fact: CIO reports on cybersecurity strategy and risk control efforts

reasoning: The paragraph primarily answers 'how does the board oversee cybersecurity?' — describing the Board's oversight role, the Audit Committee's coordination, and how information flows from management to the Board. This is a governance-chain paragraph (Board → Audit Committee → CIO → officers) with oversight structure as its purpose → BG. The CIO is a firm-specific cybersecurity leadership title (VP-level or above), elevating to Level 3. Other roles mentioned (General Counsel, CFO, CEO, Chief Accounting Officer, Audit Committee) are generic governance roles that don't qualify as firm-specific. No QV-eligible facts are present.

thinking:
Let me analyze this paragraph.

Content Category: This describes how the Board oversees cybersecurity, with the oversight structure flowing from Board → Audit Committee → management. The CIO reports to various officers and the Audit Committee. This is a governance-chain paragraph describing oversight structure → BG.

Specificity: Let me scan for facts:
- CIO - this is a firm-specific cybersecurity-adjacent role? CIO is listed as a cybersecurity leadership role at VP level or above. Yes, CIO is firm-specific.
- General Counsel, Chief Accounting Officer, CFO, CEO - these are generic governance roles, NOT firm-specific

- Audit Committee - every company has one, NOT firm-specific
- "third-party cybersecurity risk assessments" - mentions third-party assessments but no domain terminology per se

CIO qualifies as firm-specific based on the codebook listing. Chief Accounting Officer is a generic corporate role like CEO and CFO, so it doesn't count as firm-specific. The paragraph relies mostly on standard governance titles rather than domain-specific cybersecurity terminology.

Since CIO appears, that pushes this to Level 3. There are no quantifiable facts—no specific numbers, dates, named external entities, or certifications mentioned.


content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: The paragraph states a backward-looking and forward-looking materiality conclusion ('not aware of any cybersecurity incidents that have materially affected or are reasonably likely to materially affect'), making it SI per the materiality assessment rule. The cross-reference to Item 1A is subordinate. Specificity is Level 1: the negative self-assertion about no material incidents is not externally verifiable, and no domain terms, firm-specific facts, or QV-eligible facts are present.

provider: anthropic

generationId: agent-sdk

stage: benchmark


content_category: Management Role

fact: Enterprise & Technology Security ("E&TS") organization

fact: Chief Information Security Officer ("CISO")

fact: CSIRT (Computer Security Incident Response Team)

fact: Product Security Incident Response Team ("PSIRT")

fact: Business Information Security Officers ("BISO")

fact: Office of the CISO

reasoning: The paragraph answers 'how is management organized to handle cybersecurity?' by detailing IBM's E&TS organization, the CISO's responsibilities, CSIRT, PSIRT, and BISOs — all organizational structure, roles, and coordination lines. Person-removal test: stripping roles and teams leaves little substantive content. Specificity is Firm-Specific (Level 3) due to multiple named organizational units and cybersecurity-specific roles (CISO, BISO, E&TS, PSIRT), but no QV-eligible facts like numbers, dates, or named external entities.

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

Content Category: This paragraph describes how management is organized to handle cybersecurity. It details the E&TS organization, the CISO role, CSIRT, PSIRT, and BISOs - all about organizational structure, roles, and responsibilities.

Person-removal test: Remove CISO, BISO, team references. What remains? E&TS organization has oversight for security of internal systems and external offerings, addresses third-party supplier risks. There's some program description but the primary content is organizational structure - who does what, reporting lines, team composition.

This is definitely MR - the paragraph is fundamentally about how IBM's management structure is organized around cybersecurity, with the E&TS organization, CISO role, and various specialized teams like CSIRT and PSIRT. Removing all the organizational and role-specific details leaves almost nothing substantive. The firm-specific elements are everywhere: the named E&TS organization, the CISO position, the CSIRT and PSIRT teams - these are all IBM-specific structures that wouldn't apply to other companies.


content_category: Board Governance

category_confidence: medium

reasoning: This paragraph lists oversight activities (reviewing examination reports, monitoring emerging risk issues) typical of a board or board-committee charter—answering 'how does the board oversee cybersecurity?' The language is entirely general oversight vocabulary (review, monitor, discuss) with no cybersecurity domain terminology, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

This describes committee activities related to information security oversight. The items listed are review of examination reports, communications from regulators, monitoring emerging risk issues including frameworks/rules/regulations.

Category: This reads like committee activities. The question is whether this is BG (board oversight) or RMP (program activities) or MR (management committee).

These appear to be committee charter items (lettered list: f, g). They describe what a committee does - reviewing reports, monitoring issues. Without more context, this looks like oversight activities of a committee. Given the lettered format (f, g), this is likely a continuation of a committee's responsibilities list.

The oversight-oriented nature of these activities—reviewing examination reports, monitoring emerging risks—points toward board-level governance rather than operational management. The language around regulatory findings and supervisory review suggests this is BG. Looking at the specificity, the terms used are fairly general: "information security examination reports," "regulatory agencies," and "frameworks, rules and regulations" without domain-specific terminology.


fact: identity and access management

fact: cyber defense operations

fact: security engineering

fact: penetration testing

fact: threat intelligence

fact: managed security services

fact: Executive Vice President / Chief Information Security Officer (CISO)

fact: Chief Information Officer (CIO)

fact: Senior Executive Vice President / Chief Operating Officer

fact: over 25 years' experience in cybersecurity risk management (CISO)

type: quantified

fact: over 27 years' experience in technology risk management (CIO)

reasoning: The paragraph primarily answers 'how is management organized?' — it describes team composition (professionals in IAM, cyber defense, etc.), leadership roles (EVP/CISO, CIO) with their qualifications, and reporting lines up to the COO/CEO/Board. While third-party security services are mentioned, they are subordinate to the organizational structure. The person-removal test confirms MR: removing roles, experience, and reporting lines collapses most of the paragraph. Specificity reaches Level 4 via quantified years of experience ('over 25 years', 'over 27 years') which are verifiable lower bounds.

thinking:
Let me analyze this paragraph.

Content: Describes the cybersecurity team composition (identity and access management, cyber defense operations, security engineering, IT governance/risk/compliance), leadership roles (EVP/CISO with 25+ years, CIO with 27+ years), reporting lines (to SVP/COO → CEO → Board), and third-party engagements for various security services.

Category: This paragraph primarily answers "How is management organized to handle cybersecurity?" - it describes team composition, leadership roles with qualifications, and reporting lines. The person-removal test: removing all person-specific content leaves "engages information technology risk management employees...

professionals in identity and access management, cyber defense operations, security engineering and IT governance, risk and compliance... engages third parties for risk assessment, penetration testing, incident response, threat intelligence, education, and managed security services." That's still substantive but the PRIMARY content is about who leads, their experience, and reporting structure. The majority of text is about roles/qualifications/reporting lines → MR.

Actually, let me reconsider. The paragraph has substantial content about both roles AND activities. But the core structure is: team composition → leadership roles with experience → reporting lines → third-party engagements. The person-removal test leaves some content but the paragraph's primary purpose is describing the management organization. MR.

Specificity:
- The leadership experience is quantified (25+ years, 27+ years)
- Team functions are specifically named (identity and access management, cyber defense operations, security engineering, IT governance/risk/compliance)
- Third-party services are explicitly listed (risk assessment, penetration testing, incident response, threat intelligence, education, managed security services)
- Reporting structure is clearly defined (EVP/CISO and CIO reporting to SVP/COO, who reports to CEO and Board)

This is quite specific about organizational structure and capabilities.


reasoning: The paragraph is a generic introductory overview, but its most substantive disclosure is the final sentence's materiality assessment — 'not aware of any cybersecurity incidents that have materially affected or are reasonably likely to materially affect' — which is a backward-and-forward-looking conclusion per Rule 5, making SI the best fit. All language is general business vocabulary (risk management, information assets, policies and procedures, Board of Directors, management) — no cybersecurity domain terminology passes the ERM test, no firm-specific facts, and the 'December 31, 2024' date merely anchors a negative self-assertion that is not independently verifiable.

thinking:
Let me analyze this paragraph.

Content: This is an introductory/overview paragraph that covers multiple topics broadly. The last sentence is a materiality assessment.

Category analysis:
- General intro about cybersecurity importance
- Mentions board and management oversight briefly
- Mentions programs, policies, procedures
- Last sentence: materiality assessment - "not aware of any cybersecurity incidents that have materially affected or are reasonably likely to materially affect"

The last sentence is a clear SI materiality assessment (both backward and forward-looking). But the rest is generic overview. The materiality assessment is a concrete conclusion per Rule 5.

Most of this is just generic framing about having programs and policies in place. The substantive part is that final materiality statement—it's the only concrete disclosure here. Since that's the most specific thing being said, I'll categorize this as SI.

Looking at specificity markers: the December 31, 2024 date is just a reporting anchor for a negative assertion, which doesn't count as externally verifiable per the codebook. The language around cybersecurity risk management and information assets is all boilerplate—no domain terminology that passes scrutiny. References to the Board and management aren't firm-specific facts. Even the materiality language itself is standard SEC boilerplate.

This lands at Level 1—Generic Boilerplate. No domain terms survive the ERM test, no actual firm-specific facts, nothing that qualifies as quantitative or verifiable.


fact: Aerospace Safety Committee (non-generic board committee)

fact: Chief Information Officer and Senior Vice President, Information Technology & Data Analytics (CIO)

fact: Chief Security Officer (CSO)

fact: Chief Aerospace Safety Officer

fact: Chief Product Security Engineer

reasoning: The paragraph answers 'How does the board oversee cybersecurity?' — it describes Board delegation to two committees, briefing content and frequency, escalation procedures, and information flow to the full Board, all hallmarks of Board Governance. Specificity is Level 3 due to multiple firm-specific facts: the Aerospace Safety Committee is a non-generic board committee unique to Boeing, and several cybersecurity-relevant VP+ roles are named (CIO, CSO, Chief Product Security Engineer, Chief Aerospace Safety Officer). No QV-eligible facts are present — cadences like 'bimonthly' are generic, and no specific numbers, dates, named external entities, or certifications appear.

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

**Content Category:** This is clearly about board oversight of cybersecurity. It describes the Board's delegation to two committees (Audit Committee and Aerospace Safety Committee), briefing frequency, information flow, and escalation procedures. This answers "How does the board oversee cybersecurity?" → **Board Governance**

**Specificity:** Let me scan for facts:

- CIO title mentioned → firm-specific (cybersecurity-adjacent VP+ role)
- "Senior Vice President, Information Technology & Data Analytics" → named role
- CSO (Chief Security Officer) → firm-specific named role

- Aerospace Safety Committee → named non-generic committee (not every company has this) → firm-specific
- Chief Product Security Engineer → unique named role, firm-specific
- Bimonthly meetings and threat landscape discussions → generic cadence and business language
- Chief Engineer and Chief Aerospace Safety Officer → unique roles specific to Boeing's structure

The Aerospace Safety Committee and these specialized security roles (CIO, CSO, Chief Product Security Engineer) all point to Level 3 specificity—these are named positions and committees that are distinctly Boeing's, not generic industry practices.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — describing full Board oversight of ERM incorporating cyber risks, board briefings on risk assessments, an escalation process, and periodic engagement of third-party experts. All language is generic business/governance terminology: 'Enterprise Risk Management program,' 'risk assessment results,' 'escalation process,' 'independent third-party technology experts' (unnamed), and 'Board of Directors' are not domain-specific, firm-specific, or verifiable, keeping this at Level 1.

thinking:
Let me classify this paragraph.

Content Category: "How does the board oversee cybersecurity?" — Board oversight, ERM program, board being apprised, escalation process, board engaging third parties. This is clearly Board Governance.

Specificity: Let me scan for facts.
- "Enterprise Risk Management program" — generic ERM, not domain terminology
- "cybersecurity risk assessment" — generic risk language
- "escalation process" — generic
- "independent third-party technology experts" — unnamed, not firm-specific
- "information technology systems" — generic
- No named roles beyond generic "Board" and "Management"

- No domain terminology like specific security practices, tools, or frameworks
- No firm-specific facts such as a named CISO or committees beyond the full Board
- No QV facts

This is Level 1 — Generic Boilerplate. Everything here is generic business language that any company could use.


reasoning: The paragraph contains a backward-looking materiality assessment ('we have not experienced any material cyber threats or incidents to date'), which per the codebook is a materiality conclusion → SI. The remaining text is speculation ('could have a material adverse effect') and a cross-reference to Item 1A, which are subordinate. No domain terminology passes the ERM test (language like 'cybersecurity program,' 'unauthorized access,' and 'sensitive information' are general business terms), no firm-specific facts, and no verifiable claims, yielding Level 1.

thinking:
Let me analyze this paragraph.

Content: Mixed content - mentions being a target, program design, no material incidents to date, speculative impact language, and a cross-reference.

Category: The key question is what this primarily answers. Let me break it down:
- "We have been a target..." - context
- "our cybersecurity program is designed to prevent unauthorized access and protect sensitive information" - generic RMP
- "we have not experienced any material cyber threats or incidents to date" - negative assertion with materiality framing → SI
- "could have a material adverse effect" - speculation, NOT SI

- "refer to Item 1A" - cross-reference → N/O

The materiality assessment "have not experienced any material cyber threats or incidents to date" is a backward-looking materiality conclusion → SI per Rule 5. Most of the text is speculation and cross-reference, but the SI-qualifying sentence with its materiality assessment makes SI the primary content. The paragraph also contains generic facts like "large IT systems" and unnamed "third-party service providers," so specificity is low.

Looking at the language more closely, nothing here passes the ERM test—"unauthorized access" and "cybersecurity measures" are too generic, and the negative self-assertion about not experiencing material threats isn't verifiable per the codebook. This is Level 1, SI.


fact: chief information officer (CIO)

fact: chief information security officer (CISO)

fact: chief risk officer

reasoning: The paragraph primarily answers 'How does the board oversee cybersecurity?' — describing audit committee oversight, board-level reporting cadences, and information flow from CIO/CISO/CRO to the board, making it BG. Specificity reaches Level 4 because 'two members of the audit committee have obtained certifications in cybersecurity oversight' provides a specific headcount that is a quantified fact; CISO, CIO, and CRO are firm-specific roles that support Level 3.

thinking:
Let me analyze this paragraph.

Content category: This paragraph answers "How does the board oversee cybersecurity?" - it describes board/committee oversight structure, briefing frequency, how information flows to the board. BG.

There's mention of CISO, CIO, CRO but in the context of reporting TO the board/audit committee. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure.

Specificity:
- "audit committee" - not firm-specific (every company has one)
- "Two members of the audit committee have obtained certifications in cybersecurity oversight" - "Two" is a specific number, and "certifications in cybersecurity oversight" - is this QV? The number "two" is quantified.

The "two members" claim is self-reported and the certifications aren't named specifically, but the hard number itself qualifies as QV-eligible per the codebook. The CIO and CISO are firm-specific roles, while CRO is mentioned in a cybersecurity context though not explicitly cybersecurity-focused. The briefing cadences—quarterly and twice yearly—are generic frequencies. 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 please share the next thinking chunk that needs to be rewritten?


content_category: Risk Management Process

fact: phishing tests

fact: CSO (Chief Security Officer)

reasoning: Person-removal test: removing the CSO and team references leaves a substantive program description (implementing detection/reporting/mitigation functions, developing tools for incident remediation, employee trainings, phishing tests, awareness initiatives) → RMP. The CSO is a cybersecurity-specific leadership role (firm-specific, Level 3), and 'phishing tests' is domain terminology (Level 2); no QV-eligible facts present, so specificity caps at Level 3.

thinking:
Let me analyze this paragraph.

Content: Describes the information security team's role, their activities (implementing privacy/cybersecurity program, detection, reporting, security, mitigation), developing tools and processes for incident identification/containment/remediation, retaining consultants, employee trainings, phishing tests, awareness programs.

Category: Person-removal test - remove "CSO" and "information security team" references. What remains: implementing privacy and cybersecurity program, detection, reporting, security and mitigation functions, developing tools and processes for identifying/containing/remediating incidents, retaining consultants, employee trainings, phishing tests, awareness communications.

This is a substantive program description, so it qualifies as RMP. Looking at specificity: the CSO title is a cybersecurity executive role that's firm-specific, phishing tests fall under domain terminology, and "information security team" isn't quite specific enough on its own. There are no quantifiable facts like numbers, dates, or certifications present, which puts this at Level 3.


reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing the incident response process — containment, remediation, recovery, third-party assistance, notification procedures, and annual plan review. Board/committee notification is subordinate to the process description. All language is generic incident response terminology (containment, remediation, forensic investigations, incident response plan) that any ERM professional could write; 'forensic investigations' exists outside cybersecurity contexts, 'incident response plan' is explicitly non-domain, 'Franklin Audit Committee' and 'Board' are generic governance structures, and 'at least annually' is a generic cadence — nothing elevates above Level 1.

thinking:
Let me analyze this paragraph.

Content: Describes incident response process - containment, remediation, recovery, third-party relationships for forensic/IR, notification procedures, disclosure determinations, annual plan review.

Category: This primarily answers "What does the cybersecurity program do?" - it describes the incident response process. There's mention of board notification but it's subordinate to the process description. RMP.

Specificity: Let me scan for facts:
- "incident response plan" - generic, Level 1
- "third-party providers" - unnamed, not firm-specific
- "forensic investigations" - this is domain terminology (forensic investigations in cybersecurity context)

- "incident response management" - generic
- "Franklin Board of Directors" / "Franklin Audit Committee" - these are generic governance structures every company has
- "at least annually" - generic cadence

The core terms here—containment, remediation, recovery—are standard incident management language that could apply across industries. Even "forensic investigations" isn't uniquely cybersecurity-specific since it appears in financial and fraud contexts too. The paragraph is really quite generic overall, just describing a standard incident response workflow without firm-specific details or concrete practices. I'm settling on Level 1 for this section too—the references to "Franklin Audit Committee" and "Board" are generic governance terms, not firm-specific language, so there's no domain-specific content here either.


content_category: Third-Party Risk

fact: Cybersecurity team (named team conducting assessments)

fact: data security controls

specificity_confidence: medium

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing formal risk assessments of service providers, reassessment cadences, and contractual security requirements imposed on vendors, all clearly TP. The 'Cybersecurity team' is a named team performing these assessments, elevating to Level 3. 'Data security controls' passes the ERM test as domain terminology. The rest is largely generic vendor oversight language (risk-based approach, contractual language, reassessments).

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


reasoning: This is a governance-chain paragraph describing how the Board and Audit Committee oversee cybersecurity, with management reporting upward — answering 'how does the board oversee cybersecurity?' The VP title is mentioned to describe who reports to the board, keeping the frame on oversight structure (BG, not MR). The 'Vice President, Information Systems and Technology' is a VP-level IT role qualifying as firm-specific, elevating specificity to Level 3.

thinking:
Let me classify this paragraph.

Content: Board oversight of cybersecurity, Audit Committee monitors risk management including cybersecurity, management reports to the board through Audit Committee. This is a governance-chain paragraph describing oversight structure → BG.

Specific facts:
- "Vice President, Information Systems and Technology" — VP-level title with IT portfolio → firm-specific (named_role)
- "Audit Committee" — every public company has one → NOT firm-specific
- "cybersecurity maturity" — this is general language

No QV facts. One firm-specific fact (VP title). Domain terms? "cybersecurity threats" and "cybersecurity maturity" — these are general.

The domain terminology here doesn't meet the ERM threshold, so I'm classifying this as Level 3 (Firm-Specific) based solely on the VP title.


reasoning: The paragraph states a backward-looking materiality conclusion ('no cybersecurity incidents have had a material adverse effect on our business, financial condition or results of operations') and discusses cybersecurity insurance coverage, both answering 'how does cybersecurity affect the business or finances?' → SI. No domain terminology, firm-specific facts, or verifiable claims are present — 'cyber risk insurance' is general business language, the negative materiality assertion is not externally verifiable, and 'could have a material adverse effect' is generic speculation.

thinking:
Let me analyze this paragraph.

Content: Mix of materiality assessment and insurance discussion.

"No cybersecurity incidents have had a material adverse effect" - backward-looking materiality assessment → SI
"may not be successful in preventing or mitigating" - speculation
"cyber risk insurance" - insurance topic → SI
"costs relating to certain kinds of security incidents could be substantial" - financial impact discussion

Primary question: "How does cybersecurity affect the business or finances?" → Strategy Integration

The materiality assessment ("no cybersecurity incidents have had a material adverse effect on our business, financial condition or results of operations") is a backward-looking SI conclusion. The insurance discussion also falls under SI.

Looking at the specificity here, I don't see any domain-specific terminology or firm-specific facts—just generic language about cyber insurance and unverifiable claims about past incidents. This reads as standard boilerplate disclosure, so it's Level 1.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing vendor assessment, due diligence, onboarding procedures, and security requirements imposed on providers. All language (risk assessments, due diligence, security requirements and controls) passes the ERM test — a non-security risk manager could write identical text about any vendor risk domain — so no domain terminology elevates this above Level 1.

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

No domain terminology - "risk assessments," "due diligence," "security requirements and controls" are all general business/ERM language. No specific tools, frameworks, or cybersecurity-specific practices mentioned.

No firm-specific facts - no named roles, committees, or unique organizational details.

No QV facts.

Level 1.


fact: Information Security Team

reasoning: The paragraph's central topic is the process for overseeing cybersecurity risk from third-party service providers — onboarding assessments, risk tolerance decisions — directly answering 'how are third-party cyber risks managed?' The named 'Information Security Team' is a firm-specific organizational unit, elevating to Level 3. The remaining language (risk assessments, documented processes, monitoring) is general ERM vocabulary that doesn't pass the domain terminology test.

thinking:
Let me analyze this paragraph.

Content: About overseeing third-party cybersecurity risk - vendor onboarding process, risk assessments of third-party service providers.

Category: This is centrally about how third-party cyber risks are managed → Third-Party Risk (TP). The heading even says "Overseeing Third-Party Cybersecurity Risk."

Specificity:
- "Information Security Team" - named team? It's a specific named team → firm-specific
- "designated information security personnel from each segment" - organizational detail
- The rest is fairly generic process description

No domain terminology that passes ERM test - "cybersecurity risk assessment," "risk assessments" are general ERM language.

The "Information Security Team" is a named organizational unit, so that's firm-specific, but "information security program" itself is generic language. I'd rate this as Level 3.


reasoning: The paragraph's central topic is oversight of third-party service providers' cybersecurity, specifically conducting assessments of vendors requesting access to information assets — directly answering 'how are third-party cyber risks managed?' Specificity remains Level 1 because 'risk and compliance assessments' and 'information assets' are general business/ERM language that any non-security professional would use; no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Content: About managing third-party service provider cyber risks - conducting assessments of providers requesting access to information assets.

Category: This answers "How are third-party cyber risks managed?" → Third-Party Risk. The central topic is oversight of external parties' cybersecurity posture.

Specificity: Let me scan for facts.
- "risk and compliance assessments of third-party service providers" - this is general process language, not domain terminology. An ERM professional would say "risk and compliance assessments" about any vendor category.
- "information assets" - general IT/business term
- No domain terms, no firm-specific facts, no QV facts.

- This lands at Level 1 - Generic Boilerplate, since it uses standard risk management language without any specific details or specialized terminology.


fact: Emergency Incident Response Team

reasoning: This fragment describes program activities — senior management and a named team periodically reviewing and drilling on a plan — which answers 'what does the cybersecurity program do?' (RMP). The 'Emergency Incident Response Team' is a named team with a distinguishing identifier, elevating specificity to Level 3; the remaining language ('periodically review and drill on the plan') is generic and does not contain domain terminology or verifiable facts.

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

The paragraph mentions "Part I Item 1A, 1B, and 1C including key questions to be addressed, critical decision points, and sources of key information to support decision-making. Senior management and the Emergency Incident Response Team periodically review and drill on the plan."

This appears to be a fragment - likely the tail end of a paragraph describing some kind of plan that covers Items 1A, 1B, and 1C. It mentions senior management and an "Emergency Incident Response Team" reviewing and drilling on "the plan."

Content category: This describes activities (reviewing and drilling on a plan) involving senior management and a team.

The "Emergency Incident Response Team" is a firm-specific named team that periodically reviews and drills on the plan - this describes actual program activities rather than just structural elements. The content captures both who performs the activities and what those activities entail, though the description of the activities themselves is fairly minimal.

Since "Emergency Incident Response Team" is a distinguishing named team composition rather than a generic reference, this qualifies as firm-specific at Level 3. The overall categorization is RMP - it's describing the program's drilling and review activities.


reasoning: The paragraph opens with a materiality assessment stating cybersecurity threats have not materially affected and are not reasonably likely to affect business strategy, results of operations, or financial condition — this is a conclusion about materiality, making it SI. The remaining text about updating plans and making investments is generic business language with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Starts with a materiality assessment ("not aware of any cybersecurity threats that have materially affected or are reasonably likely to affect"), then generic language about threats increasing and the company updating its plan and making investments.

Category: The first sentence is a clear materiality assessment → SI. The rest is generic. The primary question answered is "How does cybersecurity affect the business?" with a materiality conclusion.

Specificity: Let me scan for facts:
- "materially affected or are reasonably likely to affect Seaboard's business strategy, results of operations or financial condition" — this is the SEC's standard materiality language, boilerplate

- The remaining terms like "information security plan" and "information technology infrastructure" are all generic without any firm-specific details or quantifiable facts, so this lands at SI Level 1.


reasoning: The paragraph states a backward-looking conclusion that cybersecurity has not materially impaired business strategy, operations, or financial standing — a materiality assessment that maps to SI under Rule 5. No domain terminology, firm-specific facts, or verifiable claims are present; the negative self-assertion ('has not encountered... breaches that have materially impaired') is not externally verifiable, so specificity remains Level 1.

thinking:
Classify this paragraph.

Content: "To date, the Company has not encountered cybersecurity challenges, risks, or breaches that have materially impaired its business strategy, operations, or its financial standing."

This is a materiality assessment - backward-looking negative assertion about whether cybersecurity has affected the business. → Strategy Integration.

Specificity: "have not... materially impaired its business strategy, operations, or its financial standing" - this is boilerplate materiality language. No domain terms, no firm-specific facts, no QV facts. The negative assertion "have not experienced material incidents" is not externally verifiable. → Level 1.

I notice there's a section header "Identified Material Risks" that appears to be part of this, but the actual substance here is just the materiality assessment itself.


fact: real-time security scoring of supplier technology services

fact: threat intelligence

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing supplier risk assessments, security scoring, threat intelligence monitoring, and contractual cybersecurity provisions, all focused on oversight of external parties. Domain terms like 'threat intelligence,' 'security scoring,' and 'continuous threat intelligence monitoring' pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: About supply chain risk management, monitoring suppliers' cybersecurity, threat intelligence for third parties, contractual provisions with suppliers. Central topic is oversight of external parties' cybersecurity → Third-Party Risk.

Specificity: Let me scan for facts.
- "threat intelligence" - domain term
- "security scoring" - domain term
- "threat intelligence monitoring" - domain term

No firm-specific facts, no QV facts.

Level 2.


fact: Head of Cyber Security

reasoning: The paragraph primarily answers how the board oversees cybersecurity: delegation to the Audit Committee, quarterly reporting from the Head of Cyber Security, and information flowing back to the full Board. While later sentences touch on program evaluation and third-party risk assessments, the oversight structure framing dominates. 'Head of Cyber Security' is a cybersecurity-specific leadership title distinguishing this company's posture, elevating specificity to Level 3. The remaining content (quarterly reports, internal/external evaluations, third-party risk assessments) uses general business language that doesn't pass the ERM test for domain terminology.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph starts with board delegation to Audit Committee, then describes reporting from Head of Cyber Security to Audit Committee, then Audit Committee reporting to the Board. Then it shifts to program evaluation and third-party risk assessments.

The primary question answered: "How does the board oversee cybersecurity?" - The paragraph is structured around the oversight chain from Board → Audit Committee → Head of Cyber Security, with information flowing back up. The program evaluation and third-party risk assessment mentions are subordinate to the oversight structure.

Actually, let me reconsider. The paragraph covers:

1. Board delegated to Audit Committee (BG)
2. Head of Cyber Security reports quarterly to Audit Committee (BG)
3. Audit Committee reports to full Board (BG)
4. Cybersecurity program evaluated by internal/external resources (RMP)
5. Results reported to senior management and Audit Committee (BG)
6. Track and log security incidents, third-party risk assessments (RMP/TP)

The majority of text is about the oversight structure and reporting flows. BG dominates. The specificity here is moderate - "Head of Cyber Security" is a firm-specific title, quarterly reporting is a generic cadence, and third-party risk assessments are general practice.

I'm checking whether "Head of Cyber Security" qualifies as firm-specific leadership. It's a cybersecurity-specific title analogous to Information Security Officer, which the codebook lists, so I'll count it as Level 3 firm-specific language.


fact: Chief Information Security Officer (CISO)

reasoning: The paragraph primarily answers 'How does the board oversee cybersecurity?' by describing the Audit Committee's oversight role, the reports it receives from the CISO, and the topics covered in those reports. The CISO title is a firm-specific cybersecurity leadership role elevating to Level 3; the remaining content (Audit Committee, regular reviews, risk management language) is generic governance language that doesn't reach domain-adapted or higher.

thinking:
Let me classify this paragraph.

Content Category: The paragraph answers "How does the board oversee cybersecurity?" - It describes the Audit Committee's oversight role, what reports it receives, and from whom. This is Board Governance.

Specificity: Let me scan for facts.
- "CISO" - firm-specific (cybersecurity leadership role at VP+ level)
- "her" - identifies the CISO as female, but not a named individual
- "independent third-party assessments" - generic, not TP since it's describing what the board reviews

- "Audit Committee" - generic, every company has one

Domain terms like "cybersecurity threats or incidents," "cybersecurity program," and "cybersecurity risks" are all general language, not firm-specific. The CISO title is what pushes this to Level 3.


fact: Cyber Security Group (named internal team)

fact: operational technology

reasoning: The paragraph primarily answers 'how are third-party cyber risks managed?' with formal vendor screening, risk ranking, periodic rescreening, attestation requirements, and supply chain sourcing restrictions — all requirements imposed ON vendors. The cyber insurance sentences are subordinate. Specificity reaches Level 4 because the 'Department of Homeland Security's list of Prohibited Nations' is a named external government reference that is independently verifiable, and 'Cyber Security Group' is a firm-specific named team.

thinking:
Let me analyze this paragraph.

Content: Third-party vendor screening, risk ranking, rescreening, attestation requirements, supply chain protection (DHS prohibited nations), cyber insurance.

Category: The paragraph starts with third-party vendor management (screening, risk ranking, rescreening, attestation requirements, barring countries). Then shifts to cyber insurance and its limitations. The majority of text is about third-party risk management. But there's also insurance (SI territory). The central topic is third-party risk management with insurance mentioned at the end.

Actually, let me count: ~4 sentences about vendor/third-party processes, then 3 sentences about cyber insurance. The dominant frame is third-party risk, but insurance is a notable portion.

The opening "Specific to third parties" really anchors the whole section, so I'm categorizing this as Third-Party Risk. Looking at specificity, I see "Cyber Security Group" is a named team, "Department of Homeland Security's list of Prohibited Nations" references an external authority, while things like "procurement process" and "business continuity programs" are more generic. The cyber insurance piece could go either way, but the vendor screening and requirements dominate the content.

For the specificity level, the DHS Prohibited Nations list is the key factor here—it's a named external government entity that's verifiable, which pushes this to Level 4.


fact: network segmentation

fact: endpoint protection

fact: identity management

fact: cloud security

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing tools and safeguards across multiple security domains. Terms like network segmentation, endpoint protection, identity management, threat intelligence, and cloud security are cybersecurity-specific vocabulary that passes the ERM test, but nothing is unique to Fannie Mae specifically — no named roles, teams, or verifiable facts.


fact: defense-in-depth and layered strategy

fact: endpoint detection and response

fact: network anomaly detection

fact: multi-factor authentication

fact: threat intelligence services

fact: phishing simulation exercises

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing risk management activities, security controls, training, and third-party engagement — clearly RMP. Multiple domain terms (EDR, MFA, defense-in-depth, network anomaly detection, threat intelligence, phishing simulation) elevate to Level 2, but no firm-specific facts (no named roles, committees, or unique organizational details) or verifiable claims (third-party consultants are unnamed, no specific numbers or certifications) push it higher.

thinking:
Let me analyze this paragraph.

Content category: "What does the cybersecurity program do?" → RMP. Describes the program's activities, tools, and processes.

Specificity: Let me scan for facts.

Domain terms: defense-in-depth, endpoint detection and response (EDR), network anomaly detection, multi-factor authentication (MFA), threat intelligence, phishing simulation - all pass ERM test → Level 2

Firm-specific: Nothing unique to this company specifically. "Various third-party consultants" is unnamed. No named roles, committees, etc.

QV-eligible: No specific numbers, dates, named external entities, or certifications.

This lands at Level 2 specificity since it uses domain-adapted terminology but lacks company-specific details, quantifiable metrics, or external references.


reasoning: The opening clause states a conclusion about materiality ('did not experience a material cybersecurity incident during the year ended December 31, 2024'), which is a backward-looking negative assertion qualifying as SI per Rule 5. The remainder is a cross-reference to Item 1A and a section header ('Governance.'), both subordinate. Specificity is Level 1: the negative materiality assertion is not externally verifiable per codebook guidance, 'December 31, 2024' is a reporting period anchor not a cybersecurity fact, and no domain terminology, firm-specific facts, or QV-eligible claims are present.

thinking:
Let me analyze this paragraph.

"Although the Company did not experience a material cybersecurity incident during the year ended December 31, 2024, the scope and impact of any future incident cannot be predicted. See "Item 1A. Risk Factors – Risks Related to Information Technology and Cybersecurity" for more information on the Company's cybersecurity-related risks. Governance."

This has three parts:
1. "did not experience a material cybersecurity incident" - negative assertion about materiality → SI per Rule 5
2. Cross-reference to Item 1A → N/O

3. "Governance." - section header → N/O

The core issue is whether the negative assertion about not experiencing material incidents qualifies as SI. The codebook treats "We have not experienced any material cybersecurity incidents" as a negative self-assertion that isn't externally verifiable, so it doesn't meet the SI threshold. The speculation about future incidents and the cross-reference are secondary to this main claim. This falls under Strategy Integration, but the specificity of the negative assertion is limited since it's an unverifiable self-assessment rather than a concrete, measurable statement.

Looking at the 2023 reference, adding a specific year doesn't actually make the negative assertion more verifiable—it's still just a claim without supporting evidence or quantifiable metrics. There are no QV facts, no firm-specific governance details like named roles or committees, and no domain-specific terminology that would satisfy the ERM test. This is straightforward Level 1 generic boilerplate.


fact: 24/7 security operations center

fact: insider threat protection program

fact: security awareness program with at least annual training

fact: operational technology mentioned alongside information technology

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing incident response plans, a SOC, insider threat program, training exercises, and security awareness — all program activities, making it RMP. The '24/7 security operations center' is a firm-specific organizational claim per the codebook (implies specific investment beyond generic monitoring), elevating to Level 3. Domain terms like insider threat protection and security awareness training are present but subordinate to the firm-specific fact. No named external entities, specific numbers, or verifiable certifications push it to Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity program activities - incident response plans, 24/7 SOC, insider threat program, training, security awareness program.

Category: RMP - "What does the cybersecurity program do?" This is about activities, processes, tools.

Specificity: Let me scan for facts.
- "24/7 security operations center" - this is both a domain term (SOC) and a firm-specific organizational claim ("24/7 security operations")
- "insider threat protection program" - domain term

- "security awareness program" - domain term (security awareness training)
- "operational technology" - domain-relevant term
- "at least annually" - generic cadence, not QV

No named external entities, no specific numbers, no certifications, no named individuals. The "24/7 security operations" claim is listed as firm-specific in the codebook, while "The Southern Company system" is just a self-reference. So this rates as Level 3 due to that operational claim.


fact: two-factor or independent authorizations (MFA/2FA)

fact: isolated computer workstations

reasoning: Despite garbled text, the paragraph primarily describes what the Trust's cybersecurity program does — protocols, personnel awareness, and authentication measures — answering 'what does the program do?' (RMP). Third-party mentions are subordinate context, not central oversight of vendor risk. Two-factor authorization and isolated workstations are cybersecurity domain concepts that pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

This is a somewhat garbled/truncated paragraph but I can extract meaning from it.

Content: Describes cybersecurity protocols including passwords, passphrases, two-factor authentication, isolated computer workstations, personnel awareness, and mentions third parties (banks, service providers, vendors) having their own protocols.

Category: The primary question answered is "What does the cybersecurity program do?" - it describes security measures and protocols. There's a brief mention of third parties but it's not the central topic - it just notes they have their own protocols. This is RMP.

Now I'm checking the specificity level. The mention of MFA and two-factor authentication qualifies as domain terminology that passes the ERM test, putting it at Level 2. Isolated workstations suggest network segmentation concepts, while basic password references are more general IT terms. There are no firm-specific facts like named roles or committees, and no QV facts present.


fact: security operations center (SOC)

fact: Chief Information Security Officer (CISO)

fact: Chief Information Officer

fact: Crisis Response Team consisting of CEO, CFO, CHRO, CIO, and General Counsel

fact: Cybersecurity Incident Response Plan

fact: Public Disclosure Committee

reasoning: The paragraph primarily describes how management is organized to handle cybersecurity — the escalation chain from SOC staff → CISO → Crisis Response Team → General Counsel → Public Disclosure Committee, with specific role allocations at each step. Person-removal test: removing all roles and team composition leaves only a brief SOC mention and generic escalation language, so the organizational structure IS the substance → MR. Specificity is Level 3 due to firm-specific facts (CISO, CIO, named Crisis Response Team with specific composition, named Public Disclosure Committee) but no QV-eligible facts (no numbers, dates, named external entities, or certifications).

thinking:
Let me analyze this paragraph.

Content: Describes security operations center, CISO reporting, incident response escalation process, crisis response team composition, and disclosure process.

Category: This is primarily about how management is organized to handle cybersecurity - the escalation chain, who's involved, the crisis response team composition, reporting lines. But it also describes the SOC and incident response process.

Person-removal test: Remove CISO, CEO, CFO, CHRO, CIO, General Counsel, Crisis Response Team.

What remains after removing those roles? The core substance is about the SOC identifying and monitoring threats, plus the escalation process itself, but the paragraph is really dominated by organizational structure—who reports to whom, the specific people involved in the crisis response team, and how decisions flow up the chain. Most of the text is actually about the roles and the escalation hierarchy rather than the technical security operations. The CISO and CIO are both firm-specific roles, with the CIO being cybersecurity-adjacent at the VP+ level. There are no quantifiable facts like numbers, dates, external firms, or certifications mentioned, so this falls clearly into Level 3 classification.


fact: CISSP certification held by team members

fact: GICSP (Global Industrial Cyber Security Professional) certification

fact: Electricity Information Sharing and Analysis Center (E-ISAC)

fact: Cybersecurity and Infrastructure Security Agency (CISA)

fact: Enterprise Cybersecurity team

fact: vulnerability scanning

fact: network monitoring

fact: threat intelligence

reasoning: Person-removal test: removing team composition and certifications leaves a substantive program description (threat intelligence sources, network monitoring, vulnerability scanning) → RMP. Specificity is Level 4 due to named verifiable certifications (CISSP, GICSP) and named external entities (E-ISAC, CISA).

thinking:
Let me analyze this paragraph.

Content: Describes TEP's Enterprise Cybersecurity team, their certifications, and what the team does (threat intelligence, monitoring, vulnerability scanning).

Category: Person-removal test - remove team composition, certifications. What remains? "uses governmental and industry threat intelligence... to proactively identify, assess, manage, and respond to risk, including network monitoring and vulnerability scanning." That's still a substantive program description. → RMP

Specificity:
- CISSP, GICSP → certifications held by individuals → QV (verifiable via issuing bodies)
- "Enterprise Cybersecurity team" → named team

- E-ISAC and CISA are named external entities they reference, while vulnerability scanning and threat intelligence are domain-specific terms that define their operational scope. The combination of verifiable certifications and these named partnerships pushes this to Level 4.


fact: EXCO (executive committee)

fact: Senior Leadership Team (SLT)

reasoning: The paragraph centers on the CISO's role and responsibilities — leading information security efforts, meeting cadences with various governance bodies, and performing tabletop exercises. While it mentions the Board (suggesting BG), the CISO is the subject throughout, describing how management is organized to handle cybersecurity. Person-removal test: removing CISO, titles, and meeting structures leaves only generic language about assessing risks and tabletop exercises, so substance is about the role. Specificity is Level 3 due to named cybersecurity-specific role (CISO) and named organizational bodies (EXCO, SLT); no verifiable quantified facts push it to Level 4 ('at least quarterly' and 'at least annually' are generic cadences).

thinking:
Let me analyze this paragraph.

Category: This describes the CISO's role and how they interact with the Board, EXCO, and SLT. The primary question: it describes both management organization (CISO leads) and board oversight (meets with Board quarterly). The governance-chain pattern here - CISO meets with Board, EXCO, SLT. The purpose seems to be describing how oversight flows - the CISO facilitates oversight by meeting with these groups.

But wait - the paragraph starts with "led by our CISO" and then describes what the CISO does: meets with groups, performs tabletop exercises, keeps them informed.

The CISO is the central subject throughout, and this is really about how the organization structures its cybersecurity management - specifically the CISO's interactions with governance bodies and their activities around oversight. When I remove the CISO and the reporting structure, what's left is mostly generic language about facilitating oversight and managing risks, but the substance of the paragraph is entirely about the CISO's role and their engagement with the Board, EXCO, and SLT. This looks like a governance-chain paragraph where the CISO connects these different levels.

The key tension I'm working through is whether this is primarily about board oversight (BG) or management responsibility (MR). The paragraph does describe how information flows to the board - the CISO meets quarterly with the Board, which is oversight flow. But it's equally focused on the CISO's responsibilities and their meeting cadence across multiple leadership bodies. The CISO is the active subject performing these activities, not just a passive reporting mechanism. I think this tips toward MR because the paragraph is fundamentally about what the CISO does and how they organize their engagement with leadership, rather than describing the board's oversight function itself.

Looking at the specificity markers: CISO and EXCO are clearly firm-specific, while "at least quarterly" and "at least annually" are generic cadences that don't rise to QV. The tabletop exercises and incident response processes aren't domain terminology in the codebook sense - they're operational activities rather than specialized cybersecurity concepts. So this would be MR without domain specificity.


fact: RCSC (named board-level committee)

fact: CISO

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing the RCSC committee's receipt of quarterly CISO reports and the scope of those briefings — a classic board oversight information-flow paragraph. Specificity is Level 3 due to the named RCSC committee (non-generic, firm-specific) and CISO role; no QV-eligible facts are present (quarterly is a generic cadence).

thinking:
BG - describes how board committee (RCSC) oversees cybersecurity through CISO reports.

Specific facts: CISO (firm-specific role), RCSC (named committee - though I need to determine if this is firm-specific), quarterly updates, content of reports.

RCSC = Regulatory Compliance & Sustainability Committee or Risk Committee of some kind - this is a named non-generic committee → firm-specific.

CISO → firm-specific role.

"quarterly updates" → generic cadence, not QV.

No QV facts. Level 3.


reasoning: The paragraph opens with a backward-looking materiality assessment ('cybersecurity risks have not materially affected our business or our results of operations'), which is a conclusion about whether cybersecurity has affected business outcomes → SI. The subsequent speculation ('can be no assurance') and cross-reference to Item 1A are subordinate. No domain terminology, firm-specific facts, or verifiable claims are present — the materiality language is standard boilerplate found in many filings.

thinking:
Let me analyze this paragraph.

The paragraph states "cybersecurity risks have not materially affected our business or our results of operations" - this is a backward-looking materiality assessment → SI.

Then it has speculation ("there can be no assurance...") and a cross-reference to Item 1A.

The materiality assessment is the key substantive content → Strategy Integration.

Specificity: The materiality conclusion is boilerplate language. No domain terms, no firm-specific facts, no QV facts. The cross-reference to a specific risk factor title is just a cross-reference. "To date" is not a specific date.

This lands at Level 1 - the materiality statement is generic and lacks any concrete details or firm-specific information.


content_category: None/Other

reasoning: This paragraph is a general statement about the importance of cybersecurity governance without describing any specific oversight structure, management roles, or program activities. It reads as introductory framing language that could apply to any company. No domain terminology, firm-specific facts, or verifiable claims are present. While it mentions 'cybersecurity program' and governance, it doesn't answer any of the six substantive questions — it merely asserts that governance is important.


fact: SOC 1 audit

type: framework

reasoning: The entire paragraph describes requirements imposed on third-party service providers (SOC 1 audits, waiver processes, report reviews), making Third-Party Risk the clear category. SOC 1 is a domain-specific audit standard (Level 2), but there are no firm-specific facts (no named roles, committees, or unique organizational details) and no QV-eligible facts ("annual" is a generic cadence, not a verifiable date).

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

Facts:
- SOC 1 audit → domain term (it's a specific audit standard, similar to SOC 2)
- "annual SOC 1 audit" → requirement imposed on vendors

Category: Third-Party Risk - the entire paragraph is about oversight of third-party service providers.

Specificity: SOC 1 is a domain term (Level 2). "Annual" is generic cadence. No firm-specific facts, no QV facts.

Wait - SOC 1 audit is a named standard/framework. It's domain terminology.

So this is Level 2.


fact: Chief Information Security Officer (CISO)

reasoning: The paragraph's subject throughout is the CISO — what the CISO does, who the CISO meets with (Board, ELT, SLT), and the CISO's responsibilities. While the Board and oversight flow are mentioned, they are framed as recipients of the CISO's activities rather than as the oversight structure itself; the primary question answered is how management is organized to handle cybersecurity. The CISO title is firm-specific (Level 3); cadences like 'at least quarterly' and 'at least annually' are generic and not QV-eligible, and 'tabletop exercises' and 'incident response processes' without cybersecurity-specific qualifiers do not pass the ERM test for domain terminology.

thinking:
Let me analyze this paragraph.

Category: This describes the CISO's role and how they interact with the Board, ELT, and SLT. The governance-chain question: is this about board oversight or management's organizational role?

The paragraph starts with "led by our CISO" (MR), then describes meetings with the Board, ELT, and SLT. The CISO meeting with the Board quarterly is describing oversight flow (BG). But the subject is the CISO throughout - the paragraph is about what the CISO does organizationally.

Person-removal test: Remove CISO, titles, reporting lines.

What remains is the substance of those interactions - tabletop exercises conducted annually to evaluate incident response, and keeping leadership informed about threat landscape and risk management. So while the CISO is the organizational subject, the paragraph is fundamentally answering how the board oversees cybersecurity through these structured interactions and activities. This leans toward BG because it's describing the oversight mechanism itself. The CISO's role and activities are the primary focus here—what they do and who they interact with—rather than the oversight structure itself. The Board is just one of several groups mentioned alongside ELT and SLT, so this leans more toward MR than BG. The cadences mentioned—quarterly and annual—are generic timeframes without specific dates, and there are no quantifiable facts, named external entities, or certifications that would elevate this further, so this stays at Level 3.


reasoning: This paragraph states a backward-looking materiality conclusion ('have materially affected... business strategy, results of operations, or financial condition'), making it SI under Rule 5. No domain terminology, firm-specific facts, or verifiable claims are present — the language is standard boilerplate found in many filings.


reasoning: The majority of the paragraph (4 of 6 sentences) answers 'how are third-party cyber risks managed?' by describing the Vendor Management department's vetting and oversight processes, making TP the dominant category over the single SI materiality sentence. All language is generic business/risk management vocabulary ('policies and procedures,' 'vetted, approved and inventoried,' 'key risk components are mitigated') — no cybersecurity domain terminology, no firm-specific facts (the 'Vendor Management department' is a generic organizational unit), and no verifiable claims, yielding Level 1.

thinking:
Let me analyze this paragraph carefully.

The paragraph has two distinct parts:
1. Vendor management processes (first 4 sentences)
2. Materiality assessment + cross-reference (last 2 sentences)

**Content Category:**
- First part answers "How are third-party cyber risks managed?" → TP
- "Risks from Cybersecurity threats or previous incidents have not materially affected business strategy, results of operations, or financial condition." → SI (backward-looking materiality assessment)
- "See cybersecurity risk factors in Item 1A" → N/O cross-reference

- The vendor management description is generic—"policies and procedures," "vetted, approved and inventoried," "key risk components are mitigated"—but it's anchored to cybersecurity through the statement about third parties in cybersecurity processes. The central topic is how vendor management applies to cybersecurity oversight, making this TP content that dominates the paragraph by volume.

- The materiality statement is clearly SI, but it's just one sentence against four sentences of vendor management discussion.

- I'm going with TP as the primary category since the vendor management content, while somewhat generic in places, takes up most of the space and directly connects to cybersecurity vendor oversight. I'm debating whether "Vendor Management department" counts as firm-specific. It's a named organizational unit, but vendor management departments are pretty common across companies—not really a cybersecurity-specific structure. I don't think it qualifies as firm-specific under the codebook's definition, so I'm leaning toward marking this as generic overall.

Looking at the language itself, everything here is standard business terminology—"vetted," "policies and procedures," "risk components," "have not materially affected." There's no domain-specific jargon or unique facts. This reads like Level 1 generic boilerplate.


fact: CISO provides cybersecurity dashboard to the Board

fact: CIO presents to the Board and Audit Committee

fact: CIO and/or CISO presents to the Board bi-annually

reasoning: The paragraph primarily answers 'how does the board oversee cybersecurity?' — describing Board and Audit Committee oversight mechanisms, briefing cadences, dashboard reviews, and escalation protocols, making it clearly Board Governance. The CISO and CIO are firm-specific roles (Level 3), and the reference to Transportation Security Administration (TSA) compliance is a named external regulatory entity whose requirements for pipeline companies are publicly verifiable, elevating to Level 4.

thinking:
Let me classify this paragraph.

Content Category: This is about how the board oversees cybersecurity - Board of Directors oversight, Audit Committee review, how information flows to the board (CISO dashboard, presentations). This is clearly Board Governance.

Specificity: Let me scan for facts.

- CISO - firm-specific (named_role)
- CIO - firm-specific (named_role)
- "cybersecurity dashboard" - this is a firm-specific detail
- "every regularly scheduled Board meeting" - generic cadence
- "key performance indicators for cybersecurity process maturity, operational performance, and enterprise performance" - somewhat specific

- "Transportation Security Administration (TSA) compliance" - this is a named external entity/regulation, QV-eligible
- "bi-annually" - generic cadence
- "Audit Committee" - not firm-specific (every company has one)
- "independent directors" - generic
- Incident escalation protocols - generic

The TSA reference is what pushes this to Level 4 - it's a named external regulatory body with publicly documented compliance requirements for pipeline companies, making it verifiable and QV-eligible.


fact: cybersecurity insurance requirement for vendors

fact: data security addendum with specific security standards

fact: mandatory incident reporting protocols for vendors

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' by describing requirements imposed on vendors — security protections, data security addenda, insurance, and incident reporting protocols. For specificity, the paragraph describes vendor requirements in detail but uses mostly general business/contractual language ('administrative, physical, and technical safeguards,' 'compliance with applicable data protection laws'). The mention of cybersecurity insurance as a contractual requirement for vendors and the structured data security addendum with incident reporting protocols show some domain adaptation, but the language overall borders on what a procurement/ERM professional could write. The terms barely clear the ERM test threshold, settling at Level 2.

thinking: Third-party risk management paragraph.


fact: Chief Information Officer (CIO)

fact: CIO is a member of the Company's Executive Committee

reasoning: The paragraph is titled 'management's responsibility' and its primary content identifies WHO is responsible (CIO, CISO) and their organizational positioning (Executive Committee membership). Person-removal test: removing the role-specific content leaves only generic language ('assessing and managing cybersecurity risks, including prevention, mitigation, detection, and remediation') — not a substantive program description, so MR wins over RMP. Specificity is Level 3 due to named cybersecurity leadership roles (CIO, CISO) and Executive Committee membership, but no QV-eligible facts (no numbers, dates, certifications, or named external entities).

thinking:
Let me analyze this paragraph.

Category: The paragraph mentions CIO and CISO roles and their responsibilities. Let me apply the person-removal test: Remove "The Chief Information Officer (CIO), who is a member of the Company's Executive Committee, and the Chief Information Security Officer (CISO) are responsible for" — what remains is "assessing and managing cybersecurity risks, including the prevention, mitigation, detection, and remediation of cybersecurity incidents" and "The Company takes a risk-based approach to cybersecurity and has implemented cybersecurity controls designed to address cybersecurity threats and risks."

The remaining text is generic risk management language.

The paragraph's real substance is about organizational roles and positioning rather than specific cybersecurity activities. The actual content—managing risks, prevention, mitigation, detection, remediation—is standard boilerplate without concrete details about tools, frameworks, or implementation specifics. This points to a management responsibility disclosure rather than a substantive program description.


fact: Privacy and Data Governance Committee

fact: CISO (chairs the Security and Technology Risk Leadership Committee)

fact: Chief Privacy Officer (chairs the Privacy and Data Governance Committee)

reasoning: The paragraph describes management-level committee structures (not board-level), their chairs, composition, and meeting cadence — answering 'how is management organized to handle cybersecurity?' → MR. Multiple named non-generic committees (Security and Technology Risk Leadership Committee, Privacy and Data Governance Committee, Data Security and Privacy Governance Committee) and cybersecurity-specific leadership roles (CISO, Chief Privacy Officer) elevate to Level 3. 'Approximately 20 departments' is a soft/hedged number and does not qualify as QV.

thinking:
Let me analyze this paragraph.

Content Category: This describes management-level committees (Security and Technology Risk Leadership Committee, Privacy and Data Governance Committee) - their composition, leadership, and meeting cadence. The primary question answered is "How is management organized to handle cybersecurity?" → Management Role.

These are management-level committees (not board-level), and the content is about structure/membership, not activities.

Specificity:
- CISO → firm-specific (named_role)
- Chief Privacy Officer → firm-specific (named_role)
- "Security and Technology Risk Leadership Committee" → named non-generic committee (named_committee)

- "Privacy and Data Governance Committee" → named non-generic committee
- "Data Security and Privacy Governance Committee" → named non-generic committee
- "approximately 20 departments" → soft number ("approximately"), NOT QV
- "monthly or every other month" → generic cadence

So Level 3 (Firm-Specific).


reasoning: The paragraph contains a backward-looking materiality assessment ('have not...experienced a cybersecurity threat or incident that resulted in a material adverse impact to our business or operations'), which per Rule 5 is SI. The remainder is speculation about potential costs and general threat landscape commentary, which is not substantive enough to shift category. All language is general business/risk vocabulary — 'unauthorized attempts and attacks,' 'internal processes and tools,' 'threat protection measures' — none passes the ERM test as cybersecurity domain terminology, and no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph carefully.

Content Category: The paragraph starts with a commitment to governance/oversight, then discusses that they haven't experienced a material incident, then discusses potential costs of incidents, evolving threats, and their detection efforts. The key materiality statement "we have not... experienced a cybersecurity threat or incident that resulted in a material adverse impact" is a backward-looking materiality assessment → SI. But the bulk of the text is about potential consequences (speculation) and general threat landscape. The materiality assessment is present but the paragraph is mostly about risk/impact speculation.

The materiality statement "have not...

experienced a cybersecurity threat or incident that resulted in a material adverse impact to our business or operations" is a backward-looking materiality assessment → SI per Rule 5. The rest is largely speculation about potential consequences and general threat landscape commentary. There's also a statement about detecting and investigating unauthorized attempts and preventing recurrence through process and tool updates, which appears to be RMP language.

The core substantive disclosure here is the materiality assessment itself—whether the company has experienced a material cybersecurity incident. Looking at the specificity, there are no firm-specific facts, no quantitative data, no domain terminology that would pass the ERM test, and no reporting context beyond the filing date. The language is entirely generic business risk language that could appear in virtually any company's filing, making this Level 1 boilerplate.


reasoning: This paragraph is a section header followed by generic risk language about operational security failures — pure speculation ('could disrupt,' 'could result in') without describing any actual cybersecurity measures, processes, or assessments. It fails the N/O threshold test: no substantive cybersecurity disclosure is present. No domain terminology, firm-specific facts, or verifiable claims.


reasoning: This paragraph is primarily a cross-reference directing readers to Item 7, with only a generic statement about ERM integration. It contains no substantive cybersecurity disclosure — no specific measures, processes, or assessments. All language ('enterprise risk management programs,' 'manage our cybersecurity risk') is generic business language that fails the ERM test.


reasoning: The paragraph contains a materiality assessment via the negative assertion 'we have not experienced any material cybersecurity incidents,' which is SI per the codebook's rule that negative assertions with materiality framing are Strategy Integration. The cross-reference to Item 1A is subordinate to this assessment. Specificity is Level 1: 'last three fiscal years' is a soft timeframe, the negative assertion about no material incidents is not externally verifiable (cannot independently confirm absence), and no domain terminology, firm-specific facts, or QV-eligible facts are present.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. A cross-reference to Item 1A risk factor about cybersecurity risks
2. A negative assertion about material cybersecurity incidents

For category: The first sentence is a cross-reference pointing elsewhere - that leans N/O. But the second sentence "we have not experienced any material cybersecurity incidents" is a negative assertion with materiality framing → SI per the codebook.

Per Rule 5 (SI materiality rule): "Have not experienced any material cybersecurity incidents" → SI (negative assertion).

The cross-reference uses "reasonably likely to materially affect" language, but it's just directing to another section, which points to N/O. However, the negative assertion "we have not experienced any material cybersecurity incidents" is the substantive assessment here. Even though the cross-reference comes first, the paragraph's core content is the negative assertion about material incidents, making this SI overall.

Looking at the specificity markers: the timeframe is soft, the self-assertion isn't externally verifiable, and there are no domain terms or firm-specific facts. This is Level 1 boilerplate.


content_category: Incident Disclosure

fact: February 2023 - specific month/year of the cyberattack

reasoning: The paragraph describes an actual cyberattack ('we experienced a cyberattack') with its consequences (system interruption, confidential information disclosure, litigation, governmental inquiries), directly answering 'what happened?' The cross-reference to Item 1A is subordinate to the incident description. 'February 2023' is a specific date tied to a real cybersecurity event, making it QV-eligible.

thinking:
Let me analyze this paragraph.

Content: Describes an actual cyberattack in February 2023 with consequences (system interruption, confidential info disclosure, litigation, governmental inquiries), then cross-references Item 1A for more details.

Category: This describes an actual incident - "we experienced a cyberattack" with timeline, scope, and consequences. ID.

The cross-reference is subordinate to the actual incident description.

Specificity:
- "February 2023" - specific date tied to a cybersecurity event → QV
- The paragraph describes a real incident with specific consequences

- This is a Level 4 disclosure.


reasoning: The paragraph states a backward-looking materiality conclusion ('has not experienced any material impacts to our business, operations, or reputation due to cyberattacks') which is an SI assessment per the materiality rule. The remaining text is generic commitment language. No domain terminology, firm-specific facts, or verifiable claims are present, so specificity remains Level 1.

thinking:
Materiality assessment - "has not experienced any material impacts" is a backward-looking conclusion about materiality → SI.

Specificity: No domain terms beyond generic language. "Material impacts" is a materiality assessment but generic. No firm-specific facts, no QV facts. Level 1.


fact: Cybersecurity Committee (named non-generic board-level committee)

category_confidence: low

reasoning: This overview paragraph touches BG (Cybersecurity Committee oversight), RMP (generic program mention), and SI (backward-looking materiality assessment). The materiality conclusion — 'past cybersecurity incidents did not have a material impact on the Company, including our strategy, financial condition or results of operations' — is a clear SI assessment per Rule 5, and the paragraph's arc frames cybersecurity in terms of business impact (materiality assessment → future risk → cross-reference to Risk Factors). Confidence is low because BG is a strong alternative given the Cybersecurity Committee mention. Specificity is Firm-Specific due to the named 'Cybersecurity Committee,' a non-generic committee; remaining language is generic business/risk vocabulary with no domain terminology or verifiable facts.

thinking:
Let me analyze this paragraph.

Content category: This paragraph touches multiple categories. Let me break it down:
- "Cybersecurity is a critical component of the Company's overall enterprise risk management program" - RMP framing
- "Howmet has implemented a framework of principles, policies and technology designed to protect our systems and data" - RMP but generic
- "The Company's Board of Directors, through its Cybersecurity Committee, is actively engaged in overseeing and reviewing the Company's cybersecurity programs and risk management" - BG

- "Although past cybersecurity incidents did not have a material impact on the Company, including our strategy, financial condition or results of operations" - SI, a backward-looking materiality assessment
- "the scope and impact of any future cybersecurity threat or incident cannot be predicted" - generic forward-looking speculation
- "See Part I, Item 1A" - cross-reference

This is genuinely split across categories. The materiality assessment is clearly SI, the board oversight is BG, and the program description is RMP but quite generic.

Looking at the text distribution: the paragraph has ERM integration, a generic program description, board oversight through the Cybersecurity Committee, a materiality assessment with forward-looking speculation, and a cross-reference. The materiality statement is the most substantive specific claim here—it's a clear Rule 5 conclusion about past impact. The board governance element is also prominent with the Cybersecurity Committee mention, but the materiality assessment and the related discussion of business impact seem to carry more weight in the paragraph overall. I'm weighing whether the materiality assessment is truly a substantive SI indicator or if the board oversight through the Cybersecurity Committee is the more distinctive disclosure here. The paragraph is fundamentally an overview that introduces the program and then highlights governance structure, so I'm leaning toward BG as the primary classification, though the materiality language and business impact framing do pull toward SI. Looking at the actual text weight, the SI-related content—materiality assessment, speculation about impact, and cross-references—spans more ground than the single sentence on board oversight, so I'm settling on SI as my classification.

For specificity, the "Cybersecurity Committee" is a named, firm-specific committee rather than a generic governance structure, which puts it at Level 3.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' by describing contractual requirements imposed ON vendors/suppliers regarding security controls and data use restrictions → TP. No domain terminology (just generic 'security controls'), no firm-specific facts, no verifiable claims — all language is generic and could appear in any company's filing.


fact: defense in depth strategy

fact: data loss prevention technology

fact: transport layer security encryption

fact: encryption for sensitive data

fact: phishing

fact: malware

fact: social engineering testing

fact: security awareness training

fact: S&T Information Security Program

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing specific security measures, training, and technologies — clearly RMP. The 'S&T Information Security Program' is a named internal program with a distinguishing identifier (firm-specific), and the paragraph is rich with domain terminology (defense in depth, DLP, TLS encryption, phishing, malware, social engineering), but lacks any QV-eligible facts such as specific numbers, dates, named external entities, or verifiable certifications.

thinking:
RMP - describes what the cybersecurity program does.

Domain terms: defense in depth, data loss prevention, encryption, transport layer security, phishing, malware, social engineering, security awareness training

Firm-specific: "S&T Information Security Program" - named internal program with distinguishing identifier

No QV facts.

Level 3.


fact: John Bresney, EVP & CIO

fact: Robert McKenna, SVP of Enterprise Strategy and Execution

fact: Christopher Cunniff, SVP and CRO

fact: Security Incident Response Plan ("IRP")

fact: employed approximately 30 years (Bresney)

fact: employed approximately 21 years (McKenna)

fact: over 27 years of technology and information security experience (McKenna)

fact: approximately six years employed (Cunniff)

fact: over 32 years of insurance industry experience (Cunniff)

fact: Certified Insurance Counselor

fact: Member of the American Academy of Actuaries

reasoning: The paragraph is entirely devoted to three named individuals' roles, qualifications, reporting lines, and career backgrounds — the person-removal test leaves nothing substantive, confirming Management Role. Multiple QV-eligible facts including named certifications verifiable via issuing bodies (Certified Insurance Counselor, Fellow of the Casualty Actuarial Society), a named university credential (Columbia University CIO Program Certificate), and specific years of experience with lower-bound thresholds.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph is about key management members' qualifications, experience, reporting lines, and responsibilities related to cybersecurity. The intro says "describes the expertise of key members of management and our committees who are responsible for assessing, managing, and presenting quarterly updates to the Board's Risk Committee about our cybersecurity risks." The bulk of the text is about three named individuals, their roles, reporting lines, qualifications, and experience.

Person-removal test: Remove all person-specific content → very little remains. This is clearly **Management Role**.

Specificity: The text includes concrete details like tenure lengths (ranging from approximately six to over thirty years), specific job titles tied to the company, named educational credentials, and quantified experience in relevant domains like technology, information security, and insurance.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing vendor cyber assessments, contractual requirements imposed on vendors, and incident notification obligations, all squarely TP. For specificity, the language describes vendor oversight processes (cyber assessments on potential vendors, contractual requirements, notification obligations) but uses no cybersecurity domain terminology that passes the ERM test — 'cyber assessments,' 'manage their cybersecurity risks,' and 'notification in the event of a cybersecurity incident' are general business/vendor management language any ERM professional could write. No firm-specific or verifiable facts are present (no named tools, frameworks, specific numbers, or unique organizational details).

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


reasoning: The paragraph answers 'what does the cybersecurity program do?' by stating the company has implemented policies, procedures, and systems to address cybersecurity risks — this is a high-level program description, placing it in RMP. However, the language is entirely generic ('policies, procedures, and systems designed to identify and address material risks') with no domain terminology passing the ERM test, no firm-specific facts, and no verifiable claims — 'confidentiality, integrity and availability' has become standard business language and the rest could appear unchanged in any company's filing.

thinking:
Let me classify this paragraph.

Content: Generic statements about recognizing importance of information security and having policies/procedures to address cybersecurity risks.

Category: "What does the cybersecurity program do?" - RMP. It describes (generically) that they have policies, procedures, and systems for cybersecurity risk management.

Specificity: Let me check for domain terms, firm-specific facts, or QV facts.
- "confidentiality, integrity and availability" - this is the CIA triad, a fundamental cybersecurity concept. However, it's become quite mainstream in business language. Let me apply the ERM test - would a non-security ERM professional use this? Actually, CIA triad is used broadly now.

The CIA triad is foundational to information security, but it's so widely used in general business contexts now that it doesn't really pass the ERM test. Everything else here—policies, procedures, systems, identifying and addressing material risks, cybersecurity incidents—is just standard business language without any specialized domain expertise or firm-specific details. This is Level 1.


reasoning: The paragraph states both a backward-looking materiality conclusion ('do not believe...materially adversely affected') and a forward-looking one ('reasonably likely to materially affect'), making it SI under the materiality assessment rule. The cross-reference to Item 1A is subordinate. No domain terminology, firm-specific facts, or verifiable claims are present — all language is standard boilerplate materiality framing.

thinking:
Let me analyze this paragraph.

It contains multiple materiality statements:
1. "We do not believe that our business strategy, results of operations or financial condition have been materially adversely affected" — backward-looking assessment → SI
2. "are reasonably likely to materially affect our business strategy, result of operations or financial condition" — forward-looking assessment (SEC Item 106(b)(2) language) → SI
3. "See Item 1A" — cross-reference, but subordinate to the assessments

This is Strategy Integration. The paragraph states conclusions about materiality both backward and forward-looking.

Specificity: Let me check for facts.

The language here is entirely generic boilerplate—no domain-specific terminology, no company-specific facts, no quantifiable details. Just standard risk language like "cybersecurity threats are pervasive." This is Level 1 materiality assessment language.


fact: Previously Disclosed Cyber Incident — named, firm-specific incident reference

reasoning: The paragraph states both a backward-looking materiality conclusion ('have materially affected us, including our results of operations and financial condition') and a forward-looking one ('reasonably likely to materially affect'), making it clearly SI under the materiality assessment rule. The cross-reference to Risk Factors is subordinate. Specificity is Level 3 because 'Previously Disclosed Cyber Incident' is a firm-specific reference to an actual named event unique to this company, but there are no QV-eligible facts (no specific dates, numbers, named external entities, or certifications).

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

Facts: "Previously Disclosed Cyber Incident" is a reference to a real incident. The paragraph states conclusions about materiality both backward ("have materially affected") and forward ("reasonably likely to materially affect"). Cross-reference to Risk Factors is subordinate.

Specificity: "Previously Disclosed Cyber Incident" - this is a firm-specific reference to an actual incident. No QV facts (no dates, numbers, named external entities, certifications). Level 3.


fact: Enterprise Risk Management Committee ('ERM Committee')

fact: SOC1 reports (third-party control attestation)

reasoning: The paragraph is framed around 'as part of our overall enterprise risk management system and processes' and describes how the company assesses, identifies, and manages cybersecurity risks, including ERM Committee review and third-party oversight — answering 'what does the program do?' The governance-chain elements (ERM Committee reporting to Audit Committee) and third-party elements (SOC1 reviews) are subordinate components of the overall process description. The named 'Enterprise Risk Management Committee (ERM Committee)' with its specific composition ('executives appointed by the Board') is a firm-specific organizational detail that elevates specificity to Level 3. SOC1 is a domain term (service organization control attestation) but the named committee drives the highest level.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph covers multiple topics. Let me break it down:
- Cross-reference to Item 1A
- ERM integration and risk assessment processes
- ERM Committee structure and reporting to Audit Committee
- Third-party risk management including SOC1 reports

The primary question: This is a mixed paragraph. It describes the overall risk management process, mentions a committee (ERM Committee), its reporting to the Audit Committee, and third-party oversight.

The "what question" test: It most directly answers "What does the cybersecurity program do?" — describing risk assessment, ERM integration, committee oversight, and third-party processes.

Looking at the structure more carefully, the paragraph's main focus is on how risks are assessed and managed through the ERM Committee, which reports to the Audit Committee, with third-party oversight as a supporting component. The governance reporting structure is secondary to the core process description. I'm reconsidering SOC 1 reports in this context—they're technically financial audit terminology rather than cybersecurity domain language, but since they're part of third-party risk assessment and in the same family as SOC 2, I'll count them as domain terminology. The ERM Committee itself is clearly firm-specific since it's a named committee appointed by the Board, not a generic governance structure. I'm looking at SOC1 reports as borderline domain terminology, and the ERM Committee qualifies as firm-specific since it's a named committee that isn't universally present at every organization, unlike generic governance roles like the Audit Committee or Board.


fact: zero-day vulnerability

fact: compromised credentials

fact: MOVEit Transfer (named file sharing software)

fact: 2023 (specific year tied to the MOVEit incident)

reasoning: The paragraph primarily describes actual cybersecurity incidents the company has experienced — unauthorized access, fraud via compromised credentials, and a named third-party vendor breach — making Incident Disclosure the dominant frame. The final sentence is a materiality assessment (SI), but the incident narrative occupies the majority of text. Specificity reaches Level 4 because MOVEit Transfer is a named external product independently verifiable, and '2023' is a specific date tied to that event.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes actual cybersecurity incidents that have occurred, their nature, and concludes with a materiality assessment.

Content Category: This is a mix of Incident Disclosure and Strategy Integration. The bulk of the text describes actual incidents (unauthorized access, fraud attempts, compromised credentials, third-party breaches, MOVEit Transfer incident). The final sentence is a materiality assessment (SI). Since the incident description dominates the text, this is **Incident Disclosure** per Rule 4.

Wait, let me reconsider. The paragraph describes a pattern of incidents rather than a single incident in detail. It describes what happened - unauthorized access, fraud attempts, compromised credentials, third-party vendor incidents, and specifically the MOVEit Transfer zero-day.

The materiality conclusion wraps up the incident frame, which clearly dominates. For specificity, I'm noting that MOVEit Transfer is a named external product that qualifies as a Quoted Value, "zero-day vulnerability" and "compromised credentials" are domain-specific terms, and the year 2023 ties to a specific event, though the vendor itself isn't named. The data types mentioned—credit card information, financial data, social security numbers—are specific categories but general in scope.

Since MOVEit Transfer is a named, externally verifiable product, this pushes the classification to Level 4.


fact: CISO

fact: CSBDO (Chief Security/Business Digital Officer)

fact: cyber incident response plan

fact: CISO has over thirty years of experience as a cybersecurity professional

fact: experience as the CISO of two large retailers

fact: CSBDO has nearly twenty years of experience enabling digital transformation

fact: cybersecurity risk insurance policy

reasoning: Person-removal test: stripping CISO/CSBDO titles, qualifications, and reporting lines leaves substantial program content — training program, incident response plan, third-party risk processes, insurance policy, security operations — so RMP wins over MR. The paragraph touches MR (qualifications), TP (vendor requirements), and SI (insurance) but the dominant frame answers 'what does the program do?' Specificity reaches Level 4 via 'over thirty years of experience' (verifiable lower bound ≥30) and 'CISO of two large retailers' (specific count), both independently checkable claims.

thinking:
Let me analyze this paragraph carefully.

This is a dense, multi-topic paragraph. Let me break it down:

1. "We place a high priority on securing confidential business information..." - generic intro
2. "We have systems in place to securely receive and store that information and to detect, contain, and respond to cybersecurity incidents." - RMP
3. "We also have processes to manage risk from cybersecurity threats associated with third parties, including service providers, such as risk assessments and contractual requirements that include cybersecurity measures." - TP element
4. "we have a cybersecurity and information security training and compliance program" - RMP

5. VF's training requirements for employees with access to confidential data happen at least annually, and the company maintains a comprehensive program overseen by the CISO and CSBDO that's designed to protect information confidentiality, integrity, and availability—including a formal incident response plan. The CISO brings over thirty years of cybersecurity experience including prior roles at major retailers, reports to the CSBDO who manages digital and technology operations with nearly two decades of experience, and the broader information security, IT, and privacy teams round out the leadership structure.

12. Beyond internal capabilities, VF works with external service providers and consultants, and maintains a cybersecurity risk insurance policy to further mitigate exposure.

The core question remains: what does the program actually do? Even stripping away the named roles and their qualifications, the description still covers substantial operational ground—training cadences, incident response procedures, third-party vetting. That points toward RMP rather than just SI.

Looking at the quantified facts more carefully: "over thirty years" is a solid lower bound, clearly verifiable. "Nearly twenty years" is softer—it's hedged language suggesting approximately 18-19 rather than a precise threshold. The codebook treats "over" as a clear quantified fact, while "nearly" falls into that approximation category. So I'm counting "over thirty years" as QV, but "nearly twenty" is borderline.

The CISO and CSBDO titles are firm-specific roles, which supports the RMP classification. Given the "over thirty years" quantified fact, this lands at Level 4.