vendor/service provider cybersecurity risks.

Specificity: Let me scan for facts:
- "due diligence of relevant service providers' information security programs" - generic process description
- "risk-based approach" - generic
- "contractually require third-party service providers" - generic TP language
- "implement and maintain appropriate security controls" - generic
- "notification and coordination concerning incidents" - generic
- No domain terminology that passes the ERM test - this is all general vendor management language

- No firm-specific facts like named roles or committees
- No QV facts

The language around information security and cybersecurity protocols is too generic to demonstrate real domain expertise. Even terms like "security controls" and "information security incidents" are standard business vocabulary without specificity. This stays Level 1 - it's describing vendor oversight processes but lacks the technical depth or organizational detail that would elevate it.


fact: threat intelligence services

reasoning: The majority of the paragraph describes requirements imposed on third parties (maintaining security controls, assessing compliance) and a Third-Party Risk Management program, making TP the primary category over the opening sentence about threat intelligence. 'Threat intelligence services' is domain terminology passing the ERM test, but there are no firm-specific or verifiable facts — the 'Third-Party Risk Management program' name is too generic to distinguish this company.

thinking:
Let me analyze this paragraph.

Content: Describes threat intelligence services and third-party risk management program.

Category: The paragraph has two parts - threat intelligence (RMP) and third-party risk management (TP). The third-party content occupies more text (sentences 2-4 vs sentence 1). The central topic of the majority is how third-party cyber risks are managed. But let me reconsider - the paragraph starts with threat intelligence (RMP), then transitions to third-party risk. About 2/3 of the text is about third-party risk management. TP wins.

Wait, Rule 3: "Vendor oversight as the central topic → TP." The majority of text is about requirements imposed on third parties and assessing their compliance. → TP.

Now I'm checking the specificity level. "Threat intelligence services" is a domain-specific term, but "Third-Party Risk Management program" is fairly generic—many organizations use that exact name. The paragraph mentions "security controls" which is also general terminology. There are no quantifiable facts or firm-specific details, so this lands at Level 2.


fact: Risk Committee of the Board

fact: Global Security Organization

fact: ERM Steering Committee

fact: CSO (Chief Security Officer)

fact: Disclosure Committee

reasoning: This is a governance-chain paragraph describing how the cyber risk management strategy is overseen from senior executives up to the Risk Committee of the Board, with reporting flows from the Global Security Organization through the ERM Steering Committee to the Board — primarily answering 'how does the board oversee cybersecurity?' Multiple firm-specific organizational facts (named committees, named team, CSO role) elevate to Level 3, but no quantified or externally verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: Describes oversight structure - senior executives, Risk Committee of the Board, Global Security Organization, reporting lines, CSO as advisor to Disclosure Committee.

Category: This is a governance-chain paragraph. It describes how the cyber risk management strategy is overseen - from senior executives up to the Risk Committee of the Board, with the Global Security Organization executing, and reporting flows. The primary question answered is "How does the board oversee cybersecurity?" - BG. But there's also management organizational structure here. The paragraph starts with board oversight ("overseen by... Risk Committee of the Board"), describes the Global Security Organization's role, and reporting lines up to the board.

The oversight structure flows from the board down through management layers - that's the BG marker. Looking at the specific elements, the Risk Committee of the Board is a named committee that's board-level and somewhat distinctive, the Global Security Organization is a named department, the ERM Steering Committee is another named governance body, and the CSO role represents firm-specific cybersecurity leadership, while the Disclosure Committee is more standard across companies.

The quarterly cadence is generic and doesn't add specificity. There are no quantified facts, specific dates, or named external entities here, so this lands at Level 3.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing vendor management processes including reviewing cybersecurity practices, contractual obligations, and security assessments imposed on service providers, making it TP. Despite mentioning several activities (reviewing practices, security assessments, contractual obligations), all are described in generic business language that any ERM professional could write — no domain terminology (e.g., SOC 2, encryption), no firm-specific facts, and no verifiable claims. The hedged framing ('may include') further confirms boilerplate-level specificity.

thinking: Third-party risk management paragraph.


reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing how cybersecurity risks are integrated into the ERM process and how the internal audit team uses ERM to develop audit plans — this is ERM integration, which falls under RMP. Person-removal test: removing VP of Internal Audit and General Counsel still leaves a description of the ERM/audit process. No domain terminology is present — 'enterprise risk management,' 'risk-based audit plan,' 'Audit Committee,' and 'General Counsel' are all general business/governance terms that fail the ERM test. VP of Internal Audit is not a cybersecurity-specific title. Everything here stays at Level 1.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes how cybersecurity risks fit into the ERM process and internal audit planning. It mentions VP of Internal Audit, General Counsel, Audit Committee. The primary question answered is about risk management processes - how cybersecurity risks are evaluated within the ERM framework.

Let me check: Is this BG? It mentions Audit Committee approving the audit plan. But the primary content is about the ERM process and how cybersecurity is integrated into it. The Audit Committee mentions are about approval, but the substance is the process itself.

Person-removal test: Remove VP of Internal Audit, General Counsel.

What remains still describes the core process - how cybersecurity risks feed into the ERM evaluation to identify top risks annually, and how that ERM program then drives the risk-based audit plan. This is fundamentally about ERM integration of cybersecurity, which falls under RMP.

Specificity check: The VP of Internal Audit title is internal audit-focused rather than cybersecurity-specific, so it's less relevant to the categorization.

Looking at the language used - "enterprise risk management," "risk-based audit plan," references to the Audit Committee and General Counsel - these are all general business and governance terms, not domain-specific terminology. There's no cybersecurity language here at all. This is Level 1.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — describing board-level oversight, quarterly reporting, and escalation of incidents to the board. No domain terminology, firm-specific facts, or verifiable claims are present; 'quarterly,' 'board of directors,' 'management,' and 'pre-determined minimum threshold' are all generic governance language that could appear in any company's filing.

thinking:
Classify this paragraph.

Category: "How does the board oversee cybersecurity?" → Board Governance. The paragraph describes board oversight, quarterly reports, information flow to the board.

Specificity: Let me scan for facts.
- "quarterly cybersecurity report" - generic cadence
- "board of directors" - generic
- "pre-determined minimum threshold" - generic process description

No domain terminology beyond general business language. No firm-specific facts (no named roles beyond generic "management" and "Board"). No QV facts.

This lands at Level 1 specificity—it's all generic process language without any concrete details or domain-specific terminology.


fact: CIO role

fact: CISO role

fact: More than 30 years of experience (CIO)

fact: More than 20 years of cybersecurity experience (CISO)

fact: Prior roles at Aegon N.V.

fact: Prior roles at Citigroup, Inc.

fact: Prior roles at JP Morgan Chase & Company

fact: SVP, CISO at Brighthouse Financial

fact: Technology VP & CISO at GE Healthcare

fact: Career started at Allstate Insurance Company

fact: Certified Information Systems Auditor (CISA)

fact: Certified Information Security Manager (CISM)

fact: Certified Information Systems Security Professional (CISSP)

reasoning: The paragraph is entirely about management qualifications, career history, and credentials for the CIO and CISO — person-removal leaves nothing, confirming MR. Specificity is Level 4 due to numerous verifiable facts: specific years of experience (30+, 20+), named prior employers (Aegon, Citigroup, JP Morgan, Brighthouse Financial, GE Healthcare, Allstate), and individually verifiable certifications (CISA, CISM, CISSP).

thinking:
Let me classify this paragraph.

Category: This is about management qualifications, credentials, career history. Person-removal test: remove all person-specific content and nothing remains. → MR

Specificity: Let me scan for facts.
- CIO - firm-specific role
- CISO - firm-specific role
- "more than 30 years of experience" - quantified (lower bound, verifiable)
- Aegon N.V., Citigroup, Inc., JP Morgan Chase & Company - named firms

- Multiple quantified experience metrics and named organizations including Brighthouse Financial, GE Healthcare, and Allstate Insurance Company, plus three industry-recognized security certifications (CISA, CISM, CISSP) that are all verifiable.

Clearly Level 4.


reasoning: The paragraph centrally answers how third-party cyber risks are managed — vendor risk assessments, contractual cybersecurity obligations, and tiered due diligence based on service sensitivity. This is squarely TP. No domain terminology (just generic risk management language like 'risk assessments,' 'due diligence,' 'contractual obligations'), no firm-specific facts, and no verifiable claims, so it remains Level 1.


fact: Cyber ERM (Enterprise Risk Management) Committee

reasoning: The paragraph establishes a management-level committee (Cyber ERM Committee), defines its cross-functional composition, and outlines its dual responsibilities (incident response implementation and reporting to the Board/Audit Committee). Per Rule 1, management-level committees are MR when focused on structure/membership and responsibilities, which is the primary purpose here — establishing who this committee is and what it is responsible for. The named 'Cyber ERM Committee' is a distinguishing organizational identifier unique to this company, elevating specificity to Level 3.

thinking:
Let me analyze this paragraph.

Content: Describes a "Cyber ERM Committee" with cross-functional representation, responsible for rapid response/incident program and reporting incidents to Audit Committee/Board for materiality assessment.

Category: This is about a management-level committee (Cyber ERM Committee) and its responsibilities. It describes both the committee structure AND its reporting to the Board. The primary question: the paragraph describes a committee's role and responsibilities, including reporting to the Board. The governance-chain aspect (reporting to Audit Committee/Board) is present but the primary content is about the committee itself - its composition, responsibilities. Let me think...

The paragraph actually covers multiple dimensions: the committee's composition and structure maps to management responsibility, the incident response program is an operational process, and the reporting chain to the Board is governance flow. When I strip away the committee membership details, what's left is the operational incident program and the governance reporting requirement—so this spans both process and governance categories.

Looking at Rule 1 more carefully, since the paragraph is fundamentally about establishing this committee and defining what it does, MR seems like the right fit. The core content is the committee itself—its cross-functional makeup and its dual mandate for incident response and board reporting.

For specificity, the named Cyber ERM Committee pushes this to Level 3, even though the incident response plan and cross-functional representation are generic concepts. The Audit Committee reference is standard across firms, so that doesn't add specificity, but the firm-specific committee name carries the classification.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing pre-engagement security risk assessments, contractual security requirements, audit rights, and ongoing vendor certification validation, all imposed ON third-party service providers. The named internal department 'Information Technology Automated Solutions (ITAS)' is a firm-specific distinguishing identifier, elevating to Level 3, but no externally verifiable claims (no named certifications, no specific numbers) push it to Level 4.

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

Facts:
- "Information Technology Automated Solutions (ITAS)" - named internal department/team → firm-specific
- "security risk assessment" - generic
- "audit rights" - generic
- "certifications" mentioned but no specific ones named

Category: Third-Party Risk - the entire paragraph is about managing vendor/supplier cybersecurity risks.

Specificity: The named department "Information Technology Automated Solutions (ITAS)" is a firm-specific fact (named team with distinguishing identifier). Level 3.


fact: Chief Information Security Officer (CISO)

fact: Cybersecurity Risk Management Team

reasoning: The paragraph answers 'how is management organized to handle cybersecurity?' by identifying the CISO, the Trust/Security/Reliability department, and the Cybersecurity Risk Management Team as responsible parties, along with their collective experience. Person-removal test: stripping roles, teams, and experience leaves only 'cybersecurity risk assessment and management processes are implemented and maintained by certain Company management' — near-nothing remains, confirming MR. Specificity is Level 3 due to multiple firm-specific named roles and teams, but no quantified-verifiable facts (no specific numbers, dates, certifications, or named external entities).

thinking:
Let me analyze this paragraph.

Category: The paragraph describes management's organizational role - the CISO, the Trust/Security/Reliability department, and the Cybersecurity Risk Management Team. It mentions who oversees what and their collective experience. Person-removal test: remove CISO, department name, team name, experience → "Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management." That collapses to near-nothing. → MR

Specificity:
- CISO → firm-specific (named_role)
- "Trust, Security and Reliability department" → firm-specific named team

- "Cybersecurity Risk Management Team" → firm-specific named team

No QV facts present - no specific numbers, dates, certifications, or named external entities. This lands at Level 3.


fact: CISO

reasoning: The paragraph answers 'How does the board oversee cybersecurity?' by describing the Audit and Risk Committee's briefing cadence from the CISO and management, plus the CISO's annual briefing to the full Board — this is oversight structure, not management's organizational role. The CISO is a firm-specific cybersecurity leadership title elevating to Level 3, but cadences ('quarterly,' 'semi-annual,' 'annual') are generic and 'external assessments' are unnamed, so nothing reaches Level 4.

thinking:
Classify this paragraph.

Category: This describes how the board/committee receives information about cybersecurity - briefing frequency, who reports, what topics. This answers "How does the board oversee cybersecurity?" → Board Governance.

Specificity:
- CISO → firm-specific (named cybersecurity role)
- Audit and Risk Committee → this is a board-level committee but named slightly differently than generic "Audit Committee" - however, "Audit and Risk Committee" is a common board committee variant. I'll treat it as borderline but it's still a board-level committee that most companies have.

The committee name is a standard variant, so I won't count it as firm-specific. The briefing cadences like quarterly or semi-annual are generic, as are references to cybersecurity training and external assessments. The CISO role itself is firm-specific at the VP level or above, and there are no quantifiable facts, specific dates, or named external entities present.


reasoning: The opening sentence states a backward-looking and forward-looking materiality conclusion ('have not materially affected... not reasonably likely to materially affect'), which is the SEC's Item 106(b)(2) assessment language → SI. The remainder is generic speculation about evolving threats and a cross-reference to Risk Factors. No domain terminology, firm-specific facts, or verifiable claims are present — all language is standard boilerplate any company could use.

thinking:
Let me analyze this paragraph.

The paragraph starts with a materiality assessment ("have not materially affected, and we do not believe are reasonably likely to materially affect"), which is the SEC's required language for Strategy Integration. The rest is generic speculation about evolving threats and a cross-reference to Risk Factors.

Category: Strategy Integration - the opening sentence states a conclusion about materiality (both backward-looking and forward-looking).

Specificity: The materiality assessment is boilerplate language. No domain terminology, no firm-specific facts, no verifiable facts. The "could result in" language is generic speculation. The cross-reference to Risk Factors is N/O-type content but subordinate.

This is clearly Level 1 boilerplate—just standard SEC language with no substantive detail.


reasoning: The paragraph opens with a backward-looking materiality assessment ('no cybersecurity incidents have had a material adverse effect') and then discusses cyber risk insurance coverage — both answering how cybersecurity affects the business/finances, making this SI. No domain terminology (cyber risk insurance is general business language), no firm-specific facts, and the negative assertion about no material incidents is not externally verifiable, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: States no material incidents, then discusses insurance and potential impacts.

Category: The first sentence is a materiality assessment (backward-looking). The second is speculation. The third mentions cyber risk insurance. The primary thrust is the materiality assessment plus insurance discussion → Strategy Integration.

Specificity: "No cybersecurity incidents have had... a material adverse effect" — negative self-assertion, not externally verifiable. "cyber risk insurance" — is this domain terminology? Insurance is general business. "cyber risk insurance" is just insurance in cyber context. No domain terms, no firm-specific facts, no QV facts.

This lands at Level 1 — it's a generic materiality claim with no substantive detail or verifiable specifics.


fact: CSO (Chief Security Officer)

fact: Chief Information Officer (CIO)

reasoning: The paragraph describes how the CSO is informed about the program and in turn informs the CIO and senior management — this is about management's organizational role and reporting lines. Person-removal test: removing the CSO and CIO leaves only generic information-flow language ('continually informed about status,' 'regularly informs... of all aspects'), so the substance is the management structure. CSO and CIO are cybersecurity-specific leadership titles qualifying as firm-specific facts, but no QV-eligible facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes the CSO's role - being informed about the program, staying current on developments, and informing the CIO and senior management. This is about management's organizational role and reporting lines.

Category: The paragraph answers "How is management organized to handle cybersecurity?" - it's about the CSO's responsibilities and reporting lines to CIO and senior management. Person-removal test: remove CSO, CIO, senior management → "continually informed about the status of the program... informed about latest developments... regularly informs... of all aspects related to cybersecurity risks and incidents." The substance collapses to generic information flow. → MR.

The specificity here is limited to organizational titles like CSO and CIO, which are firm-specific roles but lack any quantifiable facts, dates, or external references. This lands at Level 3.


reasoning: This is pure speculation ('could have a material adverse effect') combined with a cross-reference to Item 1A — no substantive cybersecurity disclosure, no materiality assessment. Generic boilerplate with no domain terminology or firm-specific facts.


fact: Chief Technology Officer (CTO)

fact: Technology Leadership Centre

fact: Risk Committee of the board of directors

fact: Controlling Department

reasoning: This paragraph describes a three-lines-of-defense governance model spanning management through board committees (Risk Committee, Audit Committee), making its primary purpose the description of the oversight structure — a governance-chain paragraph that defaults to BG. Specificity is Level 3 due to firm-specific facts: CTO as a cybersecurity-specific leadership role, the named 'Technology Leadership Centre,' and the 'Controlling Department' as distinguishing organizational units unique to this company's structure.

thinking:
Let me analyze this paragraph.

Content: Describes a three-lines-of-defense governance model. It mentions CTO, Chief Risk Officer, Risk Committee, Audit Committee, Technology Leadership Centre, IT and cybersecurity teams, Controlling Department, internal audit functions.

Category: This is describing the overall governance structure - it's a governance-chain paragraph. The question is whether it's BG, MR, or something else.

The paragraph describes the three lines of defense model spanning from management roles through board committees. It's describing the oversight structure. The first line is management (CTO + teams), second line is risk management (CRO + Risk Committee of the board), third line is audit (Controlling Department + Audit Committee).

This is fundamentally about the three-lines-of-defense model itself—how the entire governance structure works together to oversee cybersecurity. While it includes management roles, the core purpose is explaining the oversight architecture across all three lines, which makes this BG.

Now I'm evaluating which elements are firm-specific: the CTO is listed as a cybersecurity-specific leadership role, so that's firm-specific. "Technology Leadership Centre" is a named entity, also firm-specific. The Chief Risk Officer is a general role, not cybersecurity-specific. "Risk Committee" is borderline—it's common enough that I wouldn't classify it as firm-specific, unlike more specialized committees. I need to continue checking the remaining elements.


fact: ISMS (Information Security Management System)

fact: Chief Information Officer

reasoning: The paragraph primarily answers 'How does the board oversee cybersecurity?' — describing the board's and audit and risk committee's oversight role, reporting flows, and periodic updates from management, making it Board Governance. Specificity reaches Level 3 due to firm-specific cybersecurity leadership titles (CIO, Executive Director of Information Security), with 'ISMS' providing domain terminology; no QV-eligible facts are present.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph answers "How does the board oversee cybersecurity?" - it describes the board's oversight structure, the audit and risk committee's role, and how information flows to the board. This is Board Governance.

Specific facts:
- "audit and risk committee" - this is a board-level committee, but it's essentially the Audit Committee variant. Per the codebook, "Audit Committee" is NOT firm-specific because every public company has one. However, "audit and risk committee" is a specific naming variant... but it's still essentially the same as Audit Committee. I'll treat it as not firm-specific.

- "Chief Information Officer" and "Executive Director of Information Security" are both firm-specific cybersecurity roles at senior levels.
- "ISMS" is domain terminology tied to ISO 27001 standards, which counts as Level 2.
- "enterprise risk management program" is standard business language, not domain-specific.

So I'm looking at domain terminology pushing toward Level 2, and those firm-specific role titles pushing toward Level 3. There aren't any QV-eligible facts here—no specific numbers, dates, named external entities, or certifications mentioned.


reasoning: The paragraph is primarily speculative risk language ('may be insufficient', 'could result', 'may further expose') combined with a lengthy cross-reference to Item 1A Risk Factors — both hallmarks of N/O. The brief mention of 'controls and preventative actions' and 'regular testing of our cybersecurity incident response plan' is subordinate to the speculative framing and does not constitute a substantive program description. The 'could materially and negatively impact' language is generic speculation present in every 10-K, not a materiality assessment (not SI). N/O paragraphs always receive Specificity 1.

thinking:
Let me analyze this paragraph.

Content: This discusses cybersecurity threats including AI, mentions controls and preventative actions, testing of incident response plan, and then cross-references Item 1A Risk Factors. It's speculative language ("may be insufficient", "could result", "may further expose") and ends with a cross-reference.

Category: This is primarily speculative risk language ("could", "may") with a cross-reference to Item 1A. No substantive disclosure of what the company actually does. The mention of "regular testing of our cybersecurity incident response plan" is brief. The bulk is speculation and cross-reference.

The paragraph's main thrust is speculation about threats and pointing to another section, while the actual measures described—generic controls and routine testing—are secondary and vague. This fits N/O since the cross-reference and speculation dominate over any meaningful disclosure of cybersecurity practices. I'm settling on N/O with Level 1 specificity since the disclosure relies heavily on cross-references rather than providing substantive detail about the company's actual cybersecurity measures or incidents.


reasoning: The paragraph centrally addresses how third-party cyber risks are managed — vendors, service providers, and third-party systems — making TP the primary category. The language is entirely generic ('risk-based approach,' 'identifying and overseeing') with no domain terminology, firm-specific facts, or verifiable claims.


fact: Director - Information Systems (i.e. the Company's chief information officer / CIO)

reasoning: The paragraph primarily answers 'How does the board oversee cybersecurity?' by describing the Board's oversight of ERM, the Audit and Compliance Committee's supporting role, and interaction with senior management — classic BG. The Director - Information Systems is explicitly identified as the company's CIO, a cybersecurity leadership title at the firm-specific level; however, no domain terminology or QV-eligible facts are present, so specificity stays at Level 3.

thinking:
Let me analyze this paragraph.

Content: Board oversight of ERM and cybersecurity risk, Audit and Compliance Committee interacts with senior management including Director - Information Systems (CIO), board committees play role in risk management.

Category: This answers "How does the board oversee cybersecurity?" - Board Governance (BG). The paragraph describes the board's oversight structure, the committee supporting it, and how information flows.

Specificity:
- "Audit and Compliance Committee" - this is a board-level committee variant, similar to "Audit Committee" which every company has. But "Audit and Compliance Committee" is a slight variant... still essentially generic.

- The Director - Information Systems role is explicitly identified as the CIO, and since CIO is listed as a firm-specific cybersecurity title in the codebook, this reference qualifies as firm-specific even though the "Director of IT" title alone wouldn't.
- "Audit and Compliance Committee" is functionally equivalent to the standard "Audit Committee" that every company has, so it's not firm-specific.
- The paragraph contains no domain-specific terminology or QV facts, just the one firm-specific element: the CIO role, which maps to Level 3.


fact: security questionnaires

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — it describes the vendor management process including risk assessments, security questionnaires, vendor security program reviews, and contractual cybersecurity obligations imposed on providers, making it squarely TP. For specificity, 'security questionnaires' is a cybersecurity-specific vendor assessment practice (an ERM professional would say 'vendor questionnaires' generically), pushing to Level 2, but the remaining language (risk assessments, contractual obligations, review of reports and audits) is general vendor risk management vocabulary that stays at Level 1.

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

Facts: vendor management process details, risk assessments, security questionnaires, review of vendor security programs, contractual obligations. Let me check domain terminology and specificity.

"security questionnaires" - this is a vendor risk management practice
"risk assessments" - general ERM term, Level 1
"security assessments" - borderline
"contractual obligations related to cybersecurity" - general

The paragraph is centrally about how they manage third-party cyber risks → TP.

For specificity: Let me look for domain terms. "Security questionnaires" in vendor context - is this domain-specific? Vendor security questionnaires are a cybersecurity-specific practice.

Looking at the language more carefully, the paragraph relies on fairly generic vendor risk management terminology. "Security questionnaires" does stand out as somewhat specific to cybersecurity vendor assessment practices, though it's borderline whether a non-security ERM professional would use it in the same way. The rest—risk assessments, vendor security program reviews, and audit reports—are common across enterprise risk management more broadly.

I'm settling on Level 2 for Domain-Adapted, since "security questionnaires" is distinctly cybersecurity-focused terminology, even if the overall framing remains accessible to general ERM professionals.


fact: firewalls

fact: intrusion prevention

fact: endpoint detection and response

fact: vulnerability assessments

fact: cybersecurity threat intelligence

reasoning: The paragraph answers 'what does the cybersecurity program do?' by listing technical safeguards and security activities, making it RMP. Multiple domain-specific terms (firewalls, intrusion prevention, EDR, vulnerability assessments, threat intelligence) elevate it to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: Describes technical safeguards - firewalls, intrusion prevention, EDR, monitoring, access controls, vulnerability assessments, threat intelligence.

Category: RMP - "What does the cybersecurity program do?" - describes security tools and activities.

Specificity: Let me scan for facts:
- firewalls → domain term
- intrusion prevention (IPS) → domain term
- endpoint detection and response (EDR) → domain term
- vulnerability assessments → domain term
- cybersecurity threat intelligence → domain term

No firm-specific facts, no QV facts. Level 2.


reasoning: This is an introductory paragraph to a cybersecurity program description, answering 'what does the program do?' albeit at a very high level. It contains no domain terminology, firm-specific facts, or verifiable claims — 'confidentiality, integrity, and availability' is general information security language any ERM professional would use, and 'cybersecurity risk management principles' is generic framing.


fact: attack vectors

reasoning: The paragraph opens with a materiality assessment ('have not experienced any material cybersecurity events to date'), which is a backward-looking negative assertion about materiality → SI. The subsequent 'could materially affect' is speculation and the cross-reference to Item 1A is subordinate. For specificity, 'attack vectors' is a cybersecurity domain term that an ERM professional would not naturally use, elevating to Level 2.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. "we have not experienced any material cybersecurity events to date" - negative assertion about materiality → SI
2. "new advanced cybersecurity threats and attack vectors could materially affect..." - speculation with "could" → NOT SI
3. Cross-reference to Item 1A risk factors

The first clause is a materiality assessment (negative assertion: "have not experienced any material cybersecurity events"). Per the codebook, "We have not experienced any material cybersecurity incidents" → SI (negative assertion with materiality framing).

The second clause uses "could materially affect" which is speculation, so that's not SI. The cross-reference to Item 1A is subordinate to the main materiality assessment in the first sentence, which makes this overall a Strategy Integration disclosure. Looking at specificity, the language about "cybersecurity threats and attack vectors" is fairly generic and the negative self-assertion about not experiencing material events isn't externally verifiable, so there's no additional specificity marker here.

On the domain terminology question—"attack vectors" is actually cybersecurity-specific jargon that an ERM professional wouldn't naturally use. That pushes this to Level 2 specificity.


fact: ransomware

fact: denial-of-service

fact: advanced and persistent, highly organized adversaries, including nation state actors

fact: 21st Century Security vision

reasoning: The paragraph primarily answers how cybersecurity affects the business — it frames cybersecurity as critical to their strategic vision and digital transformation, discusses the threat landscape as a defense company, and notes they 'expend considerable resources.' The 'could materially adversely affect' language is speculation (not an assessment), but the overall frame is strategic importance, not program description. Specificity reaches Level 3 via '21st Century Security vision,' a named firm-specific strategic initiative, with domain terms like ransomware, denial-of-service, and nation-state/APT threat references at Level 2.

thinking:
Let me analyze this paragraph.

Content: Lockheed Martin discussing cybersecurity as critical to their vision, listing threat types they face, mentioning supply chain risks, and stating they expend resources on cybersecurity.

Category: This is about how cybersecurity affects the business/strategy. It talks about their vision, digital transformation, threats they face as a defense company, and that incidents "could materially adversely affect" operations. But "could materially adversely affect" is speculation, not an assessment. The paragraph is more about framing cybersecurity's importance to their business strategy and the threat landscape. It doesn't describe what the program does (RMP), board oversight (BG), or management roles (MR).

The "could materially adversely affect" language is speculative and doesn't count as a substantive impact assessment. The core of this paragraph is positioning cybersecurity as strategically important to their business vision and digital transformation, while acknowledging the threat landscape they operate in. That strategic framing does qualify as SI, even though the specific impacts remain hypothetical.

Looking at the specificity markers: "ransomware" and "denial-of-service" are standard cybersecurity domain terms, "nation state actors" and references to advanced persistent threats signal APT-level concepts, and "21st Century Security vision" is a named internal program that distinguishes this company's approach. That combination puts us at Level 3 specificity.


reasoning: The paragraph describes how the Audit Committee reports to the Board on cybersecurity and how the Board receives briefings from management — answering 'how does the board oversee cybersecurity?' No domain terminology, no firm-specific facts (Audit Committee and Board are generic governance structures every public company has), and no verifiable claims.


fact: Vice President and Chief Information Officer (CIO)

fact: Chief Information Security Officer (CISO)

fact: Cybersecurity Team

fact: Cybersecurity Executive Committee

fact: 27 years of cybersecurity experience

fact: less than 400 CISOs globally

reasoning: The paragraph primarily describes management's organizational structure for cybersecurity — roles (CIO, CISO), reporting lines, qualifications, and responsibilities — making it Management Role. Multiple QV-eligible facts drive Level 4: specific years of experience (27, 17), the named FBI CISO Academy (verifiable external program), and a quantified claim about fewer than 400 graduates globally.

thinking:
Classify this paragraph.

Category: This is about management organization - CISO, CIO, their qualifications, reporting lines, team structure. Person-removal test: remove all person-specific content and very little remains. → Management Role.

Specificity: Let me scan for facts:
- "Vice President and Chief Information Officer" / "CIO" → firm-specific (named_role)
- "Chief Information Security Officer" / "CISO" → firm-specific (named_role)
- "27 years of cybersecurity experience" → QV (quantified, verifiable)

- "17 of which are in the oil and gas industry" → QV (quantified)
- "less than 400 CISOs globally" → QV (quantified)
- "FBI's CISO Academy in Quantico, Virginia" → QV (named external entity, verifiable)
- "Cybersecurity Executive Committee" → firm-specific (named_committee)
- "Cybersecurity Team" → named_team

Multiple quantified facts and named entities throughout push this to Level 4.


fact: CISO

fact: two members of the Board of Directors

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing the CISO's annual briefings to the Audit Committee and the information flow between oversight bodies — this is board-level oversight structure, so BG. Specificity reaches Level 4 because 'two members' is a specific headcount verifiable against proxy filings, alongside firm-specific facts (CISO, Cybersecurity Executive Committee).

thinking:
Let me analyze this paragraph.

Content: Describes CISO briefing the Audit Committee annually on cybersecurity matters, and notes the Audit Committee composition overlaps with the Cybersecurity Executive Committee.

Category: This is about how the board (via Audit Committee) oversees cybersecurity - briefing frequency, scope, and information flow. BG.

Specificity:
- CISO → firm-specific (named cybersecurity role)
- Cybersecurity Executive Committee → firm-specific (named non-generic committee)
- "annually" → generic cadence, not QV
- "two members" → specific number, but is this verifiable? It's about board composition which could be checked against proxy statements.

The "two members" reference is a concrete headcount that I can verify, so this pushes it to Level 4.


reasoning: The paragraph centrally answers how third-party cyber risks are managed — evaluating vendors' controls, reviewing those with access to customer information/network, and imposing contractual confidentiality obligations. This is requirements imposed ON vendors, making it TP. No domain terminology, firm-specific facts, or verifiable claims are present; the language ('internal controls,' 'confidential information,' 'applicable legal requirements,' 'appropriate controls and mechanisms') is generic business/ERM vocabulary that any company could use.

thinking: Third-party vendor oversight is the central topic.


reasoning: The paragraph describes risk assessment activities (identifying threats, evaluating likelihood and damage, assessing sufficiency of controls), answering 'what does the cybersecurity program do?' → RMP. All language uses generic ERM vocabulary (risk assessments, policies, procedures, safeguards) with no domain terminology, firm-specific facts, or verifiable claims.


fact: Vice President of IT & Digitization

reasoning: The paragraph answers 'how is management organized?' by describing the VP of IT & Digitization and the IT Team's responsibilities and experience. Person-removal test: removing the VP title and team composition leaves only generic language ('identifying, assessing, monitoring, managing cybersecurity risks'), so the substance is about roles → MR. The VP of IT & Digitization is a VP-level title with IT portfolio, qualifying as firm-specific (Level 3), but no quantified-verifiable facts are present.

thinking:
Let me analyze this paragraph.

Category: This describes management's organizational role - VP of IT & Digitization, IT Team composition, their responsibilities. The person-removal test: remove "Vice President of IT & Digitization and information technology team" and experience details → what remains is generic "identifying, assessing, monitoring, managing and communicating cybersecurity risks" and "developing and implementing enterprise-wide cybersecurity strategies." The substance collapses without the people. → MR

Specificity:
- "Vice President of IT & Digitization" — This is a VP-level title whose portfolio includes IT. Per the codebook, VP-or-above titles whose portfolio includes IT/cybersecurity are firm-specific. → Level 3

- The remaining language about responsibilities and experience is boilerplate with no specific quantifiable facts, dates, or external references.


reasoning: This is a cross-reference directing readers to Item 1A Risk Factors, with no substantive cybersecurity disclosure. Cross-references are N/O and always receive Specificity 1.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — describing how the Board and Audit Committee receive reports from management, which is a classic BG oversight-flow pattern. No domain terminology, no firm-specific facts (Board, Audit Committee, and 'management' are generic governance structures every public company has), and no verifiable claims, so it remains Level 1.


fact: CISO (Chief Information Security Officer)

fact: Executive Vice President and Chief Information Officer (CIO)

reasoning: The paragraph introduces the company's enterprise information security program for assessing, identifying, and managing cybersecurity risks — answering 'what does the program do?' Person-removal test: removing the CISO and CIO references leaves 'assess, identify and manage material risks from cybersecurity threats through our enterprise information security program,' which is a (generic) program description, pointing to RMP over MR. Specificity is Firm-Specific due to the named CISO and EVP/CIO roles, but no QV-eligible facts (no specific numbers, dates, certifications, or named external entities).


reasoning: The paragraph's central topic is how third-party cyber risks are managed—vendors, service providers, and external users of systems—directly answering the TP question. Specificity remains Level 1 because the language is entirely generic ERM vocabulary ('comprehensive, risk-based approach to identifying and overseeing cybersecurity risks'); no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me classify this paragraph.

Content: About managing third-party cybersecurity risks - vendors, service providers, external users. Central topic is third-party risk oversight.

Category: Third-Party Risk - "How are third-party cyber risks managed?" This is clearly about oversight of external parties' cybersecurity.

Specificity: Let me scan for facts.
- "comprehensive, risk-based approach" - generic ERM language
- "key vendors, service providers and other external users" - generic
- "Our Adviser" - this is a named organizational entity (the external adviser manages cybersecurity for this REIT).

"Adviser" doesn't add specificity since it's standard terminology for externally managed REITs. The language relies entirely on generic risk management concepts like "risk-based approach" and "identifying and overseeing cybersecurity risks" with no mention of actual tools, frameworks, or firm-specific details like named roles or committees. This is Level 1 - Generic Boilerplate.