reasoning: The paragraph describes a management-level Information Security committee — its composition, review cadence, and relationship with the CISO. The grammatical subject is the management committee (not the board), and the content focuses on management structure and oversight responsibilities, fitting Management Role's coverage of 'management committees responsible for cybersecurity.' Named non-generic committee (Information Security committee), cybersecurity-specific roles (CDIO, CISO), and specific team composition make it Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named firms, named tools) are present.

thinking:
Let me analyze this paragraph.

Content: Describes an Information Security committee composed of senior management, reviews cybersecurity updates quarterly, approves strategy proposed by CISO.

Category: This is about a management committee's composition and activities. The grammatical subject is "Our Information Security committee" - this is a management-level committee, not a board committee. It describes management's role in overseeing cybersecurity. The CISO reports to this committee. This is Management Role - it's about the management structure/committee responsible for cybersecurity oversight.

Wait - let me reconsider.

The "Information Security committee" is a management committee (consists of senior management), not a board committee, so this is about management's role in cybersecurity oversight. The paragraph focuses on the committee's structure and responsibilities—reviewing updates and approving strategy—which fits the Management Role category. For specificity, the named "Information Security committee" qualifies as firm-specific, and the "CDIO" title is a cybersecurity-adjacent role worth noting.

Looking at the other titles mentioned: "CFO" and "Chief Administrative Officer and General Counsel" are generic C-suite positions that don't count, but "CISO" is a cybersecurity-specific role that does. So I'm seeing three firm-specific IS facts here—the named committee, the CDIO, and the CISO—with no quantitative values like dates, dollar amounts, or headcounts. This is Firm-Specific with a specificity level of 3.

fact: Information Security committee

fact: CDIO (Chief Digital & Information Officer)

fact: CISO

fact: Committee composition: CDIO, CFO, CAO and General Counsel


content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: This paragraph is an introductory preamble that acknowledges cybersecurity threats exist and describes potential generic consequences (disruptions, theft, reputational harm, expenses). It does not describe any actual risk management process, framework, governance structure, or materiality assessment. Like Borderline Case 9 (generic regulatory compliance language), it states truisms applicable to any public company without disclosing what the company actually does. 'AFG' is a company self-reference on the NOT list.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content: This is general risk acknowledgment language. It says AFG recognizes importance of managing cyber risks, acknowledges they're a target for various attacks, and notes potential consequences. No specific processes, frameworks, roles, or incidents described.

Category: This is generic risk language - no actual process description, no materiality assessment, no board/management details. It's essentially saying "cyber risks exist and could be bad." This feels like None/Other or possibly Risk Management Process at a stretch.

Looking more carefully: "Risk Management and Strategy" is a section header embedded in the paragraph. The content acknowledges cyber risks exist but doesn't describe any actual program, process, or framework.

The preamble mentions assessing and managing material risks, but the rest is just generic threat acknowledgment without substantive disclosure. The codebook is clear that I should only assign None/Other when there's truly no cybersecurity content at all, but this paragraph lacks any real process details, governance structure, or materiality assessment—it's boilerplate language that could describe any company's cyber posture. The paragraph mentions "assessing, identifying and managing material risks" but that's just introductory language without describing any actual process, framework, or activity. Looking at the codebook's guidance on generic acknowledgments versus substantive disclosures, this falls into the None/Other category with Specificity 1 since no real program or strategy is detailed.


content_category: Risk Management Process

category_confidence: medium

reasoning: The paragraph's primary content describes the company's internal risk management activities — evaluating safeguards, addressing gaps, monitoring effectiveness. The two personnel are mentioned as attribution for who manages this process, with their years of experience provided as supporting qualifications. Applying the person-vs-function test, the first sentence stands alone as a complete process description; removing the role titles and credentials leaves the substantive process content intact, pointing to Risk Management Process. Neither 'Manager of Information Technology' (essentially IT Manager, on the NOT list) nor COO (generic C-suite, NOT list) qualifies as a cybersecurity-specific role, but the two specific experience durations (25 years, 15 years) are QV-eligible hard facts, reaching the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes risk assessment follow-up processes (re-design, implement, maintain safeguards, address gaps, monitor effectiveness) and identifies two people who manage this process with their experience levels.

Category: The paragraph has two parts - process description and person identification. The first sentence is about risk management processes. The second sentence identifies two people (Manager of IT, COO) with their experience.

Person-vs-function test: The first sentence is entirely about processes. The second sentence names roles and their experience. But the dominant content is split. The first sentence describes what the company does (evaluate, re-design, implement, maintain, monitor).

The second sentence attributes the process to specific people and provides their qualifications. The first sentence stands alone as a complete process description, while the second sentence adds the personnel managing it along with their years of experience. This is borderline—the core content is the process itself, but the qualifications are clearly person-focused.

Looking at the roles mentioned: "Manager of Information Technology" doesn't appear on the cybersecurity-specific list, and it falls under generic IT leadership rather than cybersecurity-specific titles. The COO is explicitly on the NOT list. Neither role qualifies as a firm-specific fact from the information security criteria.

However, the specific years of experience—25 years and 15 years—are hard verifiable facts that meet the quantified-verifiable standard. That gives us two concrete data points that count toward the classification. I'm checking the calibration example—years of experience with specific numbers definitely count as QV-eligible facts, so two experience durations qualify. Even though the roles aren't cybersecurity-specific, the numeric values themselves meet the IS criteria. This falls under Risk Management Process as the dominant category, making it Quantified-Verifiable based on those two hard facts.

Let me reconsider the category one more time though. The paragraph leads with a process description about evaluating and redesigning safeguards, then attributes that process to specific people with their experience levels. If I removed the names and credentials, the first sentence still stands as a complete process statement, so Risk Management Process is the right call. I'm also wondering whether "Manager of Information Technology" should count as firm-specific terminology.

Looking at the NOT list, titles like "IT Manager," "Director of IT," and "Head of IT" are too generic, and "Manager of Information Technology" falls into that same category—it's a standard corporate IT role, not a cybersecurity-specific position. So that doesn't qualify as firm-specific.

What does stand out are the two quantified experience metrics: 25 years in information technology and 15 years in information technology management. Both have specific numbers attached, making them Quantified-Verifiable facts.

fact: Manager of Information Technology has over 25 years of IT experience

type: quantified

fact: COO has over 15 years of IT management experience


content_category: Management Role

reasoning: The CTO is the grammatical subject of every sentence, and the paragraph opens with reporting structure (reports to CEO) and personal qualifications (25+ years of experience). While much of the paragraph describes functional activities (risk identification, control implementation, threat intelligence), the consistent framing around the CTO as the actor and the inclusion of personal credentials make Management Role the dominant category. Applying the person-vs-function test, the qualifications and reporting line are substantive content, not incidental attribution. Specificity is Firm-Specific: CTO is a cybersecurity-specific title (one IS fact) and '25 years' is a specific number, but only one QV-eligible hard fact (the years of experience), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph is about the CTO - their reporting line, experience, and what they do. Let me apply the person-vs-function test.

The paragraph mentions:
- CTO reports to CEO (reporting line)
- 25 years of experience
- Participates in various cybersecurity organizations

But then it describes what the CTO does - collaborates with VPs, identifies risks, implements controls, meets with senior leadership, supervises efforts to prevent/detect/mitigate.

This is a mixed paragraph. The person-vs-function test: if I remove the CTO's title and credentials, does the paragraph still describe substantive activities? Yes - it describes risk identification, control implementation, collaboration, threat intelligence.

The CTO remains the grammatical subject throughout, with personal qualifications like 25 years of experience woven in. The paragraph opens with reporting structure and credentials, then transitions into describing the role's responsibilities. While the CTO's background matters, the content is dominated by what the position actually does—managing risks, implementing controls, and coordinating across the organization.

Looking at the verifiable facts: the CTO title is firm-specific, the 25 years of experience is a hard number, and reporting to the CEO is generic C-suite. That gives me one firm-specific fact, which means this qualifies as Firm-Specific. For QV-eligibility, I only have one specific number (25 years), so it doesn't meet the threshold for that category.

fact: Chief Technology Officer (cybersecurity-specific leadership role)

fact: Over 25 years of experience in managing IT/cybersecurity teams


reasoning: While the first two sentences mention Board oversight, the dominant content describes the company's cybersecurity program: framework adoption (ISO, NIST), integration into operations, and a cross-functional approach focused on confidentiality, integrity, and availability. The Board references set context but the primary communicative purpose is describing risk management processes. Named frameworks (ISO, NIST) elevate beyond boilerplate but no firm-specific facts are present.

thinking:
Let me analyze this paragraph.

Content: The paragraph starts with Board oversight language, then shifts to describing the company's cybersecurity program - frameworks (ISO, NIST), integration into operations, and a comprehensive approach to risk management.

Category: The Board is mentioned in the first two sentences, but the bulk of the paragraph describes the company's risk management processes - framework adoption, cross-functional approach, CIA triad focus. The dominant content is Risk Management Process.

Person-vs-function test: N/A - no specific person mentioned.

Specificity: Named frameworks - ISO and NIST. No firm-specific facts beyond that.

The rest relies on generic language about cybersecurity practices, so this falls into the Sector-Adapted category.

fact: International Organization for Standardization (ISO)

type: framework

fact: National Institute of Standards and Technology (NIST)


reasoning: The paragraph is overwhelmingly about the people — the CTO's and VPCS's qualifications, years of experience, educational backgrounds (named universities), and certifications. This is squarely Management Role per the person-vs-function test. Specificity is Quantified-Verifiable with numerous hard verifiable facts: specific years of experience (25, 20, 10), named universities (George Washington, SUNY, Georgetown, Virginia Tech, Purdue), and named certifications (CISSP, CISM, CISA) — far exceeding the two-fact threshold.

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

Content: This paragraph describes the management team's cybersecurity responsibilities and then extensively details the qualifications of two individuals - the CTO and the VPCS (VP of Cybersecurity/Security). It covers their years of experience, educational backgrounds, and certifications.

Category: This is clearly Management Role - the paragraph is about the people (CTO and VPCS), their qualifications, credentials, education, and experience. The first two sentences mention the team's responsibilities, but the bulk of the paragraph is about who these people are.

Specificity: Let me count QV-eligible hard facts:

1. "over 25 years" - specific number (years of experience)
2. "M.S. in information systems from George Washington University" - named university
3. "B.A. in computer science from State University of New York" - named university
4. "over 20 years" - specific number
5. "10 years in senior leadership roles" - specific number
6. "MBA from Georgetown University" - named university
7. "M.S. in information systems from Virginia Tech University" - named university
8. "B.S. in computer information technology from Purdue University" - named university
9. CISSP, CISM, CISA - named certifications

That's way more than 2 - I'm seeing nine distinct QV-eligible facts here, including specific years of experience, multiple named universities, and professional certifications.

fact: CTO role

fact: VPCS role

fact: CTO has over 25 years of information technology experience

fact: VPCS has over 20 years of information security and technology experience

fact: VPCS has 10 years in senior leadership roles

fact: MBA from Georgetown University

fact: CISSP, CISM, and CISA certifications


content_category: Strategy Integration

reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected us, including our business strategy, results of operations or financial condition'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. The brief mention of past threats/breaches is subordinate to the materiality conclusion. No specific dates, named firms, tools, or other facts from the IS list appear — all language is boilerplate.

thinking:
Let me analyze this paragraph.

Content: It makes a materiality assessment ("have not materially affected us, including our business strategy, results of operations or financial condition"), mentions past threats/breaches briefly, and cross-references Risk Factors. The materiality assessment is the primary content → Strategy Integration per Rule 6.

Specificity: No named frameworks, no specific dates, no dollar amounts, no named firms, no cybersecurity-specific roles. The materiality language is boilerplate. → Generic Boilerplate.


content_category: Board Governance

reasoning: The paragraph opens by establishing the Board's delegation of cybersecurity oversight to the Audit Committee, framing the entire governance chain (Board → Audit Committee → CTO → VPCS). While the latter half introduces management roles and reporting lines, the primary communicative purpose is the board-level delegation structure, making Board Governance dominant per Case 5 (opening clause sets the frame). Specificity is Firm-Specific: CTO and VP of Cyber Security are cybersecurity-specific titles on the IS list, but named roles do not count toward QV, so two IS facts yield Firm-Specific, not Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers both board governance and management roles. Let me determine the dominant category.

Sentences:
1. "Our Board considers cybersecurity risk as part of its risk oversight function and has delegated to the Audit Committee oversight of cybersecurity and other information technology risks." - Board Governance
2. "The Audit Committee oversees management's implementation of our cybersecurity risk management program." - Board Governance
3. "Our Chief Technology Officer (CTO) is responsible for oversight of our cybersecurity risk management program." - Management Role

4. "Our Vice President of Cyber Security (VPCS), who reports up to the CTO, is responsible for day-to-day assessment and management of cybersecurity risk." - Management Role

It's split roughly 50/50. The paragraph opens with Board governance (delegation to Audit Committee) then shifts to management structure (CTO, VPCS, reporting lines). The primary communicative purpose seems to be establishing the full oversight chain from Board → Audit Committee → CTO → VPCS.

The opening frame is Board Governance (Board delegates to Audit Committee), but then the paragraph shifts to describing the management reporting structure. Looking at Rule 2: "Board delegates responsibility to management → Board Governance." But the latter half is about the management roles themselves.

Given the tiebreaker: "Board oversight mentioned briefly + management roles as main focus → Management Role" vs "Management mentioned briefly + board oversight as main focus → Board Governance." It's fairly balanced—the first two sentences establish board oversight while the last two detail management roles. But the opening clause frames the entire chain as board delegation, making the management details subordinate to that governance structure. I'll categorize this as Board Governance.

For specificity, the CTO is a cybersecurity-specific title on the IS list, and the Vice President of Cyber Security is clearly cybersecurity-focused. The Audit Committee is generic and doesn't count toward IS specificity.

The named roles—CTO and VP of Cyber Security—are firm-specific but don't qualify for QV purposes, so this falls into Firm-Specific (3).

fact: Chief Technology Officer (CTO) oversees cybersecurity program

fact: Vice President of Cyber Security (VPCS) reports to CTO


reasoning: This paragraph quotes the SEC's regulatory rationale for Item 106(b)(1) and describes what companies must do under Item 106(b)(2). It contains no company-specific cybersecurity disclosure — it is regulatory commentary and rule summarization, not a substantive disclosure about the company's own practices.

thinking: This paragraph is quoting the SEC's purpose for the disclosure rules and describing regulatory requirements. It's not making any company-specific disclosure.


reasoning: The paragraph describes the company's internal cybersecurity training and awareness programs, including new-hire training and phishing exercises — all internal processes. The brief mention of Board and management oversight is subordinate to the training program description. No named frameworks, tools, roles, dates, or quantified facts are present; 'learning management platform,' 'phishing training,' and 'security awareness training' are all common practices on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity awareness/training programs, learning management platform, internal policies, training for new hires, phishing training/testing. Mentions management and Board oversight briefly.

Category: This is about the company's internal cybersecurity processes - training programs, policies, phishing testing. The mention of management and Board is subordinate. → Risk Management Process

Specificity: Let me check for specific facts:
- "learning management platform" - generic, not a named product
- "management and our Board of Directors" - generic governance

- "newly hired team members" - generic
- "E-mail phishing training and testing" - common practice
- No named frameworks, no named tools, no specific dates, no numbers, no named roles (CISO etc.)

All items fall on the NOT list. → Generic Boilerplate


reasoning: The paragraph contains an explicit materiality assessment ('have not experienced any cybersecurity incidents that have materially affected us, including our business strategy, results of operations, or financial condition'), making it Strategy Integration per Rule 6. The appended cross-reference to Risk Factors does not change the classification. No firm-specific facts are present — the named Risk Factor section title is a generic description of a risk, not a specific fact from the IS list.

thinking: Materiality assessment paragraph with cross-reference.


reasoning: The paragraph describes the company's approach to designing and assessing its cybersecurity program using ISO and NIST frameworks, which is squarely Risk Management Process. It names two recognized standards (ISO, NIST) but includes no firm-specific facts — the caveat that framework adoption doesn't imply meeting particular standards is generic language — so it remains Sector-Adapted.

thinking:
Classify this paragraph.

Content: Describes framework adoption (ISO, NIST) for risk management. This is about the company's own internal processes/methodology.

Category: Risk Management Process

Specificity: Names NIST and ISO frameworks → Sector-Adapted. But does it contain anything firm-specific? The disclaimer "This does not imply..." is generic. No firm-specific facts from the IS list. → Sector-Adapted (2).

fact: ISO information security risk management frameworks

fact: NIST information security risk management frameworks


reasoning: The paragraph contains an explicit materiality assessment ('the Company has not detected a significant compromise, significant data loss or any material financial losses related to cybersecurity attacks'), which per Rule 6 triggers Strategy Integration even though the surrounding text is generic threat-landscape language. No named frameworks, roles, dates, tools, or other facts from the IS list appear—every phrase is interchangeable boilerplate.

thinking:
Let me analyze this paragraph.

Content: This discusses the threat landscape, acknowledges no significant incidents to date, and discusses ongoing risks. It's a materiality-adjacent statement but also generic risk language.

The key sentence: "Although to date the Company has not detected a significant compromise, significant data loss or any material financial losses related to cybersecurity attacks" - this is close to a materiality assessment but uses "significant" and "material financial losses" rather than the standard "materially affected our business strategy, results of operations, or financial condition."

Actually, it says "any material financial losses related to cybersecurity attacks" - this is a materiality assessment. But the paragraph as a whole is mostly about the threat landscape and risk acknowledgment.

The materiality piece is really just one clause buried in a longer paragraph that's primarily focused on describing threats as severe and ongoing. Looking at the structure, I see a generic security procedures statement, then the threat severity language, then the materiality clause about no material financial losses, and finally more generic risk language about ongoing exposure. The materiality assessment is there, but it's embedded within what's fundamentally a risk acknowledgment paragraph rather than a strategic assessment.

Since the paragraph explicitly evaluates whether cybersecurity incidents have materially affected the company—even if just to say they haven't—that triggers the Strategy Integration classification under Rule 6. And given that there are no named frameworks, specific roles, dates, or concrete facts from the IS list, just standard boilerplate language throughout, this falls squarely into Generic Boilerplate.


reasoning: The paragraph is primarily about the qualifications and credentials of people involved in cybersecurity—the VP of Risk Management's certifications, MSSP personnel certifications, and external firm personnel qualifications. This is a person-focused paragraph (credentials, qualifications) rather than a function-focused one, making it Management Role. Multiple named certifications (CISA, CIA, CRMA, CISSP, CISM, Fortinet, Citrix, ITIL, etc.) easily exceed the two-fact QV threshold.

thinking:
Let me analyze this paragraph.

Content: Describes credentials of VP of Risk Management, MSSP personnel certifications, and external firm personnel qualifications.

Category: The paragraph is about people's qualifications and credentials. The VP of Risk Management's certifications are described, plus MSSP and external firm personnel credentials. The primary focus is on WHO these people are (their qualifications), not what processes they run.

The VP of Risk Management with specific certifications - this is about the person's qualifications. But it also covers MSSP personnel and external firm personnel credentials. The dominant theme is credentials/qualifications of people involved in cybersecurity.

Now I'm distinguishing between the company's own management and third-party vendors. The VP of Risk Management is internal, while the MSSP and external firms are external partners. Even though the paragraph covers both groups, they're all being evaluated on their qualifications and credentials. The VP gets less coverage than the vendors, but since the paragraph is fundamentally about the company's risk management personnel and their expertise, I'd categorize this as Management Role. The VP of Risk Management leading the paragraph establishes the frame, and while third-party credentials take up more text, the core purpose is demonstrating that qualified people—both internal and external—oversee the cybersecurity program. Management Role captures this better than Third-Party Risk since the narrative centers on personnel qualifications across the organization.

Now I'm tallying up the specific certifications mentioned to assess QV eligibility: CISA, CIA, CRMA, CISSP, ITIL Foundations, Fortinet certifications, Microsoft certifications, Citrix certifications, CISM, and CITP all count as named credentials.

fact: VP of Risk Management

fact: CISA certification (VP)

fact: CIA certification (VP)

fact: CRMA certificate (VP)

fact: CISSP (MSSP personnel)

fact: ITIL Foundations (MSSP)

fact: Fortinet Certified Network Security Administration and Professional (MSSP)

fact: Microsoft Certified IT Professional, Technology Specialist, Solutions Associate (MSSP)

fact: Citrix Certified Administrator/Citrix Presentation Server 4.0 (MSSP)

fact: CISM (external firms)

fact: CITP (external firms)


reasoning: The Audit Committee is the grammatical subject in sentences 1 and 3, and sentence 2 describes the CISO presenting TO the committee as part of board oversight — the frame is board-level oversight of cybersecurity risk. The CISO title (cybersecurity-specific role on the IS list) elevates specificity to Firm-Specific, but 'Audit Committee' and 'periodically' are on the NOT list and do not count toward QV.

thinking:
Let me analyze this paragraph.

Content: The Audit Committee oversees cybersecurity risks, CISO presents to the audit committee, and the committee's oversight includes understanding risks and management's response.

Category: The grammatical subject is the Audit Committee (board committee) in sentences 1 and 3. Sentence 2 has CISO as subject but in the context of presenting TO the audit committee. The frame is board oversight. → Board Governance.

Specificity:
- "Audit Committee" — NOT list (generic)
- "CISO" — IS list (cybersecurity-specific title) → Firm-Specific

- "Periodically" — NOT list (generic cadence)
- No second hard verifiable fact for QV

So this lands as Firm-Specific with just one firm-specific element.

fact: CISO presents cyber incidents and risks to the audit committee


reasoning: The paragraph identifies specific cybersecurity leadership roles (CSO, CPO) and describes their collective experience and expertise — this is about the people, not the program. Person-vs-function test: removing the roles and experience leaves no substantive content, confirming Management Role. Specificity is Firm-Specific: the CSO and CPO are cybersecurity-specific titles (IS list), and 'over 25 years' is a quantified fact, but only one QV-eligible hard fact (the years figure) exists — named roles don't count toward QV — so it falls short of Quantified-Verifiable.

thinking:
Let me analyze this paragraph from Booking Holdings' 10-K filing.

The paragraph is about the people in cybersecurity leadership roles - their responsibilities and experience. It describes who they are (chief security officer, chief privacy officer) and their qualifications (25+ years combined experience).

Person-vs-function test: The paragraph tells us about the persons' experience and expertise. It's about who they are, not what the program does.

Category: Management Role

Specific facts:
- "chief security officer" - cybersecurity-specific title → IS list
- "chief privacy officer" - cybersecurity-adjacent specific title → IS list

- "over 25 years of relevant work experience" is a quantified fact, but I need two QV-eligible items to classify this as QV. Since I only have one quantified metric and the named roles don't count toward QV eligibility, this falls into Firm-Specific rather than QV.

fact: chief security officer

fact: chief privacy officer

fact: over 25 years of relevant work experience collectively


reasoning: The board of directors and its Audit Committee are the grammatical subjects exercising oversight, receiving reports, and getting updates — classic Board Governance. Management roles (SRC Director, CIO) are mentioned as subordinate actors who report to the board. Two cybersecurity-specific titles (SRC Director, CIO) place this at Firm-Specific, but named roles do not count toward QV, and there are no other QV-eligible facts (no dates, amounts, named firms, or tools).

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

Content Category: The paragraph starts with "Board of Directors" and describes how the board exercises oversight through its Audit Committee. The board/Audit Committee is the grammatical subject performing the primary actions. While it mentions management roles (SRC Director, CIO), these are subordinate to the board oversight framing. → Board Governance

Specific facts:
- "Security, Risk and Compliance Director (SRC Director)" — this is a cybersecurity-specific title, firm-specific
- "Chief Information Officer" — CIO is on the IS list

- The Audit Committee itself is a standard governance structure, and terms like "regularly" and "periodic" are generic cadences that don't add specificity. The only concrete elements are the two named roles—the SRC Director and CIO—both of which are firm-specific titles, but named roles alone don't meet the quantitative value threshold. With no dates, dollar amounts, headcounts, or other measurable data points, this lands at Firm-Specific (3).

fact: Chief Information Officer


reasoning: The paragraph is primarily about organizational structure for cybersecurity risk management: the ERC's composition (named roles), reporting lines to Co-CEOs, the Enterprise Risk Officer's interactions with the CISO, and a board director's cybersecurity credentials. While ERM process content exists, the dominant purpose is identifying who manages cyber risk and their qualifications — fitting Management Role. Specificity is Quantified-Verifiable with multiple hard verifiable facts: CERT Certificate in Cybersecurity Oversight (named certification) and Carnegie Mellon University (named university in credential context) meet the two-fact QV threshold, with additional support from the named individual (Ms. Murray) and named external program (NACD Cyber-Risk Oversight Program).

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. ERM program design
2. Enterprise Risk Committee composition and oversight
3. ERC reporting structure
4. Enterprise Risk Officer's role and interactions
5. Cybersecurity as a risk under ERM
6. A board director's cybersecurity credentials

Let me determine the dominant category. The paragraph describes:
- The ERC committee (named members by role) overseeing ERM including cyber
- An Enterprise Risk Officer who meets with the CISO
- A board director (Ms. Murray) with cyber credentials

This is a mix of management/governance.

The ERC is a management committee overseeing the ERM program, with specific reporting lines and an Enterprise Risk Officer coordinating with the CISO, while the final sentence highlights a board director's cybersecurity expertise—so the core focus is on the management structure for risk oversight. I'm applying the person-versus-function test to confirm: if I strip away the titles and names, the core content is still about processes—risk identification, mitigation strategies, ERM oversight—but the paragraph's weight is clearly on organizational structure and who holds responsibility. The Enterprise Risk Committee composition, reporting lines to the Co-CEOs, the Enterprise Risk Officer's activities, and Ms. Murray's credentials dominate the text, so Management Role is the right categorization.

For the IS list specifics, I'm identifying the Enterprise Risk Committee as a named committee, the CISO and Enterprise Risk Officer as named roles, and Ms. Murray as a named individual.

On the other_specific items: the NACD Cyber-Risk Oversight Program and CERT Certificate in Cybersecurity Oversight are both named programs and certifications, while Carnegie Mellon University and the Software Engineering Institute are named institutions.

For QV-eligible facts, I have Carnegie Mellon University as a named university in a credential context, the CERT Certificate as a named certification, and Ms. Murray as a specific named individual—though I should verify whether named individuals actually qualify under the QV criteria, which typically focus on dates, dollar amounts, headcounts, percentages, and named third-party firms or products.

Looking at what's actually verifiable: the CERT Certificate and Carnegie Mellon University are solid QV-eligible facts, giving me at least 2 hard verifiable items. The NACD program could also count as a named program. For categorization, the paragraph's main focus is the ERC committee structure and composition, which falls under Board Governance, though there's also content about the Risk Management Process and management roles.

fact: Enterprise Risk Committee ("ERC") — named committee with unique identifier

fact: CISO mentioned as a cybersecurity-specific role

fact: AFG Enterprise Risk Officer — cybersecurity-adjacent named role

fact: Ms. Murray — named individual (independent Director)

fact: CERT Certificate in Cybersecurity Oversight — named certification

fact: Carnegie Mellon University — named university in credential context

fact: NACD Cyber-Risk Oversight Program — named external program

fact: Software Engineering Institute — named institution


reasoning: The paragraph describes internal cybersecurity processes — a TT&E program, incident response team training, tabletop exercises, and phishing simulations — making it Risk Management Process. The named internal program with a unique abbreviation ('TT&E') qualifies as a firm-specific fact per the IS list, and NIST SP 800-84 is a named framework, but neither counts toward QV (no dates, dollar amounts, headcounts, named firms, or named tools), so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes a Testing, Training, & Exercise (TT&E) program, NIST SP 800-84, IRT participation, tabletop exercises, phishing simulations. This is about internal cybersecurity processes.

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

Specificity analysis:
- "Testing, Training, & Exercise (TT&E) program" - named internal program with unique identifier/abbreviation → IS list ✓
- "NIST Special Publication 800-84" - named framework → triggers at least Sector-Adapted

- "IRT" (Incident Response Team) - generic team reference
- Tabletop exercises, phishing simulations - common practices, NOT list

The TT&E program is a named internal initiative with its own abbreviation, which qualifies as firm-specific. NIST SP 800-84 is a recognized framework but doesn't elevate the classification on its own. There are no quantifiable indicators like dates, financial figures, headcount, or named external tools, so this stays at the Firm-Specific level.

fact: NIST Special Publication 800-84


reasoning: This paragraph describes erroneous invoice payments and a material weakness in internal controls over financial reporting (cash disbursements). It contains no cybersecurity disclosure content — it is about accounting/financial controls, not cybersecurity risk management, incidents, or governance. None/Other always receives Generic Boilerplate.

thinking: This is about erroneous payments and internal control material weakness - not cybersecurity.


reasoning: The paragraph is a bulleted list describing the company's internal cybersecurity program components — risk assessments, security team, external providers, tools, training, incident response plan, and vendor risk management. All content is about processes and functions, not about any person's credentials or background. No named frameworks, tools, firms, dates, headcounts, or cybersecurity-specific titles appear; every item uses generic language ("a security team," "security tools," "cybersecurity awareness training") that could apply to any company.

thinking:
Let me analyze this paragraph from Bread Financial Holdings' 10-K filing.

Content: This is a bulleted list describing the company's cybersecurity risk management program components - risk assessments, security team, external service providers, security tools, training, incident response plan, and third-party risk management.

Category: This describes internal processes and program components. The person-vs-function test: it's about what the program does, not about any person. → Risk Management Process

Specificity: Let me check for specific facts:
- No named frameworks (NIST, ISO, etc.)
- No named roles (CISO, CIO, etc.) - just "a security team"

- No named tools, firms, dates, or numbers
- "external service providers" and "cybersecurity incident response plan" are generic program names
- "third-party risk management process" is also generic

Everything here is generic practices with no IS-list items or named standards. → Generic Boilerplate


reasoning: The paragraph opens with CIO credentials (20 years experience) but the dominant content is an extensive bulleted list of cybersecurity program processes: IRP implementation, incident response team management, risk assessment, security controls, post-incident reviews, training, and annual IRP review. Applying the person-vs-function test, removing the CIO's title and experience leaves a fully coherent process description — the paragraph is about the function, not the person. Specificity is Firm-Specific: CIO is a cybersecurity-specific title (one IS-list fact), and '20 years of experience' is one QV-eligible fact, but only one QV-eligible fact does not reach the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph starts by naming the CIO role and mentions "over 20 years of experience" - that's about the person. But then it goes into a detailed list of what the CIO does: implementing IRP, managing incident response team, coordinating activities, conducting post-incident reviews, providing training, reviewing the IRP.

Person-vs-function test: If I remove "Our CIO" and replace with "The Company," the paragraph still makes complete sense as a process description. The bulk of the content is about what the program/function does, not about who the person is.

The credentials are there, but they're just the opening hook. The real substance is the process enumeration, which dominates by volume. According to Rule 2b, this is Risk Management Process content with an incidental role attribution, not a Management Role paragraph.

For specificity, the CIO title is cybersecurity-specific and counts as firm-specific, and "over 20 years of experience" is a concrete number that qualifies for QV eligibility. The program names like IRP and IRT are generic though, so they don't add unique identifiers.

Looking at the QV rules more carefully, I need specific dates, dollar amounts, headcounts, percentages, named third-party firms, products, tools, or certifications. The years of experience does count as a QV-eligible fact, but that's just one—not enough to reach QV threshold. The CIO designation pushes this to Firm-Specific.

fact: Chief Information Officer (CIO) designated to implement and maintain the IRP

fact: CIO has over 20 years of experience in cybersecurity


reasoning: The CISO is the grammatical subject throughout, describing their reporting lines to the Technology Risk Management Committee, Audit Committee, Board, and CEO — this is about the role's communication structure rather than the person's credentials or the processes themselves. The Technology Risk Management Committee is a named non-generic committee (Firm-Specific), but no QV-eligible hard facts (dates, dollar amounts, named firms/tools, certifications) reach the two-fact threshold.

thinking:
Let me analyze this paragraph.

Content: The CISO provides updates to various groups. The primary actor is the CISO, describing what they report on and to whom.

Category: The CISO is the grammatical subject throughout. But what is the paragraph about? It's about the CISO's reporting/communication activities - who they report to and what topics they cover. This is about reporting lines and communication structure.

Person-vs-function test: The paragraph doesn't describe the person's credentials, background, or qualifications. It describes what the CISO does in terms of reporting. But it's also about board oversight (Audit Committee receives updates) and management oversight.

The CISO is clearly the grammatical subject performing the reporting action, which points toward Management Role. But I'm noticing the real substance here is the organizational structure itself—the reporting lines and oversight relationships around the CISO's role, not the individual's qualifications or background.

Looking at what qualifies as firm-specific: the CISO is a cybersecurity-specific title, and the Technology Risk Management Committee is a named committee rather than generic. The Audit Committee, Board, and CEO are all too generic to count. That gives me two IS facts, neither of which are QV-eligible, so this lands as Firm-Specific.

fact: CISO

fact: Technology Risk Management Committee


reasoning: The paragraph describes the company's internal cybersecurity risk management program and its integration with ERM, including risk assessments and governance processes. No named frameworks, specific roles, dates, or firm-specific facts are present — this language could apply to any company.


reasoning: The paragraph identifies the CSO role, describes its responsibilities, and notably includes the Executive Committee's evaluation of the CSO's expertise and knowledge — a qualitative assessment of the person's qualifications. While sentences 1-2 describe functions, sentence 3 shifts to a personnel-qualification judgment, making the overall purpose about establishing the CSO as a qualified person rather than describing program processes. CSO is a cybersecurity-specific title (one IS-list fact) but no second QV-eligible hard fact exists, so Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: About the CSO (Chief Security Officer) role - responsible for cyber and physical security, identifying/assessing/managing cyber risk. The Executive Committee evaluated the CSO's expertise.

Person vs function test: The paragraph mentions what the CSO is responsible for (functions), but also discusses the Executive Committee's evaluation of the CSO's expertise/knowledge. The primary content is about the CSO's responsibilities and their qualifications (expertise evaluation). It's a mix - but the dominant theme is about the role holder's responsibilities and qualifications assessment.

Actually, let me re-read. Three sentences:
1. CSO is responsible for cyber and physical security

2. CSO is responsible for identifying, assessing, managing cyber risk
3. Executive Committee evaluated expertise of CSO and determined it has necessary knowledge

Sentences 1-2 describe functions/responsibilities. Sentence 3 is about the person's qualifications (expertise evaluation). The person-vs-function test: if I remove the CSO title, the paragraph still describes responsibilities and an expertise evaluation. But the expertise evaluation is about the person.

This is borderline. The paragraph is mostly about what the CSO does (function), but the third sentence evaluates the person's expertise. I'd lean Management Role because the expertise evaluation is a significant part and it's about the person's qualifications.

The paragraph establishes both the CSO's responsibilities and confirms their qualifications through an Executive Committee assessment, so this leans toward Management Role. For specificity, the CSO title is cybersecurity-specific, making this Firm-Specific, and there are no dates, amounts, or named entities beyond that—just one identifying fact, so it's not QV.

fact: CSO (Chief Security Officer) — cybersecurity-specific title


reasoning: The paragraph describes what management does regarding cybersecurity — hiring, integrating risk into ERM, approving budgets, preparing for incidents, reviewing assessments. Applying the person-vs-function test: removing the CEO/CFO titles, the paragraph still describes organizational processes and activities, making it Risk Management Process rather than Management Role. No cybersecurity-specific titles (CISO, CIO, CTO), no named frameworks, no firm-specific facts — CEO and CFO are generic C-suite roles on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes management's role in cybersecurity - CEO, CFO, executive team responsibilities including hiring, budgets, incident prep, process approval, reviewing assessments. The Board is mentioned briefly ("at the direction of our Board of Directors") but the primary actors are management/executive team.

Category: This is about what management does (functions/processes) rather than about who the people are (credentials, background). The CEO and CFO are mentioned but these are generic C-suite titles, not cybersecurity-specific roles. The paragraph describes functions: hiring, integrating risk, communicating priorities, approving budgets, preparing for incidents, reviewing assessments.

The person-vs-function test is helping me see this more clearly. Even though the paragraph names specific roles like CEO and CFO, removing those titles doesn't change the core content—it's still describing a set of activities and responsibilities. The focus is on what these positions do: hiring personnel, weaving cybersecurity into enterprise risk management, setting priorities, allocating budgets, preparing incident response plans, approving processes, and reviewing assessments. These are all operational functions, which points toward Risk Management Process rather than organizational structure.

Looking at the specificity markers, though, the language is quite generic. The references to "C-suite," "information technology team," and "Board of Directors" lack any concrete detail or named frameworks. There are no cybersecurity-specific titles like CISO or CTO, and nothing that ties to the actual IS list. This generality suggests Generic Boilerplate.


reasoning: The paragraph describes what the management team does — supervising prevention, detection, mitigation, and remediation activities, gathering threat intelligence, and using security tools. Applying the person-vs-function test, replacing 'Our management team' with 'the Company' leaves the paragraph fully intact as a process description; no credentials, background, or qualifications are mentioned. All entities are generic ('internal security personnel,' 'external consultants,' 'security tools') with no named frameworks, tools, firms, dates, or numbers.

thinking:
Let me analyze this paragraph.

Content: Management team supervises cybersecurity efforts, provides briefings from various sources including internal security personnel, threat intelligence, external consultants, and security tools.

Category: This is about what management does - supervising cybersecurity efforts. The grammatical subject is "Our management team." But is this about the person or the function? It's about what management does (prevent, detect, mitigate, remediate) - the function. There are no qualifications, credentials, or background mentioned. Using the person-vs-function test: remove "Our management team supervises" and you get a description of cybersecurity activities.

I'm reconsidering whether this fits Risk Management Process. The paragraph describes management's oversight role in supervising prevention, detection, mitigation, and remediation efforts, along with providing briefings from multiple sources. Applying the person-vs-function test, if I swap "Our management team" with "the Company," the description still works as a process—"The Company supervises efforts to prevent, detect, mitigate..." This confirms it's describing a function rather than individual qualifications, so this belongs in Risk Management Process. The paragraph lacks any named frameworks or specific methodologies.


reasoning: The paragraph's primary content is about the CISO as a person — their experience (25+ years), when they joined (January 2025), reporting lines (to CTO, who reports to CEO), and the leadership transition following the prior CISO's departure in October 2024. While the Audit Committee is mentioned and the final sentence touches on IR responsibilities, the dominant communicative purpose is identifying and qualifying the management role holder(s). Three QV-eligible hard facts (25 years of experience, January 2025 join date, October 2024 departure date) reach the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph carefully.

This is a rich paragraph that covers multiple categories. Let me apply the decision rules.

The paragraph covers:
1. Audit Committee oversight (Board Governance)
2. CISO qualifications, experience, reporting lines (Management Role)
3. CISO's responsibilities for incident response (Risk Management Process)

The dominant content: The paragraph starts with one sentence about Audit Committee oversight, then spends most of its text on the CISO — their experience (25 years), when they joined (January 2025), reporting lines (to CTO, who reports to CEO), the interim CISO situation, the previous CISO's departure (October 2024), and briefing cadence. The last sentence mentions the CISO and team's responsibilities.

The person-versus-function test is telling me this is primarily about the individual in the role rather than the function itself. The bulk of the content focuses on who the CISO is—their background, tenure, and the organizational transition—with only a brief mention of their actual responsibilities at the end. That makes this a Management Role category, with the CISO as the central subject. I'm noting the specific facts: CISO and CTO are both named roles, and the 25 years of experience is a quantified credential.

Looking at what qualifies for verification, I've got three facts that meet the threshold: the 25 years of experience, the January 2025 date, and the October 2024 date. That puts this in the Quantified-Verifiable category.

fact: Chief Technology Officer (CTO)

fact: over 25 years of experience

fact: joined the Company in January 2025

fact: departure of our then current CISO in October 2024


reasoning: The paragraph's primary communicative purpose is describing how the board and Audit Committee receive cybersecurity updates from management (COO), making the board/committee the recipient-subject of the oversight structure. The COO is mentioned as the person reporting TO the board, which per Rule 2 keeps this as Board Governance. COO is on the NOT list (generic C-suite), and 'Audit Committee' is generic governance, but 'beginning in 2024' is a specific date qualifying as a firm-specific fact.

thinking:
Let me analyze this paragraph carefully.

The paragraph discusses board-level oversight of cybersecurity - the board and audit committee receive updates from management (COO). The primary actors receiving updates are the board and audit committee. The COO is mentioned as the person providing updates, but the frame is about the governance structure - who gets briefed and how.

Content Category: This is about board/committee oversight. The board and audit committee are receiving updates on cybersecurity. The COO is mentioned but as the person reporting TO the board. Per Rule 2: "Board delegates responsibility to management → Board Governance" and the overall frame is about the board's oversight structure. → Board Governance

Now I'm checking what counts as a specific fact. The COO and audit committee are generic governance roles, so they don't qualify, but "beginning in 2024" is a concrete date that makes this firm-specific. Since I have at least one verifiable fact, this falls into the Firm-Specific category.

fact: beginning in 2024


reasoning: The paragraph contains an explicit materiality assessment ('We have not currently encountered any cybersecurity threats that have materially impaired our operations or financial standing'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. No firm-specific facts from the IS list are present — the named risk factor title is filing metadata, not a cybersecurity-specific fact.

thinking:
Let me analyze this paragraph.

It contains a cross-reference to Risk Factors AND a materiality assessment ("We have not currently encountered any cybersecurity threats that have materially impaired our operations or financial standing"). Per Rule 6 and the codebook, a materiality assessment makes this Strategy Integration even with the cross-reference.

Specificity: The paragraph contains boilerplate materiality language. No named frameworks, no firm-specific facts from the IS list. The cross-reference names a specific risk factor title, but that's a company self-reference/filing metadata. → Generic Boilerplate.


specificity_confidence: medium

reasoning: This multi-topic paragraph covers management direction (CFO), board reporting, Audit Committee updates, a materiality statement, and a cross-reference. Board Governance is dominant because the board/Audit Committee oversight structure occupies the most text (incidents reported to the board, no designated cyber committee, Audit Committee receives periodic updates). The CFO mention is brief and CFO is generic C-suite per the NOT list. The materiality statement ('no material incidents in 2024') is secondary to the governance framing. Specificity is Firm-Specific based on the specific year reference '2024'; all other elements (Board of Directors, Audit Committee, CFO, 'periodic updates') are on the NOT list.

thinking:
Let me analyze this paragraph carefully.

This is a multi-topic paragraph from a small company (Thunder Mountain Gold). Let me break down the content:

1. "Our cybersecurity programs are under the direction of our CFO with assistance from the management team." - Management Role (CFO directing cyber)
2. "Any significant Cyber incidents that they become aware of are reported to the board of directors." - Board Governance (reporting to board)
3. "The Board of Directors does not have a designated cybersecurity committee, but the Audit Committee receives periodic updates on cybersecurity matters." - Board Governance

4. "The Company has not experienced any material cybersecurity incidents to date and there were no material cybersecurity incidents discovered in 2024." - Strategy Integration (materiality assessment)
5. "Please refer to Item 1A: Risk Factors for further insights into cyber attack-related risks." - Cross-reference

Looking at the distribution, Board Governance dominates with two sentences about incident reporting and the Audit Committee's role. Management Role covers the CFO's oversight, while the materiality statement and cross-reference are secondary points. The paragraph's primary focus is on how governance structures handle cybersecurity matters. The board and Audit Committee oversight dominates the paragraph, so Board Governance is the right classification. Looking at specificity, most elements are generic—CFO, Board of Directors, Audit Committee, periodic updates—but the reference to 2024 as a specific year where no material incidents occurred does count as a firm-specific fact, landing this at Firm-Specific (3). I'm settling on Board Governance as the dominant category since the oversight structure and management reporting take up most of the space, even though the materiality assessment about no incidents in 2024 could push toward Strategy Integration. For specificity, I'm questioning whether just mentioning "2024" as a year really qualifies as firm-specific or if it needs more granular detail like a specific month to count as one fact. I need the next thinking to rewrite. You've provided my current rewritten thinking and the guidelines, but I don't see the "next thinking" content that I should be rewriting.

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


reasoning: The paragraph names the CISO and ISD but its substantive content describes what the division does: threat intelligence, incident response, monitoring, severity-based classification, escalation processes, and third-party arrangements. Applying the person-vs-function test, removing the CISO attribution leaves a complete process description — this is about the function, not the person. Two IS-list facts (CISO as cybersecurity-specific title, ISD as a named internal program with unique identifier) support Firm-Specific, but no two QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools) are present to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes BNY Mellon's Information Security Division (ISD), led by the CISO, and what the division does - cyber threat intelligence, incident response, monitoring, incident classification, escalation processes, and third-party arrangements.

Category: The paragraph names the CISO and ISD but then extensively describes what the division DOES - processes, monitoring, incident response, classification, escalation. Applying the person-vs-function test: remove "led by the CISO" and the paragraph still makes complete sense as a process description. This is Risk Management Process.

Now I'm checking the specificity level. The CISO is a cybersecurity-specific title that qualifies, and ISD is a named internal division with a unique identifier. There are no named frameworks, specific dates, dollar amounts, headcounts, or third-party firms mentioned. Since we have the CISO and the named internal program ISD, this lands at Firm-Specific level 3.

fact: Chief Information Security Officer (CISO)

fact: Information Security Division ("ISD") — named internal program with unique abbreviation


reasoning: The paragraph describes the company's internal cybersecurity risk management program — ERM integration, threat assessment framework, training, vulnerability assessments, network monitoring, and use of third-party assessors. Third parties and insurance are mentioned as components of the internal program, not as central topics. No named frameworks, tools, firms, roles, dates, or quantified facts appear; all language is generic and interchangeable across companies.

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity risk management program - ERM integration, framework for handling threats, third-party services mentioned as component, training, assessments, monitoring, third-party assessors, insurance.

Category: Risk Management Process - this is about the company's internal processes. Third parties are mentioned as components, not the central topic. Insurance is mentioned briefly but the dominant content is process description.

Specificity: Let me check for specific facts:
- No named frameworks (NIST, ISO, etc.)
- No named roles (just "management" and "Board" which are generic)

- No named tools, firms, dates, or numbers
- References to "cybersecurity assessors and consultants" and "industry-standard cybersecurity insurance" lack any concrete details
- Everything relies on common practices like security awareness training, vulnerability assessments, and network monitoring

This is entirely generic boilerplate with no substantive specifics or named standards.


reasoning: The paragraph describes the company's own internal cybersecurity measures and processes (incident response plan, risk assessments, vulnerability management, encryption, access controls, employee training, etc.), making it squarely Risk Management Process. Every item listed is a common practice from the ✗ NOT list or generic boilerplate language; no named frameworks, tools, firms, roles, dates, or quantified facts are present.

thinking:
Classify this paragraph.

Content: Describes the company's internal cybersecurity measures - technical, physical, organizational. Lists many practices: incident response plan, risk assessments, vulnerability management, encryption, etc.

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

Specificity: Let me check for specific facts.
- No named frameworks (NIST, ISO, etc.)
- No named roles (CISO, etc.)
- No dates, dollar amounts, headcounts
- No named tools or firms
- All items listed are common practices (incident response plan, risk assessments, vulnerability management, encryption, etc.)

- Cybersecurity insurance is mentioned but without any details

This reads as generic boilerplate that could describe almost any organization's security posture.


reasoning: The paragraph's primary substantive content is an explicit materiality assessment ('no risks from identified cybersecurity threats... have materially affected... the Company, including our business strategy, results of operations, or financial condition'), which per Rule 6 is Strategy Integration even though it is boilerplate. The surrounding language about evolving threats and the trailing cross-reference to Risk Factors do not override the materiality conclusion. No specific facts from the IS list are present — all language is generic and interchangeable across filings.

thinking:
Let me analyze this paragraph.

Content: It starts with acknowledging cybersecurity incidents, then makes a materiality assessment ("no risks from identified cybersecurity threats... have materially affected... the Company, including our business strategy, results of operations, or financial condition"), then discusses forward-looking uncertainty, and ends with a cross-reference.

Category: The materiality assessment is the core substantive content. Per Rule 6, materiality disclaimers → Strategy Integration. The cross-reference at the end doesn't change this.

Specificity: No named frameworks, no specific facts from the IS list, no dates beyond "through the date hereof" which is generic.

This is just standard boilerplate materiality language without any substantive detail.


reasoning: The paragraph's primary communicative purpose is a materiality assessment — management concludes that cybersecurity risks are not reasonably likely to materially affect business strategy, results of operations, or financial condition, and confirms no material incidents occurred. Per Rule 6, materiality disclaimers are Strategy Integration. Specific fiscal years (2025, 2026) are firm-specific date references; however, they form a single temporal range within one clause rather than two independently verifiable hard facts, so this stays at Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Management evaluates cybersecurity risks, makes a materiality assessment, and states no material incidents. The primary communicative purpose is the materiality disclaimer - "does not believe there are currently any known risks from cybersecurity threats that are reasonably likely to materially affect us or our business strategy, results of operations, or financial condition." Plus "we have not had a material cybersecurity incidents in fiscal 2025 or 2026."

Category: Strategy Integration (materiality assessment per Rule 6)

Specificity: Let me check for facts.

I'm identifying the specific dates mentioned - "fiscal 2025" and "fiscal 2026" both qualify as specific temporal references per the IS list. However, the phrase "fiscal 2025 or 2026 through the date of filing" functions as a single timeframe rather than two separate facts, so this likely counts as one QV-eligible temporal reference rather than two distinct facts.

fact: fiscal 2025

fact: fiscal 2026 through the date of filing


reasoning: Per Rule 2, the Executive Officer and VP of Technology are the grammatical subjects providing briefings to the Board, making management the primary actor ('Management role reports TO the board → Management Role'). However, neither 'Executive Officer' nor 'Vice President of Technology' qualifies as a cybersecurity-specific title per the IS list — they fall under generic C-suite/IT leadership on the NOT list. 'Periodic' is a generic cadence, 'Board of Directors' is standard governance. No named frameworks, dates, or firm-specific facts remain after validation.

thinking:
Let me analyze this paragraph.

The paragraph describes briefings to the Board from Executive Officer and VP of Technology. The board is receiving briefings, but the grammatical subjects performing the action are the Executive Officer and VP of Technology. However, the purpose is about informing the board - this is about board oversight through briefings.

Wait - let me re-read. "Executive Officer and Vice President of Technology provide periodic briefings to the Board of Directors regarding..." - The management roles are the grammatical subjects, but the content is about briefing the board. This is a borderline Board Governance vs Management Role case.

Now I'm applying the tiebreaker rules. The core action here is management providing briefings to the board about incidents, testing, and third-party activities - this is fundamentally about the board's oversight mechanism. Even though management is performing the briefing action, the substance is about how the board stays informed. Rule 2 suggests that when management reports to the board, it's a Management Role, but the emphasis on what the board receives and how it maintains oversight pushes this toward Board Governance. I'm applying Rule 2 to determine the category: since the Executive Officer and VP of Technology are the grammatical subjects reporting to the board, this fits the "Management role reports TO the board" pattern, making it Management Role. But I'm second-guessing myself because the focus seems to be on the briefing process itself rather than the individuals—though the person-vs-function test applies to Management Role versus Risk Management Process, not Board Governance, so that distinction doesn't help here.

Looking at the examples, "CISO reports quarterly to the Board" is clearly Management Role because the management role is the subject providing briefings. The VP of Technology is similar to "VP of IT" on the specific facts list, so I'll count it as firm-specific rather than generic C-suite. "Periodic briefings" is generic language, but the specificity of the roles and the clear reporting structure to the board points toward Management Role. technology role, not cybersecurity-specific. "Executive Officer" is also too generic. After filtering out these non-specific titles, there are no concrete facts left—just descriptions of briefing topics. This lands it in Generic Boilerplate with a specificity score of 1. The paragraph describes a governance mechanism where management briefs the board, which makes it a Management Role category.


reasoning: The paragraph describes the company's internal cybersecurity risk management program including risk assessments, preventative/detective controls, and protection of information systems — all core Risk Management Process topics. No named frameworks, tools, roles, dates, or any other specific facts appear; every phrase ('periodic risk assessments,' 'preventative and detective security controls,' 'confidentiality, integrity, and availability') is generic boilerplate usable by any company.

thinking:
Classify this paragraph.

Content: Describes the company's cybersecurity risk management program - risk assessments, controls, protection measures. This is about internal processes.

Category: Risk Management Process

Specificity: No named frameworks, no named roles, no specific dates, no named tools. "Periodic risk assessments", "preventative and detective security controls" - all generic. No IS-list items.

→ Generic Boilerplate (1)


reasoning: The Audit Committee is the grammatical subject and primary actor throughout the paragraph, making this Board Governance. It describes the committee's oversight role, reporting to the Board, and receiving briefings — all board-level oversight activities. For specificity, the paragraph contains a cybersecurity-specific role (CISO), a specific date (2023), and a specific meeting count (four times); the date and meeting count are two hard verifiable facts, reaching the QV threshold, though the meeting count as a QV-eligible fact is borderline since it is not a headcount, dollar amount, or percentage in the strict sense.

thinking:
Let me analyze this paragraph.

Content: Audit Committee oversight, reviews cybersecurity risks, information security team performs annual risk assessment, presents to management and Audit Committee, Audit Committee reports to Board, in 2023 CISO met with Audit Committee four times.

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

Specific facts:
- CISO (cybersecurity-specific role) → named_role
- "In 2023" → specific_date
- "four times" → quantified (specific number of meetings)

- "four times" is a specific number but doesn't fit the QV-eligible categories like headcount, dollar amount, or percentage, so it doesn't qualify as a hard verifiable fact on its own. However, the specific date "In 2023" does count → Quantified-Verifiable with one qualifying element.

Actually, wait—I need to be more careful about what counts as a specific date for QV purposes. The guidelines say "month+year or exact date," but "2023" is just a year. That might not meet the threshold, even though "fiscal 2025" appears in calibration examples. Let me reconsider whether this claim has any QV-eligible facts at all. I need to reconsider what counts as QV-eligible. "Four times" is a specific number, but the QV criteria are pretty narrow—dollar amounts, headcounts, percentages, and similar metrics. Meeting frequency doesn't fit those categories, so it probably doesn't qualify. That leaves just "In 2023" as a hard verifiable fact, which combined with the CISO role from the IS list points toward a Firm-Specific classification.

fact: four times (CISO/team met with Audit Committee)


reasoning: The paragraph describes the company's internal cybersecurity tools and monitoring capabilities (endpoint security, SIEM, PAM, SOC), which are core risk management process activities. The third-party SOC is mentioned as a component of the internal program, not as vendor oversight. Despite mentioning several technology categories (SIEM, PAM, SOC), these are generic acronyms for common technology classes, not named products or vendors. No named frameworks, no named tools/products, no named firms, no specific dates or numbers — all items are generic security practices describable at any institution.

thinking:
Let me analyze this paragraph.

Content: Describes tools and processes - endpoint security, SIEM, PAM, email/web filtering, user analytics, third-party SOC. This is about the company's internal cybersecurity processes and tools.

The third-party SOC is mentioned as a component of their internal program, not as vendor oversight being the central topic.

Category: Risk Management Process

Specificity: Let me check for specific facts.
- "SIEM" - generic acronym, not a named product
- "PAM" - generic acronym
- "SOC" - generic

- "best of breed tools" - generic phrase
- "24-by-7 Security Operations Center" - standard practice description
- No named products, vendors, dates, dollar amounts, headcounts, or frameworks mentioned
- No cybersecurity-specific titles referenced

The paragraph describes general tool categories and common security practices without naming any specific products, vendors, or standards, making this generic boilerplate.


reasoning: The paragraph describes what the Enterprise Risk program does — providing frameworks, conducting risk assessments, coordinating with Internal Audit and Compliance. The CRO and CISO are mentioned as attribution for who runs these processes, but the substantive content is about the function (risk identification, assessment, monitoring, assurance activities), not the persons' qualifications or backgrounds. CISO is a cybersecurity-specific title triggering Firm-Specific, but there are no QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: Describes the CRO leading the Enterprise Risk program, coordinating with CISO, the Enterprise Risk team's activities, risk assessments, coordination with Internal Audit and Compliance.

Category: This is about what the program DOES - risk assessments, framework, tools, monitoring, coordination. The CRO and CISO are mentioned as attribution. Apply person-vs-function test: remove the titles and the paragraph still describes processes. → Risk Management Process.

Specificity:
- CRO: Chief Risk Officer - not on the cybersecurity-specific titles list (CISO, CTO, CIO, VP of IT/Security...).

The CRO is a generic C-suite role, while the CISO is on my cybersecurity-specific list, making that a firm-specific fact. The Enterprise Risk program lacks any unique identifier, and Internal Audit and Compliance are standard governance functions. With only one fact tied to a specific title and no quantifiable details like dates, amounts, or named tools, this falls into Firm-Specific (3).


reasoning: The paragraph describes internal governance processes — the Information Security team reviewing/updating governance documents, maintaining a strategic plan, and presenting to the Audit & Risk Committee. The primary actors are the Information Security team and CISO performing process functions; the committee is in a receiving/approval role, not the primary subject. Applying the person-vs-function test, the CISO is mentioned as attribution for approvals and progress reports, not for credentials or background. Multiple firm-specific facts (named governance documents, Audit & Risk Committee, CISO, named strategic plan) but no two QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: Describes the Information Security team's governance document review process, strategic planning, and reporting. The primary actors are the Information Security team and CISO, with the Audit & Risk Committee receiving documents for approval.

Category: This is about internal processes - governance document reviews, strategic planning, updates. The CISO is mentioned but as attribution for approving/reporting, not about the person's credentials. The Audit & Risk Committee is mentioned but in a receiving role. The primary content is about the processes (document reviews, strategic plan maintenance). → Risk Management Process

I'm reconsidering whether the Audit & Risk Committee's role elevates this to Board Governance, but the Information Security team remains the primary actor here—they're the ones reviewing and updating documents, while the committee is positioned to receive and approve rather than drive the action. The named documents like the Information Security Charter, Policy, and Program Plan are specific internal governance artifacts, which reinforces this as a Risk Management Process category.

Looking at the specificity markers: I have the named committee, the CISO title, and a three-year timeframe, but no hard verifiable facts like dates, financial figures, headcounts, third-party vendors, products, or certifications. That puts this solidly at Firm-Specific (3).

fact: Information Security Charter, Information Security Policy, and Information Security Program Plan (named governance documents)

fact: Audit & Risk Committee (non-generic named committee)

fact: Formal cybersecurity strategic three-year plan


reasoning: The Audit and Examination Committee (a board committee) is the grammatical subject of the opening clause and the paragraph frames its oversight role, making Board Governance dominant. The Information Security Officer's quarterly reporting is described in service of the committee's oversight function. The non-generic committee name and cybersecurity-specific role title are both IS-list facts, but neither qualifies as QV-eligible (no dates, dollar amounts, named firms, or tools), so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: The Audit and Examination Committee oversees cybersecurity risk management. The Information Security Officer provides quarterly reports to the committee. Reports may be more frequent for significant issues.

Category: The grammatical subject of the first sentence is "The Audit and Examination Committee" - a board committee. The second sentence has "Our Information Security Officer" as subject, but it's describing reporting TO the committee. The frame is board oversight. → Board Governance

Specific facts:
- "Audit and Examination Committee" - this is a named non-generic committee (not just "Audit Committee") → IS list

- "Information Security Officer" - cybersecurity-specific title → IS list
- "quarterly reports" - generic cadence, NOT list

I've identified two IS-list facts here: the named committee and the cybersecurity-specific officer role. Neither qualifies for QV since there are no dates, dollar amounts, headcounts, or named third parties. With at least one IS fact present, this falls into Firm-Specific.

fact: Audit and Examination Committee (non-generic committee name)

fact: Information Security Officer


reasoning: The paragraph centers on the VP of IT as the person responsible for cybersecurity monitoring and reporting, describing why this individual can serve as the 'central point person' given the company's limited IT footprint. While it touches on functions, the primary communicative purpose is establishing who holds cybersecurity responsibility and the management structure, not describing specific processes or tools. VP of Information Technology is a cybersecurity-specific title on the IS list, yielding Firm-Specific; no second QV-eligible fact is present.

thinking:
Let me analyze this paragraph.

Content: Describes the VP of IT's role in monitoring cybersecurity threats, notes the company's IT landscape is small, and states the VP of IT is the central point person.

Category: This is about management's role - the VP of IT is the grammatical subject/focus. But let me apply the person-vs-function test. The paragraph describes what the VP of IT does (monitors prevention, detection, mitigation, remediation) and why they can do it (small IT landscape). It's about the function/role structure rather than the person's credentials/background. However, the primary framing is about who is responsible - the VP of IT as the central point person.

There's no process detail here—no frameworks, tools, or methodologies mentioned. This is purely about the management structure and who owns cybersecurity oversight. The VP of IT isn't described by their background or expertise, but by their organizational position and capacity to handle this responsibility given the company's small IT footprint. So this falls under Management Role.

Now I'm checking whether "VP of IT" qualifies as firm-specific. The IS list includes "VP of IT/Security," so yes—that's a firm-specific title. There are no QV-eligible facts like dates, dollar amounts, headcounts, named firms, or certifications here, so this is Firm-Specific.

fact: Vice President of Information Technology


reasoning: The paragraph names the CIO as the person implementing cybersecurity processes and provides their experience (15 years) and reporting structure. Applying the person-vs-function test: removing the CIO's title, experience, and reporting line leaves only a shell sentence ('processes are implemented by certain members of management'), so the paragraph is primarily about the person, not the function. One QV-eligible fact (15 years of experience) plus a cybersecurity-specific role (CIO) yields Firm-Specific; two QV-eligible hard facts are not met since named roles don't count toward the QV threshold.

thinking:
Let me analyze this paragraph.

The paragraph mentions the CIO (cybersecurity-specific role) and describes their experience (15 years) and reporting structure. But let me apply the person-vs-function test.

The paragraph starts with "cybersecurity risk assessment and management processes are implemented and maintained by certain members of our management, including our CIO" - this is about who implements the processes. Then it describes the CIO's experience and reporting line.

The primary content is about the person - their experience (15 years) and reporting structure. The processes are mentioned as context but not described in detail. This is more about Management Role.

Now I'm checking which facts qualify as QV-eligible. The CIO role itself isn't QV-eligible since named roles don't count, but "over 15 years of experience" does qualify as a specific number of years. That gives me just one QV-eligible fact from this paragraph.

With only one QV fact and at least one IS fact present (the CIO title and experience), this falls into Firm-Specific territory. For the category, I'm applying the person-versus-function test: if I strip away the CIO's title, experience, and reporting structure, there's almost nothing substantive left about the actual cybersecurity processes themselves. The paragraph is fundamentally about the person and their role, so this is a Management Role classification.

fact: CIO (cybersecurity-specific role)

fact: over 15 years of experience in IT management


content_category: Third-Party Risk

reasoning: The paragraph's central topic is oversight of third-party service providers connected to the company's networks — obtaining SOC-1 reports, reviewing them via Internal Audit, and limiting vendor access based on service nature. This is vendor oversight as the primary subject, not a component of an internal process description. The VP of Information Technology (matching 'VP of IT' on the IS list) provides a firm-specific fact, and the SOC-1 Report names a recognized standard; however, only one IS-list fact (the VP role) is present and no QV-eligible hard facts reach the two-fact threshold, so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: VP of IT oversees third-party service providers connected to networks. Company obtains SOC-1 Reports, reviewed by Internal Audit. Company limits access based on nature of services.

Category: The central topic is oversight of third-party service providers - vendor risk management. This is Third-Party Risk.

Specificity:
- "Vice President of Information Technology" - this is a generic IT title, not cybersecurity-specific per the IS list. "VP of IT/Security" is on the IS list, but "VP of Information Technology" is more of a general IT title.

Now I'm reconsidering whether "VP of Information Technology" aligns with "VP of IT" from the IS list. The list includes "CISO, CTO, CIO, VP of IT/Security, Information Security Officer, Director of IT Security..." so "VP of IT" could reasonably encompass this role → Firm-Specific. SOC-1 Reports are a named standard, making that Sector-Adapted, while Internal Audit is just a generic department name. "Vice President of Information Technology" maps to "VP of IT" on the IS list, so that's firm-specific. SOC-1 is a named standard making it sector-adapted, but the firm-specific role pushes the overall classification to firm-specific level 3. For QV eligibility, I don't have the hard verifiable facts needed—no dates, amounts, or named entities—so this falls under Third-Party Risk without QV qualification.

fact: Vice President of Information Technology oversees third-party service providers

fact: SOC-1 Report (Report on Controls at a Service Organization)


content_category: Incident Disclosure

reasoning: The paragraph describes an actual cybersecurity incident—ransomware attack with unauthorized encryption and malware deployment—including timeline, response actions, and outcome. The closing materiality sentence is subordinate to the incident narrative. One QV-eligible hard fact (specific date) yields Firm-Specific; terms like 'ransomware,' 'manual processes,' and 'no payments' are descriptive but not independently verifiable named entities or quantities meeting the QV threshold.

thinking:
Classify this paragraph.

Content: Describes a specific cybersecurity incident - date, what happened (ransomware, encryption, malware), response (manual processes), outcome (no payments, no material impact).

Category: Incident Disclosure - describes what happened in an actual incident. The last sentence includes a materiality note, but the dominant content is the incident narrative.

Specificity:
- Specific date: "June 28, 2023" ✓ (QV-eligible)
- No named firms, tools, or other QV-eligible facts
- Only one QV-eligible hard fact → Firm-Specific (3)


reasoning: The paragraph describes the company's internal escalation process during a cybersecurity incident — management reports to the Audit Committee and Board per protocols and the incident response plan. This is about the function (escalation procedures), not about who the person is (no credentials, background, or named cybersecurity role), so the person-vs-function test points to Risk Management Process. All elements are generic: 'management' is not a cybersecurity-specific title, 'Audit Committee' is standard, 'incident response plan' is a generic program name, and the scenario is hypothetical ('In the event of').

thinking:
Classify this paragraph.

The paragraph describes what management will do "in the event of" a material incident - reporting to Audit Committee and Board per escalation protocols and incident response plan.

Category: This is about escalation/reporting protocols. The primary actor is "management" reporting to the Board/Audit Committee. It's describing an incident response process - what happens when an incident occurs. This is forward-looking/hypothetical ("In the event of"). It describes the company's internal process for escalation. This feels like Risk Management Process (incident response planning/escalation protocols) or Board Governance (reporting to board).

The grammatical subject is "management" - they report to the Audit Committee and Board.

The content focuses on incident response escalation protocols rather than management's qualifications or role definition. This is fundamentally about the process itself - what triggers, who gets notified, and how information flows during an incident. The lack of specific frameworks or cybersecurity terminology, combined with the generic references to "management" and "Audit Committee," suggests this is describing a standard Risk Management Process for incident escalation.


reasoning: The paragraph's primary content is about the people who lead cybersecurity processes — their roles, qualifications, and years of experience — making it Management Role under the person-vs-function test. While CFO, General Counsel, and Head of IT are generic titles (NOT list), the three specific experience durations (10 years, 10 years, 30 years) are quantified facts, and the Information Technology Steering Committee is a named non-generic committee. Three QV-eligible quantified durations exceed the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes who leads cybersecurity risk management processes - CFO, General Counsel, and Head of IT - and then details their qualifications/experience. It also mentions an IT Steering Committee.

Person-vs-function test: The paragraph briefly mentions processes "discussed in greater detail above" but the bulk of the content is about the people - their roles, experience, and qualifications. This is about the persons, not the function.

Content category: Management Role

Specific facts:
- Head of Information Technology (cybersecurity-specific? Let me check... "Head of IT" is listed under "✗ IS NOT" as generic IT leadership.

Now I'm cross-referencing against the IS and NOT lists. The IS list specifies "Director of IT Security, HSE Director overseeing cybersecurity" while the NOT list flags "Head of IT", "IT Manager", "Director of IT", and "Chief Compliance Officer" as generic titles. So the CFO and General Counsel are both generic C-suite roles per the NOT list, but the Information Technology Steering Committee is a named non-generic committee similar to what appears on the IS list. I'm also noting the specific experience metrics: over 10 years for both the CFO and General Counsel, and over 30 years for the Head of IT.

Actually, I need to reconsider whether years of experience count as QV-eligible facts. Looking back at the calibration example where "The CISO has 17 years of experience and holds CISSP and CISM certifications" was treated as containing QV-eligible information, it seems quantified experience durations do qualify.

So I have three quantified facts here: over 10 years for the CFO, over 10 years for the General Counsel, and over 30 years for the Head of IT. That's three quantified durations, which exceeds the two-or-more threshold for Quantified-Verifiable classification.

The roles themselves being on the NOT list doesn't negate the fact that the experience durations are independently quantifiable facts. I also have the Information Technology Steering Committee as a named committee. With three quantified experience durations, this should classify as Quantified-Verifiable.

fact: CFO has over 10 years of experience leading IT departments

fact: General Counsel has over 10 years of experience related to legal/IT matters

fact: Head of IT has over 30 years of relevant experience


reasoning: The paragraph spans Board Governance (Risk Committee oversight, reporting cadence) and Management Role (CISO qualifications, credentials, reporting line), but the Management Role content occupies more text and provides the most distinctive detail — the CISO's 20+ years of experience, MBA, four named certifications (CISSP, CISM, GLAW, GSEC), and reporting structure. The person-vs-function test confirms: the CISO content is about who the person is, not what the program does. QV is reached via specific years of experience plus multiple named certifications (2+ hard verifiable facts).

thinking:
This is a complex paragraph that spans multiple categories. Let me analyze it.

The paragraph covers:
1. Board/Risk Committee oversight (Board Governance)
2. CISO qualifications, experience, certifications (Management Role)
3. Some process elements (reports about prevention, detection, etc.)

Let me apply the dominant category rule. The paragraph starts with board oversight via Risk Committee, then transitions to management roles (CRO, CISO), and spends significant text on the CISO's qualifications (20+ years, MBA, CISSP, CISM, GLAW, GSEC).

This is a tough call between Board Governance and Management Role.

Looking at the text allocation, the opening frames this around board oversight through the Risk Committee, but the bulk of the content focuses on the CISO's credentials and qualifications. The paragraph title "Cybersecurity Risk Oversight" suggests a governance angle, yet the substance is really about who's managing the function and what they bring to the role. I'm leaning toward Management Role as the primary category since the CISO's qualifications and experience dominate the discussion. I'm weighing whether the dominant category here is Management Role or Board Governance. The CISO's qualifications and experience take up more text, but board oversight is also substantial. Looking at the actual content distribution, Management Role wins out—the credentials, background, and reporting structure are what really define this section, even though governance is mentioned as context.

Now I'm checking which facts are actually verifiable. The specific certifications like CISSP, CISM, GLAW, and GSEC are named and checkable, and "over 20 years" gives a concrete number. That's enough hard facts to qualify this as Quant-eligible.

fact: Risk Committee

fact: Cybersecurity Committee

fact: CISO

fact: over 20 years of cybersecurity operations and management experience

fact: CISSP certification

fact: CISM certification

fact: GLAW certification

fact: GSEC certification


reasoning: The paragraph primarily describes the company's internal cybersecurity processes — software tools (antivirus, endpoint detection, MFA), policies and procedures, and internal review processes. While the board and a senior VP are mentioned, they are incidental to the process description; the person-vs-function test confirms the content is about what the program does, not about any individual. No facts from the IS list are present: 'senior vice president of operations and engineering' is not a cybersecurity-specific title (not CISO/CTO/CIO/VP of IT/Security), 'Audit Committee' and 'Board of Directors' are generic, and the tools listed (antivirus, endpoint detection, MFA) are common practices rather than named products.

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

Content Category: This paragraph describes the company's internal cybersecurity processes - cross-departmental approach, software programs (antivirus, endpoint detection, MFA), policies and procedures. While it mentions the board and a senior VP, the dominant content is about the risk management processes and tools. The person-vs-function test: removing the role titles, the paragraph still describes processes. → Risk Management Process

Specific facts:
- "senior vice president of operations and engineering" - this is a specific role but not cybersecurity-specific (not CISO/CTO/CIO/VP of IT/Security).

The SVP of operations and engineering isn't a dedicated cybersecurity role, so it doesn't meet the IS criteria. The rest of the content is all generic—standard security tools like antivirus and MFA, plus boilerplate references to the Audit Committee, Board, and employee handbook. There are no named frameworks, specific dates, third-party firms, or proprietary tools mentioned.

This is clearly Generic Boilerplate with a specificity score of 1.


reasoning: The paragraph contains an explicit materiality assessment ('not aware of cybersecurity incidents that have materially affected or are reasonably likely to materially affect us'), which per Rule 6 is Strategy Integration regardless of the appended cross-reference to Risk Factors. It also mentions cybersecurity insurance but with no specifics (no named insurer, no dollar amounts). All language is boilerplate with no firm-specific facts.

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

The paragraph contains:
1. Acknowledgment of past incidents (no details)
2. Materiality assessment ("not aware of cybersecurity incidents that have materially affected...")
3. Forward-looking risk language
4. Mention of cybersecurity insurance (no specifics)
5. Cross-reference to Risk Factors

Per Rule 6, the materiality assessment makes this Strategy Integration. The cross-reference doesn't change that.

Specificity: No named frameworks, no firm-specific facts, no dates, no dollar amounts.

The insurance reference is too vague to add substance—it's just boilerplate language without any meaningful detail about coverage or claims.


reasoning: The paragraph describes the company's internal incident response and management plans, testing cadence, and playbook steps from detection through notification. Board and management are mentioned only as notification recipients, not as primary actors. No named frameworks, tools, specific titles, dates, or other firm-specific facts are present — all language is generic and could apply to any company.

thinking:
Let me analyze this paragraph.

Content: Describes incident response and management plans, testing effectiveness, response playbook with steps from detection to mitigation/recovery/notification.

Category: This is about the company's internal processes - incident response planning, testing, playbook. The Board and management are mentioned as recipients of notifications, not as primary actors. → Risk Management Process

Specificity: Let me check for specific facts:
- No named frameworks
- No cybersecurity-specific titles (just "employees, management, and Board of Directors" - all generic)
- "legal" mentioned as a functional area - but "e.g., legal" is generic

- No named tools, firms, dates, or numbers
- "incident response playbook" is just a generic program name
- These are standard incident response practices

This is clearly generic boilerplate with no specific facts or named standards.