reasoning: The paragraph covers multiple topics (employee training, cyber insurance, vendor contract procedures) but the dominant content is the company's own internal cybersecurity processes — training requirements and formal procedures. The cyber insurance mention is brief (one sentence, no details), and the vendor contract language describes the company's own procedures applied to vendors rather than centering vendor oversight as the primary topic. No named frameworks, no IS-list facts (no cybersecurity-specific titles, no named firms/tools, no specific dates or numbers), so it remains Generic Boilerplate.

thinking:
Let me analyze this paragraph from Nestor Partners' 10-K filing, Item 1C.

Content: Training requirements, third-party designed training, cyber insurance, formal cybersecurity procedures for vendor contracts.

Category: This covers multiple topics - training (Risk Management Process), cyber insurance (Strategy Integration), vendor contract procedures (Third-Party Risk). The dominant theme is a mix of internal processes. Let me assess:
- Employee training → Risk Management Process
- Training designed by third-party → Risk Management Process (third party serves the company)
- Cyber insurance → Strategy Integration

- Formal cybersecurity procedures for vendor contracts → Third-Party Risk

This is a mixed paragraph with internal processes as the primary focus. Counting the content, Risk Management Process appears twice with training-related items, while Strategy Integration and Third-Party Risk each appear once. That makes Risk Management Process the dominant category here.

Now checking for specific details - I see references to "General Partner" as a self-reference and "third party service provider" mentioned without naming them specifically.  The cyber insurance is brought up but without concrete details, and the training cadence is just described as "annual" without anything more concrete. There are no named frameworks, no specific roles, no dates, and no numbers. This is generic boilerplate language without substantive facts.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company's internal cybersecurity training programs and use of technology-based tools to mitigate risk — all internal processes. No named frameworks, tools, roles, dates, or any firm-specific details are provided; the language is entirely generic and could apply to any company.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Classify this paragraph.

Content: Describes internal cybersecurity training and technology tools - these are internal processes. No board, no management person, no third-party focus, no incident, no materiality assessment.

Category: Risk Management Process

Specificity: No named frameworks, no named tools, no named roles, no specific facts. Generic practices described. → Generic Boilerplate


content_category: Board Governance

reasoning: The Audit Committee is the grammatical subject throughout, overseeing cybersecurity risk and receiving briefings from management — classic Board Governance. No IS-list facts are present: 'Audit Committee' is generic, 'annual' is a generic cadence, 'management' is generic, and the listed topics (data security posture, third-party assessments, incident response plan) are common practices without named frameworks, specific roles, or firm-specific details.

thinking:
Let me analyze this paragraph.

Content: The Audit Committee oversees cybersecurity risk. Management provides annual overview to Audit Committee. Topics covered include data security posture, third-party assessments, risk mitigation goals, incident response plan, threat risks. Audit Committee receives cybersecurity briefing materials.

Category: The Audit Committee (board committee) is the grammatical subject throughout. This is about board/committee oversight. → Board Governance

Specificity: Let me check facts:
- "Audit Committee" — generic, on the NOT list

- "annual basis" — generic cadence
- "management" — generic
- Topics listed are generic practices
- No named roles (CISO, CIO), no named frameworks, no specific dates, no named firms

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


reasoning: The paragraph describes the company's internal cybersecurity risk management program, its framework alignment, and ERM integration — all hallmarks of Risk Management Process. It names NIST 800-171 and references 'international bodies,' but provides no firm-specific facts (no named roles, dates, tools, or headcounts), placing it at Sector-Adapted.

thinking:
Classify this paragraph.

Content: Describes the company's cybersecurity risk management program, framework adoption (NIST 800-171), ERM integration. This is about internal processes.

Category: Risk Management Process

Specificity: Names NIST 800-171 specifically. No firm-specific facts beyond that. "international bodies" is vague. No named roles, no specific dates, no headcounts.

Decision test:
1. Two+ hard verifiable facts? No.
2. IS list fact? NIST 800-171 is a named framework → but wait, is naming a framework a ✓ IS fact? Let me check...

The paragraph mentions NIST 800-171 as a named standard, which falls under Sector-Adapted rather than a firm-specific fact. There's nothing beyond the framework reference that would constitute company-specific information.

Specificity: Sector-Adapted

fact: NIST Cybersecurity Framework (800-171)

type: framework


content_category: Strategy Integration

reasoning: The paragraph opens with generic risk acknowledgment but its substantive content is a materiality assessment: the company has not experienced a material cybersecurity incident and is not aware of third-party providers experiencing one. Per Rule 6, explicit materiality conclusions are Strategy Integration. No named standards, specific dates, firm-specific facts, or hard verifiable details are present.

thinking:
Let me analyze this paragraph.

The paragraph has two parts: (1) generic risk acknowledgment about cyber threats, and (2) a materiality assessment - "we have not experienced a material cybersecurity incident."

The second part is a materiality disclaimer → Strategy Integration per Rule 6.

Specificity: "To date, we have not experienced a material cybersecurity incident" - this is boilerplate materiality language. No named standards, no specific facts from the IS list. → Generic Boilerplate.


content_category: None/Other

reasoning: This paragraph describes the career history of a Senior Vice President responsible for the AFP business segment. It contains no cybersecurity disclosure content whatsoever — it appears to be erroneously extracted executive biography text unrelated to Item 1C cybersecurity disclosure.

thinking: This is about a Senior Vice President's career history at Eastman Chemical, but it's about the AFP (Advanced Films and Polymers?) segment - not cybersecurity at all.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment methodology in three parts (asset identification, criticality assessment, threat/impact assessment) and references choosing security controls — all squarely Risk Management Process. Despite the detailed structure, it names no specific framework (only 'an internationally recognized information security framework'), no tools, no dates, no roles, and no firm-specific facts. The three-part methodology described is standard risk assessment practice that could apply to any company.

thinking:
Classify this paragraph.

Content: Describes a three-part risk assessment process - asset identification, criticality assessment, threat impact assessment. Then mentions using "an internationally recognized information security framework" without naming it.

Category: Risk Management Process - clearly about internal processes/methodology.

Specificity: No named framework (says "internationally recognized" but doesn't name it), no firm-specific facts, no dates, no names. Everything described is generic risk assessment methodology. → Generic Boilerplate (1)


reasoning: The Board of Directors and its named committees (RAC, TEC) are the grammatical subjects providing direction and oversight of cybersecurity risk management, making this Board Governance. The CISO is mentioned only in the context of reporting to these committees. Multiple named non-generic committees (RAC, TEC, plus management-level committees) and the CISO role qualify as firm-specific facts, but none are QV-eligible (no dates, dollar amounts, headcounts, named firms, or named tools), so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Board of Directors oversight through RAC and TEC committees, quarterly meetings, management committees, CISO reporting.

Category: Board Governance - the Board/committees are the grammatical subject performing oversight.

Specific facts:
- Risk Assessment ("RAC") Committee - named non-generic committee ✓
- Technology ("TEC") Committee - named non-generic committee ✓
- CISO mentioned - cybersecurity-specific role ✓
- Enterprise Risk Management, Operational Risk Management, Technology Management committees
- "quarterly" - generic cadence, NOT list

QV check: Named committees (RAC, TEC) are firm-specific but not QV-eligible.

The CISO role is firm-specific but doesn't meet QV criteria since there are no dates, dollar amounts, headcounts, named third-party firms, tools, or certifications mentioned. This lands it at Firm-Specific (3) due to the multiple IS-list facts like the named committees and CISO position.

fact: Risk Assessment ('RAC') Committee

fact: Technology ('TEC') Committee

fact: Chief Information Security Officer ('CISO')

fact: Enterprise Risk Management, Operational Risk Management, and Technology Management committees


reasoning: The paragraph makes an explicit materiality assessment ('have not encountered cybersecurity incidents or identified risks... that have materially impaired our operations or financial standing'), which per Rule 6 is Strategy Integration even though a cross-reference to Risk Factors follows. The cross-reference does not change the classification. No firm-specific facts are present — the Risk Factor title is generic boilerplate language, and 'Item 1A' is a standard filing cross-reference.

thinking: Materiality assessment + cross-reference. Per Rule 6, the materiality assessment is the substantive content.


content_category: Management Role

reasoning: The paragraph is primarily about management personnel — the CIO's qualifications (35 years experience, MIS degree), the CISO's reporting line to the CIO, the CFO's incident oversight role, and the organizational hierarchy of the Information Security Department. While it briefly mentions 'assessing and managing material risks,' the dominant content is about who the people are and how they relate to each other (person, not function). Specificity is Firm-Specific: CISO and CIO are cybersecurity-specific roles (IS-list), and 35 years of experience is a specific number, but only one QV-eligible hard fact (the degree lacks a named university), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the Information Security Department structure, reporting lines (CISO → CIO), team composition, CIO's qualifications (35 years experience, MIS degree), CISO's reporting to CIO and CFO, CFO's incident oversight role, quarterly executive discussions.

Category: This is primarily about management roles and their qualifications/reporting lines. The paragraph describes WHO the people are (CIO's experience and degree), reporting structure (CISO reports to CIO, CISO informs CIO and CFO), and organizational hierarchy. While there's some process mention ("assessing and managing material risks"), the dominant content is about the people and their roles.

Now I'm applying the person-versus-function test to determine if this qualifies as a management role category. The content focuses on the CIO's specific experience and credentials, the reporting chain between CISO and CIO, and who holds responsibility—all indicators this is about people and their positions rather than processes or frameworks. Looking at what's quantifiable and specific: the CIO's 35 years of experience is a concrete number that would be QV-eligible, while the MIS degree and CFO reference are too generic to qualify.

fact: Chief Information Security Officer (CISO)

fact: Chief Information Officer (CIO)

fact: 35 years of experience (CIO)

type: quantified

fact: degree in Management Information Systems


reasoning: The paragraph's primary content is about the people filling cybersecurity leadership roles — their titles (Acting CISO, Acting CIO), combined experience (30 years), reporting structure (CISO reports to CIO), and committee membership (ERMC). While the final sentence describes ERMC functions, the dominant purpose is identifying who is responsible and their qualifications. Only one QV-eligible hard fact (30 years of experience); named roles and named committee are firm-specific but not QV-eligible, so this is Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph discusses management roles (Acting CISO, Acting CIO) and their responsibilities, reporting lines, and experience. It also mentions the ERMC committee.

**Content Category Analysis:**

The paragraph starts by identifying the management members responsible for cyber risk - Acting CISO and Acting CIO. It describes:
- Combined 30 years of experience
- Acting CISO's responsibility and reporting line to Acting CIO
- Acting CIO's membership in ERMC
- ERMC's ultimate responsibility

The primary focus is on WHO these people are (their roles, experience, reporting structure). But then it shifts to the ERMC's responsibilities.

Now I'm testing whether this is really about people or processes - if I strip away the titles and credentials, what's left? The experience levels and reporting structure are clearly about the individuals themselves. The ERMC piece is about committee oversight, but since ERMC is a management committee rather than a board-level body, the whole thing falls under Management Role rather than Board Governance.

Looking at the specificity, I've got named roles (Acting CISO and Acting CIO), a quantified fact (over 30 years combined), and a named committee. Only the experience number qualifies for QV purposes, so despite having multiple IS facts, this lands as Firm-Specific.

fact: Acting Chief Information Security Officer

fact: Acting Chief Information Officer

fact: over 30 years of combined experience in managing cybersecurity

fact: ERMC (Enterprise Risk Management Committee)


reasoning: The paragraph is primarily about the people — the CISO's and CIO's experience, qualifications, and background — making it Management Role under the person-vs-function test. Two QV-eligible hard facts (specific years of experience: 10+ and 15+) meet the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes CISO and CIO - their responsibilities, experience, qualifications, education. The paragraph is about the people (CISO, CIO) - their experience, background, credentials.

Person-vs-function test: If I remove the people's titles, credentials, and experience, what's left? "is responsible for assessing and managing our material risks from cybersecurity threats and has primary responsibility for our overall cybersecurity risk management program and supervising both our internal cybersecurity personnel and our retained external cybersecurity consultants." - This is somewhat about function, but the bulk of the paragraph is about who these people are and their qualifications.

The paragraph breaks down into the CISO's role description in the opening, then shifts to detailing both executives' backgrounds—the CISO brings over a decade of cybersecurity experience plus a computer science degree, while the CIO has 15+ years across multiple relevant domains. Since the focus is clearly on their qualifications and experience rather than their functional responsibilities, this falls under Management Role.

Looking at what qualifies as Quantified-Verifiable: the "more than 10 years" and "over 15 years" are both specific numerical claims about experience that can be verified, so that's two QV-eligible facts pointing toward a Quantified-Verifiable classification.

fact: CISO

fact: CIO

fact: more than 10 years of experience in cybersecurity and information technology risk management

fact: over 15 years of information technology experience


reasoning: The paragraph describes Everest's internal cybersecurity processes: threat intelligence, multi-layered protections, SOC operations, incident escalation protocols, and testing methodologies. The CISO is mentioned only as part of the escalation chain—an incidental attribution—making this about the function, not the person. The NIST framework is named (Sector-Adapted), and the CISO title is a cybersecurity-specific role on the IS list, elevating to Firm-Specific. However, no QV-eligible hard facts (dates, dollar amounts, named third-party firms, named tools/products) appear, so it does not reach Quantified-Verifiable.

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

Content: Describes multi-layered cybersecurity process, threat intelligence, security tools/protections, SOC operations, incident response protocols, testing methods, and NIST assessments.

Category: This is clearly about the company's internal cybersecurity processes - Risk Management Process. The CISO is mentioned incidentally as part of escalation, not as the focus.

Specificity: Let me check for facts:
- SOC (Security Operations Center) - generic term
- CSIRT - generic term
- CISO - cybersecurity-specific role (IS list) → firm-specific fact

- NIST - named framework → sector-adapted
- Various security practices described (pen testing, phishing tests, red team exercises, vulnerability scans) - common practices, NOT list

I'm identifying the firm-specific facts here: CISO appears as a cybersecurity-specific title, and NIST is a named framework. There are no specific dates, dollar amounts, headcounts, named third-party firms, named products, or certifications mentioned, so this doesn't qualify as QV-eligible. Since there's at least one IS fact present, this falls under Firm-Specific.

fact: CISO (Chief Information Security Officer) mentioned in escalation chain

fact: NIST assessments conducted annually


content_category: Incident Disclosure

reasoning: The paragraph describes an actual cybersecurity incident — the AMCA breach — with a specific date and named external party, making it Incident Disclosure. Two hard verifiable facts (exact date + named third-party firm) qualify it as Quantified-Verifiable. The cross-references and litigation mentions are subordinate to the incident narrative.

thinking:
Let me analyze this paragraph.

Content: Describes a past cybersecurity incident (AMCA breach from 2019) - specific date, named third party, what happened, and then cross-references to other sections.

Category: This describes an actual cybersecurity incident - the AMCA breach. It gives the date, the entity involved, what happened (security incident involving personal information), and mentions ongoing litigation. The primary content is about what happened in the incident. → Incident Disclosure

Specificity:
- Specific date: May 14, 2019 ✓ (QV-eligible)

- Named third-party firm: AMCA / Retrieval-Masters Credit Bureau ✓ (QV-eligible)

I've identified two concrete, verifiable facts here that qualify this as Quantified-Verifiable content.

fact: Retrieval-Masters Credit Bureau, Inc. d/b/a American Medical Collections Agency (AMCA)


category_confidence: medium

reasoning: The paragraph primarily describes the management committee structure for cybersecurity: delegation from the Enterprise Risk and Return Council to the ISC, the CISO chairing it, and its cross-functional composition. While the ISC's functions are mentioned (monitoring, escalating, sponsoring controls), these are subordinate to the organizational structure description. Multiple firm-specific facts (named committees with unique identifiers, CISO role, specific departmental composition) but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms/tools).

thinking:
Let me analyze this paragraph.

Content: Describes the ISC committee structure, its delegation from Enterprise Risk and Return Council, CISO chairing it, membership composition, and what the ISC does (monitors, mitigates, escalates risks, sponsors controls, oversees policy).

Category: This is about management-level committees and their cybersecurity functions. The CISO chairs the ISC, and the paragraph describes what the ISC does. The primary actor is the ISC (a management committee), not the board. This is about management structure and function.

Person-vs-function test: The paragraph mentions the CISO but is primarily about what the ISC does (monitors, makes decisions, escalates, provides sponsorship, oversees).

The ISC is fundamentally a management committee with defined responsibilities—it's about organizational structure and who's accountable for cybersecurity governance, which maps to Management Role in the codebook. C does. The person-vs-function test: if I remove CISO and the committee structure, the remaining content is about monitoring risks, making decisions, sponsoring controls, overseeing policy - that's process stuff. But the primary content IS the committee structure and delegation chain.

I think this is Management Role because:
- It's about the management committee structure (ISC)
- CISO chairs it
- Composition described
- Delegation from Enterprise Risk and Return Council

The process description (monitors, escalates, sponsors) is subordinate to the organizational structure.

Specificity:
- CISO: cybersecurity-specific title → IS list ✓
- "Information Security Council ('ISC')": named internal program with unique identifier → IS list ✓
- "Enterprise Risk and Return Council": named non-generic committee → IS list ✓
- "Privacy, Legal and Technology": specific team composition → IS list ✓

Now checking what's actually quantifiable: CISO and ISC are named roles and committees, which aren't eligible for QV scoring. Same with the Enterprise Risk and Return Council and team composition details. There are no dates, financial figures, headcounts, vendor names, tool references, or certifications mentioned. So while I have multiple firm-specific facts, none of them reach the threshold for QV eligibility.

fact: Enterprise Risk and Return Council delegates to ISC

fact: Information Security Council (ISC)

fact: CISO chairs the ISC

fact: Representatives from Privacy, Legal and Technology


reasoning: The paragraph describes the company's internal cybersecurity processes: threat detection, monitoring, incident response escalation, penetration testing, vulnerability scanning, and framework assessments. The CISO is mentioned incidentally as part of the escalation path, not as the subject — the paragraph is about the function/process, not the person. The CISO title (a cybersecurity-specific role on the IS list) elevates specificity above Sector-Adapted to Firm-Specific, but there are not two QV-eligible hard facts (CISO is a named role, not QV-eligible; no named third-party firms, dates, dollar amounts, or tools).

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

Content Category: This paragraph describes the company's internal cybersecurity processes - risk assessment, threat detection, monitoring, incident response, testing. The CISO is mentioned incidentally as part of the escalation chain. The paragraph is about the function/process, not the person. → Risk Management Process

Specific facts:
- SOC (Security Operations Center) - this is a generic term, not firm-specific
- IRT (Incident Response Team) - generic
- CISO mentioned - cybersecurity-specific role → IS list

- NIST assessments referenced as a named framework, conducted annually and independently → this pushes us to Firm-Specific level since we have a named cybersecurity role and a specific control framework being used

QV check: CISO is a named role but not quantifiable. NIST is a framework reference, also not quantifiable. No dates, dollar amounts, headcounts, third-party vendors, or product names that would qualify as hard verifiable facts.

The SOC and IRT are just generic terms, and while "specialized third-party service providers" is mentioned, they're not named. So the specificity lands at Firm-Specific due to the CISO reference combined with the named NIST framework.

fact: Chief Information Security Officer (CISO) referenced in escalation chain


reasoning: The paragraph's primary purpose is identifying which management roles and teams are responsible for cybersecurity risk — General Counsel and Assistant GC drive the program, legal/compliance works with IT leaders. This is organizational responsibility assignment (management structure), not a description of processes or tools. However, no cybersecurity-specific titles (CISO, CTO, CIO) are named — General Counsel, CEO, and 'IT leaders' are all on the NOT list — and no credentials, background, named individuals, dates, or numbers appear, leaving specificity at Generic Boilerplate.

thinking:
Let me analyze this paragraph.

The paragraph describes who drives the cybersecurity program and who is responsible for risk management. Let me apply the person-vs-function test.

Content: General Counsel and Assistant General Counsel – Compliance drive the program. Executive leadership team including CEO and management team are responsible for identifying/assessing/managing/mitigating risks. Legal and compliance team works with IT leaders on cybersecurity risks.

This is about management's role in cybersecurity - but is it about the person or the function?

The paragraph doesn't describe qualifications, credentials, or background of any individual. It describes organizational responsibility and how teams work together. But the primary focus is on WHO is responsible (management roles and teams) rather than WHAT processes they use.

These are generic titles like General Counsel and CEO rather than specific individuals, and the focus is on what these roles do—identify, assess, manage, and mitigate risks. This is fundamentally about organizational structure and responsibility assignment for cybersecurity oversight, not about particular people or their backgrounds. Looking at the specifics here - the paragraph describes who's responsible for cybersecurity governance and how teams coordinate, which points toward Management Role. The roles mentioned aren't cybersecurity-specific titles like CISO, and some are on the exclusion list, but the core content is about organizational responsibility assignment and team structure for the cybersecurity program. The "legal and compliance team" working with IT leaders describes a specific team composition rather than individual credentials or career history, which keeps it borderline but leans toward Management Role as the primary classification. I'm weighing whether the specific organizational structure—with an Assistant General Counsel for Compliance driving the cybersecurity program alongside IT leaders—is distinctive enough to count as firm-specific, or if it's just generic boilerplate since these roles and team compositions are fairly standard across companies. The lack of cybersecurity-specific titles like CISO or CTO pushes me toward classifying this as Management Role, Generic Boilerplate. The reporting structure is explicitly mentioned here—the General Counsel drives the program with legal and compliance working alongside IT—so this fits Management Role. Since all the titles are generic and there are no cybersecurity-specific roles, standards, or numerical details, I'm categorizing this as Generic Boilerplate.


reasoning: This is a materiality assessment stating that no cybersecurity incident has materially affected the company's business strategy or financial condition. Per Rule 6, materiality disclaimers are Strategy Integration. The language is boilerplate with no specific facts beyond the company's own name (which is on the NOT list).


reasoning: The paragraph describes an actual ransomware incident: its timing (July 2018), affected systems (Dx IT systems), scope of investigation (no data exfiltration), and outcome. While it ends with a materiality conclusion, the dominant content is the incident narrative. Specificity is Firm-Specific: July 2018 is one QV-eligible date and 'Dx information technology systems' is firm-specific, but there is only one hard verifiable fact (the date), falling short of the two needed for Quantified-Verifiable.

thinking:
Classify this paragraph.

Content: Describes a past ransomware incident - date, what was affected, investigation findings, materiality conclusion.

The paragraph describes what happened (ransomware incident, July 2018, affected Dx IT systems, investigation determined no data theft), and ends with a materiality statement. The dominant content is the incident narrative - timeline, scope, investigation findings. The materiality sentence is one closing line.

Category: Incident Disclosure (describes what happened - date, systems affected, investigation findings, response). The materiality conclusion at the end is subordinate.

Now I'm checking the specificity of the facts mentioned. The July 2018 date is specific enough to qualify, but the reference to Dx information technology systems is firm-specific without being QV-eligible. There's no third-party names, tools, dollar amounts, or headcounts. With just one QV-eligible fact, this falls into the Firm-Specific category.

fact: July 2018

fact: Dx information technology systems (company-specific business segment)


reasoning: The paragraph describes internal cybersecurity processes — framework adoption (CIS), audits, vulnerability testing, governance assignments, and training — making it Risk Management Process. The Cybersecurity Department is the actor but the content is about what the program does (function), not about the people (person). Specificity is Firm-Specific: naming CIS reaches Sector-Adapted, and the existence of a dedicated 'Cybersecurity Department' is a firm-specific organizational fact, but there are no two hard verifiable facts (no dates, dollar amounts, headcounts, named firms/tools) to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the Cybersecurity Department's use of CIS framework, policies, controls, audits, vulnerability testing, governance assignments, and training.

Category: This is about internal cybersecurity processes - framework adoption, vulnerability testing, audits, training. The "Cybersecurity Department" is the subject but it's describing what the department DOES (processes), not who the people are. → Risk Management Process

Specificity:
- Names CIS framework → Sector-Adapted at minimum
- "Cybersecurity Department" - this is a named department/team, could be firm-specific

- "typically every three years" is a generic cadence
- No named individuals, specific dates, dollar amounts, or named tools

Wait, "Cybersecurity Department" is a firm-specific organizational unit - they have a dedicated department with that title, which is analogous to cybersecurity-specific titles like CISO or named committees like Cybersecurity Committee. That's a firm-specific fact on its own.

So this lands at Firm-Specific (3).

Now checking for QV: I have one IS fact (the Cybersecurity Department) plus the CIS framework mention, but no hard verifiable facts like specific dates, dollar amounts, headcounts, named third-party firms, or named products. "Every three years" is too generic. This doesn't meet the QV threshold.

The classification is Firm-Specific, with the Cybersecurity Department as the named organizational unit and CIS framework as the methodology reference.

fact: CIS (Center for Internet Security) framework used as benchmark

fact: Dedicated Cybersecurity Department


reasoning: The paragraph describes the company's Incident Response Plan — its structure, protocols, testing, and alignment with crisis management. The CITO and CIRO are mentioned as attribution for who leads the plan's review, but the substantive content is about the process itself (person-vs-function test: remove the titles and the paragraph still describes the IR Plan). Two cybersecurity-specific roles (CITO, CIRO) make it Firm-Specific, but named roles do not count toward QV.

thinking:
Let me analyze this paragraph.

Content: Describes an Incident Response Plan, its alignment with crisis management, what it covers, and who leads it (CITO and CIRO).

Category: This is about internal processes - the IR Plan, its framework, requirements, reporting processes, protocols. The CITO and CIRO are mentioned as attribution for who leads the review/testing. The person-vs-function test: remove the titles and the paragraph is still about the IR Plan. → Risk Management Process.

Specificity:
- "Incident Response Plan (IR Plan)" - named internal program with unique identifier? It's a generic name with abbreviation.

The codebook distinguishes between "Cyber Incident Response Plan (CIRP)" which qualifies and generic "incident response plan" which doesn't, so "IR Plan" falls on the generic side. However, the titles "Chief Information and Technology Officer (CITO)" and "Chief Information Risk Officer (CIRO)" are cybersecurity-specific and firm-specific variants, pushing this toward Firm-Specific. No quantifiable metrics like dates, dollar amounts, headcounts, or named tools appear, so this doesn't meet QV criteria.

Specificity: Firm-Specific (3).

fact: Chief Information Risk Officer (CIRO)


reasoning: The paragraph describes the company's internal cybersecurity risk identification processes — risk assessments, roles/responsibilities matrix, threat intelligence sharing, employee training, and usage policies. All of these are common practices described in generic terms with no named frameworks, tools, firms, roles (CISO/CIO), dates, or quantified details. Vendors are unnamed ('leading security and technology vendors'), consortiums are unnamed ('various consortiums'), and cadences are vague ('periodically', 'several times a year').

thinking:
Let me analyze this paragraph from First Industrial LP's 10-K filing, Item 1C.

Content: Describes the "Identify" phase of their cybersecurity risk management process, including risk assessments, roles/responsibilities matrix, threat intelligence sharing, employee training, and computer usage policy.

Category: This is clearly about the company's internal cybersecurity processes - risk assessments, training, policies. → Risk Management Process

Specificity: Let me check for specific facts:
- "leading security and technology vendors" — unnamed, NOT specific
- "periodically" — generic cadence

- "various consortiums, associations and groups" — unnamed
- "several times a year" — vague
- No named frameworks, no named tools, no specific dates, no named firms, no specific roles like CISO

Nothing from the IS list. No named standards. This is Generic Boilerplate - describes common practices without any firm-specific detail.


reasoning: The paragraph's primary subject is the Board and Audit Committee's oversight structure, including delegation to a named Cybersecurity Steering Committee — all Board Governance. Contains multiple IS-list facts (named non-generic committee, cybersecurity-specific roles CISO/CIO, specific departmental composition, named individuals), making it Firm-Specific. Only one QV-eligible fact (headcount of three directors) — named individuals and named roles don't count toward the two-fact QV threshold — so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content Category: This is about Board/committee oversight. The Board delegates to Audit Committee, which established a Cybersecurity Steering Committee. The grammatical subjects are Board, Audit Committee, and the Cybersecurity Steering Committee. This is Board Governance.

Specific facts:
- Cybersecurity Steering Committee (named non-generic committee)
- Three independent directors named: Laura Black (Chair), Douglas Gilgilstrap, Joanne Solomon
- CIO and CISO mentioned (cybersecurity-specific roles)
- Specific team composition: legal, finance, and internal audit

- The three named directors are verifiable facts, and the headcount of "three independent directors" qualifies as QV-eligible, though the individual names themselves aren't explicitly on the standard QV list.
- For IS facts, I'm looking at the Cybersecurity Steering Committee as a named non-generic committee, plus the specific titles (CIO, CISO) and team composition details across legal, finance, and internal audit.
- The named individuals—Laura Black, Douglas Gilstrap, Joanne Solomon—are verifiable, but the codebook doesn't explicitly list "named individuals" as QV-eligible, so I'm sticking strictly to what's defined.
- That leaves just the headcount of three independent directors as the single QV-eligible fact, which means this falls into Firm-Specific territory.

fact: Cybersecurity Steering Committee

fact: Three independent directors named: Laura Black (Chair), Douglas Gilstrap, Joanne Solomon

fact: Chief Information Officer (CIO)

fact: Chief Information Security Officer (CISO)

fact: Team composition: legal, finance, and internal audit


reasoning: The paragraph primarily describes an actual ransomware incident—its detection date, nature (ransomware affecting internal systems), and response actions (containment, business continuity, restoration). While it opens with a generic sentence about controls, the dominant content is the incident narrative. One QV-eligible hard fact (specific date May 4, 2022) places this at Firm-Specific; no second hard verifiable fact prevents Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes physical/technical/admin controls briefly, then describes a ransomware incident from May 4, 2022 - detection, containment, restoration.

Category: The dominant content is about the incident - what happened, when, response actions. → Incident Disclosure

Specific facts:
- "May 4, 2022" - specific date
- "ransomware" - specific attack type (but this is standard incident language)

Wait, let me check: "May 4, 2022" is a specific date (QV-eligible).

"Ransomware" is just describing the incident type, not a QV-eligible fact. No named firms, no named tools, no dollar amounts, no headcounts. That leaves only the specific date as QV-eligible, so this falls under Firm-Specific (3).


reasoning: The paragraph describes internal cybersecurity processes — asset protection, environment monitoring, analysis, remediation, vendor-led vulnerability testing, and incident response planning. These are all standard risk management activities. No named frameworks, no named roles, no named vendors ('outside vendors' is generic), no dates, no specific tools or numbers — entirely generic language that could apply to any company.

thinking:
Let me analyze this paragraph from VanEck Bitcoin ETF's 10-K filing.

This describes internal cybersecurity processes - monitoring, analysis, remediation, reporting, vulnerability testing, incident response planning. It's about what the company does for cybersecurity risk management.

No named frameworks, no named roles, no dates, no specific tools, no named vendors ("outside vendors" is generic). This is generic boilerplate describing standard security practices.


reasoning: The paragraph describes remediation actions taken after an actual cybersecurity event ('Following this cybersecurity event... key learnings from the incident'), making it Incident Disclosure per the codebook's inclusion of incident response actions. While the remediation measures described (zero trust, MFA, PAM, EDR, awareness training) are substantive, they are all described in generic terms without named products/tools, specific dates, named firms, or quantified metrics, resulting in Generic Boilerplate specificity.

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

Content: Describes post-incident remediation actions - three-pronged approach, zero trust, security awareness training, MFA, PAM, EDR implementation.

Category: This describes what happened after a cybersecurity incident - the remediation actions taken. It's describing incident response/remediation, which falls under Incident Disclosure (response actions to an actual incident). But it's also describing risk management processes that were implemented. The paragraph references "this cybersecurity event" and "the incident" - so it's tied to an actual incident.

Looking at the specificity here, I'm checking for concrete details - there are no named tools, dates, dollar amounts, or specific headcounts. The remediation measures mentioned like zero trust, multifactor authentication, PAM, and EDR are all standard industry practices without any particular implementation details or named standards referenced. This falls squarely into Generic Boilerplate territory.


reasoning: The paragraph's primary content describes what the Compliance Committee does — reviewing security metrics, identifying risks, assessing enhancements, making recommendations, and escalation processes. Applying the person-vs-function test: replacing 'The Compliance Committee' with 'The Company' leaves the paragraph intact as a process description. The CIO is mentioned incidentally as part of the committee composition, not as the subject of credential or background disclosure. The named Compliance Committee (non-generic, firm-specific organizational structure) and CIO title each qualify as IS-list facts, but neither is QV-eligible, yielding Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes a cross-functional Compliance Committee with CIO, their responsibilities, meeting cadence, what they review, escalation processes, and monitoring protocols.

Category: This is about management's role in cybersecurity. The Compliance Committee is a management-level committee (not a board committee). But let me think - is this about the person or the function? The paragraph describes what the committee DOES - assessing risks, reviewing metrics, making recommendations, escalation processes. This is more about the function/process than about individuals' credentials.

Actually, the primary subject is the Compliance Committee - a management committee. It describes what the committee does (processes, reviews, recommendations).

I'm trying to determine whether this is fundamentally about the management structure overseeing cybersecurity or the actual processes they execute. The paragraph opens with the committee's composition and structure, then details their activities like risk assessment and metric review. The codebook distinction matters here—Management Role focuses on who's responsible, while Risk Management Process focuses on what gets done. This feels like it's primarily about the oversight structure itself, with the processes being secondary to establishing that management layer. I'm going back and forth on this. The codebook says Management Role is about who people are—their background, credentials, experience, reporting structure. This paragraph doesn't really do that; it describes what the Compliance Committee does and how it operates. The activities and processes are the main focus here, which points toward Risk Management Process. I'll go with that since the dominant content is about the oversight activities and procedures, not about characterizing the people involved.

Now I'm checking the specificity markers. "Compliance Committee" seems firm-specific enough—it's not a generic committee like Audit Committee, and it's not on the exclusion list. "CIO" is definitely on the cybersecurity-specific titles list. "Quarterly" is just a standard cadence, so that's generic. I'm tallying up which elements count as specific.

fact: Compliance Committee (named management committee overseeing cybersecurity)


reasoning: The paragraph contains generic language about experiencing attempted breaches (common to all companies), a forward-looking disclaimer about future assurance, and a pure cross-reference to Risk Factors with no materiality assessment. No actual incident is described (attempts were prevented), no processes or frameworks are detailed, and no substantive cybersecurity disclosure content is present.

thinking:
Let me analyze this paragraph.

Content: Describes generic past attempts to breach systems, says they were prevented, disclaims future assurance, cross-references Risk Factors.

Category: No actual incident disclosed (attempts were prevented). No materiality assessment. It's generic risk language with a cross-reference. This is None/Other - it's general business language about threats without substantive disclosure.

Wait - let me reconsider. It mentions experiencing efforts to access/breach systems that were prevented. This isn't really an incident disclosure (no actual breach). It's not a materiality assessment. It's generic risk language + cross-reference. → None/Other.

The language here is completely generic with no specific standards cited or company-specific details—just standard boilerplate risk disclaimers.


reasoning: The paragraph describes the company's internal cybersecurity processes: team structure, safeguards (firewalls, monitoring, training), third-party maturity assessments, and NIST CSF alignment. The CIO is mentioned as attribution for who leads the team, but the substantive content is about what the program does — passing the person-vs-function test for Risk Management Process. The CIO title (a cybersecurity-specific role on the IS list) elevates specificity beyond Sector-Adapted to Firm-Specific, but there is only one QV-eligible fact, so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes DTE Energy's cybersecurity program - dedicated team led by CIO, safeguards (firewalls, monitoring, training), third-party assessments, NIST CSF framework usage.

Category: This is about the company's internal cybersecurity processes. The CIO is mentioned as attribution ("led by the Chief Information Officer") but the paragraph is about what the program does. Person-vs-function test: remove "led by the Chief Information Officer" and the paragraph still describes processes. → Risk Management Process.

Now I'm checking what counts as a specific fact here. The CIO title is cybersecurity-specific and appears on the IS list, so that's one firm-specific fact. NIST CSF is a named framework that qualifies as sector-adapted. The unnamed third parties and generic practices like firewalls don't add specificity. With just the CIO as a hard fact, this lands in Firm-Specific, not QV.

fact: Chief Information Officer leads the cybersecurity team

fact: NIST Cybersecurity Framework (CSF)


reasoning: The paragraph describes internal cybersecurity processes: regular review meetings with IT management teams and a global incident response plan with escalation protocols. Although the CIO is named as the meeting convener, the person-vs-function test shows this is about what the program does (meetings, reviews, incident response protocol), not the CIO's qualifications or background. CIO is a cybersecurity-specific title on the IS list, yielding Firm-Specific, but there are no second QV-eligible hard facts (no dates, headcounts, named firms/tools).

thinking:
Classify this paragraph.

The paragraph describes what the CIO does (meets with IT teams) and describes an incident response plan. Let me apply the person-vs-function test: if I remove "The CIO," the paragraph still describes meetings with IT teams and an incident response plan. This is about processes/functions, not about the person's qualifications or background.

Content category: Risk Management Process

Specific facts:
- CIO is a cybersecurity-specific title per the IS list → Firm-Specific
- "global incident response plan" — generic program name, not unique identifier
- "regularly" — generic cadence

- Only one IS-list fact present (CIO title), with no quantifiable details like dates, dollar amounts, headcounts, or named entities. This lands it squarely in Firm-Specific territory.

fact: CIO (cybersecurity-specific leadership title)


reasoning: The paragraph describes the company's internal cyber risk management structure — ERM integration, IRM program governance, and committee reporting chains. The CSO is mentioned as a committee member (incidental attribution), and the substantive content is about how the risk management function is organized and operates. Multiple firm-specific facts (named teams, named programs with unique identifiers, non-generic committees like Risk Committee and IRM Steering Committee) but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: Describes the Global Security Organization's role, ERM integration, IRM program, IRM Steering Committee, CSO membership, reporting to Risk Committee.

Category: This is about internal processes and organizational structure for cyber risk management. The primary topic is the company's risk management framework - ERM, IRM program, governance structure. The CSO is mentioned as a member but the paragraph is about the function/process, not the person. → Risk Management Process

Specific facts:
- "Global Security Organization" - named internal team/department
- "IRM program" - named internal program with specific identifier

- "IRM Steering Committee" - named committee
- "CSO" (Chief Security Officer) - cybersecurity-specific role
- "Risk Committee" - named non-generic committee (per IS list)
- "ERM Steering Committee" - named committee

No quantifiable metrics like dates, dollar amounts, or headcounts present. Firm-Specific facts identified: CSO role, IRM program, IRM Steering Committee, and Risk Committee. This rates as Firm-Specific (3) in specificity.

fact: Global Security Organization

fact: IRM program (Information Risk Management)

fact: IRM Steering Committee

fact: CSO (Chief Security Officer)

fact: Risk Committee of the Board

fact: ERM Steering Committee


reasoning: The grammatical subjects performing the primary action are the ITSC and Chief Information Officer — they provide reports to the Board. Per Rule 2, 'Management role reports TO the board' → Management Role. The paragraph describes a reporting structure rather than the person's credentials or the board's oversight activities. CIO is a cybersecurity-specific title and ITSC is a named non-generic committee, both qualifying as firm-specific facts, but neither counts toward QV.

thinking:
Classify this paragraph.

The paragraph describes the ITSC and CIO providing reports to the Board quarterly. The primary actors are the ITSC and CIO (management), reporting TO the board. But the purpose is about integration into risk management and reporting to the board.

Let me think about category. The grammatical subjects are "ITSC and Chief Information Officer" - they provide reports to the Board. Per Rule 2, "Management role reports TO the board" → Management Role. But also, "CISO reports quarterly to the Board on..." → Management Role.

Wait, but the paragraph is also about ERM integration ("cybersecurity risk management is integrated into the Company's overall risk management plans").

Now I'm applying the person-versus-function distinction. The paragraph focuses on what the CIO and ITSC do—specifically their reporting obligations to the Board—rather than their qualifications or background. The core content is really about the organizational structure and reporting cadence. The Board is positioned as the recipient of these reports, but management's role in providing them is what drives the narrative. So the tiebreaker comes down to whether the emphasis is on Board oversight or on management's reporting function. Given that the sentence structure centers on management as the active party ("the ITSC and CIO provide reports"), this points toward Management Role rather than Board Governance.

But there's another layer here—the stated purpose is to ensure cybersecurity risk is integrated into the Company's overall risk management plans. That integration mechanism is what the reporting accomplishes, which could suggest Risk Management Process. Still, since the CIO and ITSC are the primary actors performing the action, Management Role seems like the better fit.

Now I'm checking the specificity factors: CIO is a cybersecurity-specific title on the IS list, and ITSC is a named committee, so those are IS facts. But for Quantifiable Verification, named roles and committees don't count—I need hard verifiable facts. That puts this in Firm-Specific territory.

fact: Chief Information Officer

fact: ITSC (Information Technology Steering Committee)


reasoning: The paragraph opens with brief attributions to the board and management but its primary content describes the company's cybersecurity program: framework adoption (NIST, ISO), ERM integration, and incident response planning. Applying the person-vs-function test, removing the board/management attributions leaves a complete process description. Named frameworks (NIST, ISO) elevate beyond Generic Boilerplate, but no firm-specific facts from the IS list are present — 'board of directors,' 'management,' and 'IT security incident response plan' are all on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Board oversees risk management, management handles day-to-day, cybersecurity policies based on NIST and ISO frameworks, integrated into ERM.

Category: Mixed - board oversight mentioned, management mentioned, but the bulk is about the risk management process (framework adoption, ERM integration). The board and management mentions are brief attributions. The dominant content is about the program's framework alignment and integration. → Risk Management Process

Specificity: Names NIST and ISO (recognized frameworks) → Sector-Adapted. No firm-specific facts from the IS list. "Management" is generic, "board of directors" is generic, no CISO/CIO named.

The incident response plan is also a generic program name without firm-specific details, so that's Sector-Adapted as well.

fact: National Institute of Standards and Technology (NIST)

fact: International Organization for Standardization (ISO)


reasoning: The paragraph lists key features of the company's cybersecurity program — incident response, policies, testing, risk assessments, vendor management, and training. The CISO is mentioned as attribution for who directs/manages these processes, not as the subject of personal credential disclosure, so the person-vs-function test points to Risk Management Process. Firm-Specific due to cybersecurity-specific roles (CISO, Chief Privacy Officer) and named departmental composition, but no two QV-eligible hard facts (no dates, dollar amounts, named firms, or named tools).

thinking:
Let me analyze this paragraph from Metropolitan Life Insurance Co's 10-K filing, Item 1C.

Content Category: This paragraph describes the "key features of the Program" — listing internal cybersecurity processes including incident response, policies, testing, risk assessments, vendor management, employee training, etc. The CISO is mentioned as attribution. This is about what the program does, not about the person. → Risk Management Process.

Wait, there are elements of Third-Party Risk (vendor management) and Strategy Integration (insurance), but the dominant topic is the company's internal cybersecurity program features.

Specific facts:

The CISO holds a named cybersecurity-specific role, and the program involves multiple departments—Global Technology & Operations, Risk, Compliance, Legal, Privacy, and Internal Audit—though the references to "various geographical regions" and "annual" exercises are too vague to be meaningful. They mention cybersecurity and privacy liability insurance but provide no specifics on coverage or amounts. The CISO role itself isn't quantifiable, and the departmental composition, while firm-specific, doesn't meet the threshold for quantifiable verification since there are no concrete metrics, dates, or headcounts attached.

fact: CISO directs cybersecurity incident response team

fact: Chief Privacy Officer co-manages incident response plan

fact: Cross-functional team includes Global Technology & Operations, Risk, Compliance, Legal, Privacy and Internal Audit


reasoning: The paragraph opens with a generic risk statement and mentions the CIRT program, but the dominant content is about the Director of IT as a person — their reporting line (to CFO), formal education, certification, 28 years of experience, and areas of expertise. This passes the person-vs-function test: the paragraph is primarily telling us who this person is and what qualifies them. Two QV-eligible hard facts — 'Microsoft Certified Information Systems Professional' (named certification) and '28 years of experience' (specific number) — push specificity to Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content: The paragraph covers multiple topics:
1. Generic risk statement about cybersecurity threats
2. Named internal program: CIRT (Cybersecurity Incident Response Team)
3. Director of IT leads CIRT, reports to CFO
4. Director of IT's qualifications: formal education in Computer Information Systems, Microsoft Certified Information Systems Professional, 28 years of experience
5. Director of IT's experience areas

The primary content is about the person - the Director of IT - their qualifications, credentials, experience, reporting line. The CIRT is mentioned but the bulk of the paragraph describes who this person is and what makes them qualified.

So the core purpose here is establishing the credentials of the person managing cybersecurity response, not describing a cybersecurity-specific role. The title itself—Director of Information Technology—is general IT leadership rather than a dedicated cybersecurity position, even though they oversee the incident response team. This means the paragraph is really about demonstrating that someone with broad IT experience and relevant certifications is handling this responsibility. The NOT list says "Director of IT" is generic. "Cybersecurity Incident Response Team (CIRT)" is a named internal program so it qualifies for the IS list. "28 years of experience" is a specific number that's QV-eligible, and "Microsoft Certified Information Systems Professional" is a named certification, also QV-eligible—that gives me 2 QV-eligible facts. "Chief Financial Officer" is generic per the NOT list, and "Computer Information Systems" without a named university is also generic. So this comes down to Management Role and Quantified-Verifiable.

fact: Director of Information Technology leads CIRT

fact: 28 years of experience


specificity_confidence: medium

reasoning: The paragraph describes an actual cybersecurity incident — unauthorized access on October 31, 2023, scope of data affected, and response actions taken — squarely fitting Incident Disclosure. For specificity, the incident date (Oct 31, 2023) is a hard verifiable fact; the 8-K filing dates are filing metadata rather than disclosure substance (per the codebook's metadata exclusion in Case 3), and the firms engaged are unnamed ('existing cybersecurity firms', 'additional cybersecurity experts'). With one substantive hard fact, this is Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes a cybersecurity incident - unauthorized access on October 31, 2023, personal information obtained, response actions taken.

Category: Incident Disclosure - clearly describes what happened in an actual cybersecurity incident.

Specific facts:
- "November 2, 2023" - specific date
- "November 9, 2023" - specific date
- "December 15, 2023" - specific date
- "October 31, 2023" - specific date
- "substantially all of our current and former customers" - vague quantifier

QV check: Multiple specific dates count as hard verifiable facts.

The incident date of October 31, 2023 is the core hard fact here, while the subsequent filing dates are more administrative metadata. The phrase "substantially all of our current and former customers" is too vague to count as a specific verifiable claim, so I'm looking at whether the incident date alone plus any other concrete details meet the threshold for Quantified-Verifiable classification. I've identified the incident date of October 31, 2023 as the one concrete, verifiable fact here—that's what makes this Firm-Specific rather than a vague quality indicator.

fact: October 31, 2023 — date of the cybersecurity incident

fact: November 2, 2023 — date of initial Form 8-K disclosure

fact: November 9, 2023 — date of Form 8-K/A amendment

fact: December 15, 2023 — date of second Form 8-K/A amendment


reasoning: The paragraph describes the company's internal cybersecurity processes — incident response planning, technical reviews, patching, and breach response plans — squarely within Risk Management Process. No named frameworks ("multiple cybersecurity risk frameworks" is unnamed), no named roles, tools, dates, or quantified facts; all language is generic and could apply to any company.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity policies, incident response plan processes, and technical reviews. This is about internal processes and methodologies.

Category: Risk Management Process - describes the company's own internal cybersecurity processes (incident response planning, technical reviews, patching).

Specificity: Let me check for specific facts:
- "multiple cybersecurity risk frameworks" - unnamed, generic
- "incident response plan" - generic program name
- "technical reviews" - common practice
- No named frameworks, no named roles, no dates, no numbers, no named tools

This is Generic Boilerplate (1). No named standards, no firm-specific facts.


reasoning: The paragraph describes how the Board receives cybersecurity briefings and participates in strategy discussions — classic board oversight mechanisms. Although senior management (CIO/CISO) is the grammatical subject of the first sentence, the communicative purpose is to describe the Board's oversight cadence and engagement. The CISO and CIO are cybersecurity-specific titles on the IS list, making this Firm-Specific, but there are no QV-eligible hard facts (no specific dates, dollar amounts, headcounts, named firms, or named tools) to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph describes board briefings by senior management (CIO and CISO) on cybersecurity posture. The Board is being briefed, and the Board participates in strategy discussions.

Category: The primary actor here is a mix. "Senior management, including our CIO and CISO, brief the Board" - management is the grammatical subject briefing the board. But the overall purpose is about board oversight - the board receives briefings and participates in strategy discussions. This is about the board's oversight mechanism (how the board stays informed). The board is the recipient of oversight information.

Looking at Rule 2: "CISO reports quarterly to the Board on..." → Management Role (CISO is primary actor).

But I'm seeing both management as the briefing actor and the board as a co-participant in strategy discussions. The core focus is on the board's oversight function—how they stay informed and engaged on cybersecurity matters. I'll categorize this as Board Governance. For specificity, the mention of CIO and CISO titles makes this Firm-Specific.

fact: CIO

fact: CISO


reasoning: The paragraph briefly describes an actual incident (two sentences) but its primary communicative purpose is the materiality assessment ('did not materially and adversely affect our results of operations') followed by extensive boilerplate language about potential future material adverse effects and a cross-reference to Risk Factors. Per the tiebreaker rule, a brief mention of a past incident plus a materiality conclusion as the main point yields Strategy Integration. One QV-eligible hard fact (specific date February 16, 2022) but no second hard fact ('third-party experts' is unnamed/generic), so Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph from Century Aluminum Co's 10-K filing.

The paragraph starts with a description of an actual incident (February 16, 2022 cybersecurity intrusion), then transitions into a materiality assessment ("did not materially and adversely affect"), then extensive boilerplate risk language about potential future impacts, and ends with a cross-reference to Risk Factors.

Category decision: The paragraph has multiple elements:
1. Incident description (first two sentences) - specific date, what happened
2. Materiality assessment - "did not materially and adversely affect our results of operations"

3. Extensive boilerplate risk language about potential future impacts
4. Cross-reference to Risk Factors

The dominant content by volume is the boilerplate risk language and materiality assessment. The incident is briefly described but the main point transitions to materiality and risk language. Per the tiebreaker: "Brief mention of a past incident + materiality conclusion as the main point → Strategy Integration."

Actually, let me reconsider. The incident description is about 2 sentences. The materiality conclusion is one clause. Then the rest is generic risk language. The paragraph's primary communicative purpose seems to be: we had an incident, it wasn't material, but here are all the ways cyber risks could hurt us. The boilerplate dominates the space and tone, so this leans toward Risk Disclosure rather than Strategy Integration.

But the tiebreaker rule is clear: when you have a brief incident mention plus a materiality conclusion as the main point, that's Strategy Integration. The materiality assessment is the actual conclusion being drawn—the boilerplate is just supporting context.

I'll go with Strategy Integration.

Now checking specificity: "February 16, 2022" is a specific date that qualifies. "Team of third-party experts" is generic boilerplate. No named tools, products, or financial figures. Only one hard verifiable fact, so this is Firm-Specific (3).

fact: February 16, 2022 — specific date of cybersecurity intrusion


reasoning: This paragraph describes the company's overall cybersecurity program across multiple dimensions (governance, technical safeguards, incident response, third-party risk, training) — all internal processes under the ERM umbrella. While board oversight and CIO are mentioned, they are components within a comprehensive process description, making Risk Management Process the dominant category. QV is met with at least two hard verifiable facts: specific dates (in 2023, multiple references) and a named external organization (FBI-led training).

thinking:
Let me analyze this paragraph carefully.

This is a long, multi-topic paragraph covering multiple aspects of Callon Petroleum's cybersecurity program. It's structured as bullet points under the umbrella of the company's ERM approach.

Content Category: This paragraph covers governance, collaborative approach, technical safeguards, incident response, third-party risk management, and education. The dominant theme is the company's overall cybersecurity program and its processes. While it mentions Board oversight and CIO, these are components within a broader Risk Management Process description. The primary communicative purpose is describing the company's internal cybersecurity processes across multiple dimensions.

Now I'm identifying which facts are specific enough to qualify as verifiable details. The CIO is a named role, there's mention of an oil and gas threat intelligence group with weekly meetings, a 2023 date, third-party audit involvement, specific departments like IT, legal and operations, and FBI-led training also in 2023 — these are the concrete elements I can extract.

For quantified-verifiable purposes, I need to distinguish between firm-specific details and genuinely hard verifiable facts. The CIO role is firm-specific, not externally verifiable. The year 2023 appears multiple times, and the FBI is a named organization, which gives me two potentially verifiable anchors. But I should clarify whether just "2023" without a specific month counts as a precise date for verification purposes, or if it's too broad compared to examples like "December 2023."

fact: Chief Information Officer (CIO)

fact: in 2023, penetration test performed by a third-party audit firm

fact: IT, legal and operations departments participate in IR plan testing

fact: in 2023, completed comprehensive review of third-party providers

fact: implemented a third-party risk management service with risk scoring and continuous monitoring

fact: FBI-led training in 2023


reasoning: The paragraph briefly describes a past incident (February 2022 intrusion) but its primary communicative purpose is the materiality assessment ('did not materially and adversely affect our results of operations') followed by extensive generic risk language about potential future material adverse effects and a cross-reference to Risk Factors. Per the tiebreaker rule, brief mention of a past incident plus materiality conclusion as the main point → Strategy Integration. One QV-eligible fact (specific date) yields Firm-Specific; 'third-party experts' is generic and does not count.

thinking:
Let me analyze this paragraph from Century Aluminum Co's 10-K filing.

The paragraph starts with a specific incident (February 16, 2022 cybersecurity intrusion), then transitions into a materiality assessment ("did not materially and adversely affect our results of operations"), then goes into extensive generic risk language about potential future impacts, and ends with a cross-reference to Risk Factors.

Category: The paragraph describes an actual incident briefly, makes a materiality assessment, then spends most of the text on generic risk language. The dominant purpose seems split between Incident Disclosure and Strategy Integration. The incident description is brief (detected intrusion, engaged experts).

The materiality conclusion is explicit and serves as the main point, with the bulk of the paragraph devoted to generic risk language about potential future impacts. The incident itself is only briefly mentioned in the opening sentences, while the materiality assessment and forward-looking risk language dominate the rest. This makes Strategy Integration the appropriate category.

Specificity: The date "February 16, 2022" is specific and would qualify for QV eligibility, but there's no other specific quantitative information provided.


reasoning: The dominant content describes the company's internal communication and disclosure framework for cybersecurity incidents — escalation processes, stakeholder notification, and committee oversight of response measures. While the final sentence contains a materiality disclaimer (Strategy Integration), the majority of the paragraph details the risk management process. No named frameworks, cybersecurity-specific roles, named firms, specific dates, or other IS-list facts are present; 'internal disclosure committee,' 'executive management team,' and 'internal and external legal counsel/audit teams' are generic corporate functions that appear on the NOT list.

thinking:
Let me analyze this paragraph carefully.

The paragraph has three parts:
1. Description of a communication/disclosure framework for incidents (escalation processes, disclosure committee, etc.)
2. Significant events directed to "the Committee" for oversight
3. Materiality disclaimer

Let me determine the dominant category. The first two sentences describe internal processes (communication framework, escalation). The third sentence is a materiality disclaimer.

The materiality disclaimer is present but the bulk of the paragraph describes the risk management process (communication and disclosure framework). However, per Rule 6, materiality disclaimers → Strategy Integration. But the dominant content test applies - most of the text is about the process.

The process description clearly dominates by word count, so Risk Management Process is the primary category here, even though the materiality statement appears at the end. The framework and escalation procedures are what the paragraph emphasizes, making that the core focus.

Now looking at the specificity—the language is entirely generic. There are no named committees beyond vague references, no cybersecurity titles, no specific dates or tools, and no named frameworks. The composition of the disclosure committee and the teams involved are described in broad strokes without any concrete details that would signal insider knowledge or specific institutional practices.


reasoning: The paragraph describes the oversight mechanism by which the Risk Committee receives reports on the Information Security Program, including briefing scope and cadence. While the IT Management team is the grammatical subject, the communicative purpose is to describe the Risk Committee's oversight structure. The Risk Committee is a named non-generic committee (distinct from the standard Audit Committee), triggering Firm-Specific. Annual/quarterly cadences are generic and do not count toward higher specificity.

thinking:
Let me analyze this paragraph.

The paragraph describes reporting from the IT Management team to the Risk Committee - covering what they report on and how often.

Category: The Risk Committee (a board-level committee) is receiving reports. But the grammatical subject is "Our IT Management team" - they are the ones reporting. However, the paragraph is about the reporting relationship and what gets reported to the Risk Committee.

Actually, let me reconsider. The grammatical subject is "Our IT Management team reports... to the Risk Committee." The primary actor is the IT Management team reporting upward. But the content is about oversight - the Risk Committee receiving reports. This is a borderline Board Governance vs Management Role case.

I'm applying the tiebreaker rule: when a management-level team reports to the board on their activities, that's a Management Role category, since the management team is the primary actor. The IT Management team is the subject performing the action, so this falls under Management Role despite the board-level recipient. the Risk Committee's oversight mechanism. The paragraph focuses on what reports the Risk Committee receives and how frequently, making this Board Governance rather than Management Role. Since "Risk Committee" is a named committee on the IS list, that's one firm-specific fact, but the generic cadences and non-cybersecurity-specific IT Management team keep this from reaching QV threshold.

fact: Risk Committee


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected, nor are they reasonably likely to materially affect, our business strategy, results of operations, or financial condition'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-references to Risk Factors. The materiality language is standard boilerplate with no named frameworks, specific dates, dollar amounts, or other firm-specific facts — the lengthy Risk Factor cross-references are pointers elsewhere, not substantive disclosure content.

thinking:
Let me analyze this paragraph.

Content: Acknowledges attempted unauthorized access, then makes a materiality assessment ("have not materially affected, nor are they reasonably likely to materially affect, our business strategy, results of operations, or financial condition"), followed by lengthy cross-references to Risk Factors.

Category: The paragraph contains an explicit materiality assessment. Per Rule 6, this is Strategy Integration. The cross-references don't change that.

Specificity: The materiality language is boilerplate. The cross-references mention bitcoin (firm-specific context) but the cross-reference text is just pointing elsewhere, not making disclosure.

The materiality assessment itself relies entirely on standard boilerplate language with no named frameworks, specific dates, or hard facts to support it—that's Generic Boilerplate.


reasoning: The paragraph's primary communicative purpose is generic disclaimer language ('no system is entirely secure,' 'may not be sufficient to prevent all incidents') followed by a pure cross-reference to Item 1A Risk Factors with no materiality assessment. The opening sentence references frameworks from a prior paragraph but is a thin continuation, not the paragraph's focus. The cross-reference lacks any materiality conclusion ('have not materially affected...'), so it does not qualify as Strategy Integration. No specific facts are present — 'Information Security Program' is a generic program name and 'these frameworks' are unnamed in this paragraph.

thinking:
Let me analyze this paragraph.

Content: References frameworks informing security controls, acknowledges limitations, and cross-references Risk Factors. No materiality assessment - just a cross-reference.

Category: This is mostly generic risk language and a cross-reference. There's no materiality conclusion ("have not materially affected..."). It just says "please refer to Item 1A." The mention of "Information Security Program" is a generic program name. This is None/Other - it's generic disclaimers plus a cross-reference.

Wait, let me reconsider. "These frameworks inform the design of our security controls" - this references frameworks from a prior paragraph. The rest is generic risk language and a cross-reference.

The opening sentence does touch on Risk Management Process with the frameworks and controls discussion, but everything after that is just boilerplate caveat language with no real substance. The cross-reference at the end doesn't include any materiality assessment either. So while there's a brief RMP reference, the paragraph is dominated by generic disclaimers and a pointer elsewhere. That makes this None. The first sentence does contain substantive RMP language about how frameworks inform security controls, but the paragraph's dominant purpose is disclaiming and cross-referencing rather than substantively addressing risk management. The specificity is generic boilerplate—"Information Security Program" is a generic program name, and the frameworks are only vaguely referenced as "these frameworks" without any named examples or specific facts. I'm settling on None/Other as the classification.


reasoning: The paragraph describes how cybersecurity risk management is embedded into business processes, with the ERM team and CSO collaborating to evaluate and address risks. The CSO is mentioned as attribution within a process description (person-vs-function test: remove the CSO reference and the paragraph still describes an internal risk management process), making this Risk Management Process. The CSO title is a cybersecurity-specific role on the IS list, elevating specificity to Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes how risk management is embedded in business processes, mentions ERM team working with CSO and IT risk management team to evaluate cybersecurity risks.

Category: This is about internal processes - how the company manages cybersecurity risk. The CSO is mentioned but as attribution within a process description. The paragraph is about what the teams DO (evaluate and address risks), not about WHO the CSO is. → Risk Management Process

Specific facts:
- "Chief Security Officer" / "CSO" - this is a cybersecurity-specific title → IS list item
- No named frameworks, no dates, no dollar amounts, no named firms/tools

- The CSO reference gives me one firm-specific fact, which isn't enough to reach the QV threshold.

fact: Chief Security Officer (CSO)


reasoning: The paragraph's primary communicative purpose is describing the cybersecurity leadership structure: the CISO's qualifications (20 years of experience, certifications), the reporting chain (Cybersecurity and Privacy team → CTDO → CEO, and CISO/CTDO → named Committee), and the team composition. While the latter portion describes monitoring and scanning processes, these are framed as activities the CISO implements, keeping the person as the grammatical subject and organizational focus. For specificity, multiple IS-list facts exist (CISO, CTDO, named non-generic committee, 20 years), but only one QV-eligible hard fact (20 years) — 'appropriate security certifications' are not named, so this is Firm-Specific, not Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

This is a dense paragraph covering multiple topics. Let me break it down:

1. "The Cybersecurity and Privacy team... reports to our Chief Technology and Digital Officer, who reports directly to our Chief Executive Officer." - Reporting structure (Management Role)
2. "led by our Chief Information Security Officer ("CISO"), who is responsible for developing and implementing our cybersecurity program" - CISO role attribution
3. "The CISO and Chief Technology and Digital Officer report to the Cybersecurity, Technology and Innovation Committee" - Reporting to a named committee

4. The CISO brings substantial experience with 20 years in cybersecurity leadership, relevant certifications, and a strong track record in the field.
5. The CISO oversees regular monitoring processes, including deployment of advanced security controls, technologies, and continuous scanning and testing activities.
6. The CISO stays current with industry developments by regularly attending cybersecurity conferences.

Looking at the structure here, the paragraph emphasizes the reporting hierarchy—with the CISO and Chief Technology and Digital Officer both reporting to the CEO and sitting on the Cybersecurity, Technology and Innovation Committee—alongside the CISO's qualifications and experience. The process activities described are attributed to and carried out by the CISO. The dominant focus is on the management role and organizational structure rather than generic processes, so this leans toward Management Role as the primary category.

For the QV eligibility check, I have one hard verifiable fact: the 20 years of experience. But QV requires at least two distinct verifiable facts, and I'm not finding a second one—no named certifications, no named firms, no specific dates, no dollar amounts. So this qualifies as Firm-Specific rather than QV.

The paragraph's main focus is the management structure and the CISO's qualifications, with the reporting cadence being secondary detail. That makes this a Management Role category.

fact: CISO (Chief Information Security Officer)

fact: Chief Technology and Digital Officer

fact: Cybersecurity and Privacy team

fact: 20 years as a cybersecurity leader

fact: Reports to the Committee at least three times per year


content_category: Third-Party Risk

reasoning: The paragraph's central topic is engaging external third-party providers for incident response capabilities, making vendor engagement the primary subject. However, this is borderline with Risk Management Process since the third parties serve the company's own IR capabilities. The providers are unnamed ('third party providers'), no frameworks or firm-specific details are mentioned, making this Generic Boilerplate.


reasoning: The paragraph is about the people leading cybersecurity — their roles, experience, and credentials — making it Management Role. Multiple QV-eligible hard facts are present: over ten years of experience (specific duration) plus multiple named certifications (CISSP, CCSP, GIAC, GCFA, GCIH), well exceeding the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes two management roles (IT Director, IS Director), their experience, and credentials. This is about the people - their qualifications and credentials.

Category: Management Role - the paragraph is about who these people are, their experience, and certifications.

Specific facts:
- IT Director (named role - cybersecurity-adjacent but let me check... "Information Technology Director" - this is more generic IT, but "Director of Information Security" is cybersecurity-specific)
- Director of Information Security (IS Director) - cybersecurity-specific title
- "over ten years of experience" - specific number

- Bachelor of Science in Cybersecurity & Information Assurance degree, plus multiple industry certifications including CISSP, CCSP, and several GIAC credentials (GCFA, GCIH) - that's well over two quantified-verifiable facts between the years of experience and named certifications.

fact: Information Technology Director (IT Director)

fact: over ten years of experience managing information security

fact: CISSP certification

fact: CCSP certification

fact: GIAC certification

fact: GCFA certification

fact: GCIH certification


reasoning: The paragraph discusses business/financial consequences of cyber risk: it references cybersecurity insurance and notes costs may not be fully covered, which is a strategic/financial assessment. The materiality language ('material adverse effect') and insurance mention are Strategy Integration markers. No named insurers, dollar amounts, or other specific facts — entirely generic.

thinking:
Let me analyze this paragraph.

Content: Mixed - mentions cybersecurity insurance (Strategy Integration), a materiality-related statement, and a cross-reference to Risk Factors.

The paragraph has:
1. "may not be successful in preventing or mitigating a cybersecurity incident that could have a material adverse effect on us" - this is generic risk language
2. "we maintain cybersecurity insurance, the costs related to cybersecurity threats or disruptions may not be fully insured" - Strategy Integration (insurance mention)
3. "See Item 1A, Risk Factors" - cross-reference

The dominant content is about business/financial impact - insurance coverage and materiality.

This is Strategy Integration since the insurance mention is the substantive element here. But there's no specificity—no named standards, firm-specific facts, named insurers, or amounts. Just generic boilerplate language around cybersecurity insurance.


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

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. Generic description of directed attacks they experience
2. A materiality assessment ("not aware of any risks... which have materially affected or are reasonably likely to materially affect our Company, including our business strategy, results of operations, or financial condition")
3. A cross-reference to Risk Factors

Per Rule 6 and the codebook, any paragraph with an explicit materiality assessment is Strategy Integration, even with a cross-reference appended.

Specificity: The materiality language is boilerplate. The cross-reference names a specific risk factor title, but that's metadata/cross-reference, not cybersecurity disclosure substance.

There's no mention of named frameworks or company-specific facts from the IS list, so this falls squarely into generic boilerplate territory.


reasoning: The central topic is oversight of external parties' cybersecurity — evaluating third-party risks, selecting reliable vendors, and imposing contractual requirements. This is vendor oversight as the primary subject, not a component of an internal process description. No named standards, specific facts, or firm-specific details are present; the language is generic and could apply to any company.

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


reasoning: The paragraph's primary communicative purpose is describing an actual cybersecurity incident: the February 13, 2023 disclosure of a third-party vendor file transfer software breach that exposed patient data. The opening sentences about the general threat landscape are context-setting, but the specific incident narrative dominates. Only one hard verifiable fact (the specific date) is present — the vendor and software platform are unnamed — so it reaches Firm-Specific but not Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Discusses general cyber threat landscape, mentions being regularly targeted, then describes a specific incident on February 13, 2023 involving a third-party vendor's file transfer software breach exposing patient data.

Category: The paragraph describes a specific incident - date, what happened, who was involved. The dominant content is the incident disclosure (specific event with date, attack vector, impact).

Specificity:
- Specific date: "February 13, 2023" ✓
- No named third-party firm (just "a third-party vendor")

- No named tools (just "secure file transfer software platform")
- "personal information of certain patients" - vague

Only one hard verifiable fact (the date). So Firm-Specific (3).

fact: February 13, 2023 — date of security breach disclosure


reasoning: The paragraph identifies specific management roles (CTO, SVP of IT & Security) and devotes substantial text to their years of experience and qualifications, making the persons the primary content. Three specific durations (17 years, 10 years, 19 years) constitute multiple QV-eligible hard verifiable facts.

thinking:
Let me analyze this paragraph carefully.

Content category: This paragraph describes the management team responsible for cybersecurity, their titles, and their experience/qualifications. The primary content is about WHO these people are and their credentials.

Person-vs-function test: The paragraph names specific roles (CTO, General Counsel, SVP of IT & Security), describes their experience (17 years, 10 years, 19 years). If I remove the people and their credentials, what's left? "is responsible for assessing and managing our material risks from cybersecurity threats" and "has primary responsibility for our overall cybersecurity risk management program and supervises both our internal cybersecurity personnel and our retained external cybersecurity consultants." There's some function description, but the bulk of the paragraph—especially the last sentence—is about the persons' qualifications. The dominant purpose is Management Role.

Now I'm identifying the specific facts that matter for classification. The CTO and SVP of IT & Security are both cybersecurity-specific titles on the relevant list, while the General Counsel isn't. The three experience durations—17 years, 10 years, and 19 years—are all specific numbers that qualify as quantified-verifiable facts, giving me three QV-eligible items total.

fact: Chief Technology Officer

fact: Senior Vice President of Information Technology & Security

fact: 17 years as a Chief Technology Officer

fact: 10 years of cybersecurity oversight responsibilities

fact: 19 years of experience in information technology


reasoning: The paragraph centers on the CISO as primary subject throughout both sentences — their responsibility, their team, their tenure (13 years), and their experience (20+ years). While the first sentence touches on the program and team areas of expertise, the CISO remains the grammatical subject and the second sentence is purely about the person's background. Two QV-eligible hard facts (13 years tenure + over 20 years experience) reach the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph has two sentences:
1. First sentence: "The Company's CISO is responsible for developing and implementing our information security program and manages a team of cybersecurity professionals with broad experience and expertise, including in [list of areas]."
2. Second sentence: "Our CISO has been with the Company for 13 years in various information security roles and has over 20 years of experience in the cybersecurity field."

Person-vs-function test: The first sentence starts with the CISO as subject and describes what they're responsible for (the program) and the team they manage.

The second sentence focuses entirely on the individual—their tenure and experience. Looking at the paragraph as a whole, it's fundamentally about the CISO as a person: their responsibilities, their team, their background, and their expertise. The person is the grammatical subject throughout, making this Management Role. I'm identifying the key facts: CISO is a cybersecurity-specific title, 13 years with the Company, and over 20 years in the field—that's two quantified facts making this Quantified-Verifiable.

fact: CISO (Chief Information Security Officer)

fact: 13 years with the Company in various information security roles

fact: Over 20 years of experience in cybersecurity


reasoning: The paragraph describes the company's internal cybersecurity program — protecting systems, responding to incidents, and risk management processes (mitigation, transference, acceptance). Applying the person-vs-function test: 'Director – Information Systems' is named as attribution, but the substantive content is about what the program does, not the person's credentials or background. 'Director – Information Systems' is a general IT title (comparable to 'Director of IT' on the NOT list), not a cybersecurity-specific role from the IS list, and no other specific facts are present.

thinking:
Let me analyze this paragraph.

The paragraph describes the "Director – Information Systems" coordinating with management to implement a cybersecurity program. Let me apply the person-vs-function test.

Content: The paragraph mentions a role (Director – Information Systems) but then describes what the program does - protect systems, respond to incidents, risk management process. The person-vs-function test: if I remove the role title, the paragraph still describes processes. But wait - "Director – Information Systems" is the grammatical subject doing things. Let me re-read.

Actually, the paragraph has two sentences:
1. "The Director – Information Systems... works collaboratively across the Company to implement a program designed to protect... and to promptly respond..."

2. "Management is actively involved in the incident response and risk management process (mitigation, transference, and acceptance)."

Both sentences focus on the program's functions and how management participates in them, not on the person's specific credentials or background. This is clearly about the risk management process itself. Now I'm checking whether "Director – Information Systems" qualifies as a cybersecurity-specific title. It's similar to "Director of IT Security" but more general in scope, and it doesn't appear on the list of recognized cybersecurity titles like CISO, CTO, or Information Security Officer.

"Director – Information Systems" aligns more with generic IT leadership titles like "Director of IT," which are explicitly excluded. Without any named frameworks, specific dates, tools, or firms mentioned, this comes across as generic boilerplate with minimal specificity.


reasoning: The paragraph describes the company's internal risk assessment and audit process (who conducts them, how they are reported), making the primary content about internal processes rather than board governance. The Audit Committee is the recipient of reports, not the grammatical subject performing oversight. No IS-list facts are present: 'VP of Internal Audit' is a general corporate title (not cybersecurity-specific like CISO/CIO/VP of IT Security), 'Audit Committee' is generic governance, and 'periodically'/'quarterly' are generic cadences.

thinking:
Let me analyze this paragraph.

Content: Risk assessments conducted by VP of Internal Audit, internal audits reported to Audit Committee quarterly.

Category: This describes risk assessment activities (internal audit process) with a mention of reporting to the Audit Committee. The primary content is about the process of conducting risk assessments and internal audits. The VP of Internal Audit is mentioned as attribution for who does it, but the paragraph is about the process. However, the second sentence shifts to Board Governance (reporting to Audit Committee).

Actually, let me reconsider. "Risk assessments are periodically conducted by our VP of Internal Audit" - this is about the process.

The next part about internal audits being conducted and reported to the Audit Committee quarterly mixes process with board governance. The dominant purpose here is describing the risk assessment and audit process, with the Audit Committee receiving quarterly reports. The VP of Internal Audit is a general corporate role, not cybersecurity-specific like a CISO or CIO would be. So this paragraph straddles both the operational process side and the board governance side, with the Audit Committee as the oversight recipient.

Looking at the specifics: "VP of Internal Audit" isn't on the information security list, "Audit Committee" is generic governance, and "quarterly" is just a standard cadence. There are no information security-specific facts or named standards here, so this reads as generic boilerplate about risk management processes.


reasoning: This list item describes a GRC function (policies, standards, controls, measurement) as part of the company's cybersecurity program, making it Risk Management Process. It contains no named frameworks, no firm-specific facts, and relies on generic language ('industry best practices and regulatory requirements'), so it is Generic Boilerplate.

thinking:
Classify this paragraph from SEC filing.

This is a fragment describing "governance, risk, and compliance defining policies, standards, and systems of control and measurement in line with industry best practices and regulatory requirements."

This appears to be a bullet point or list item describing a component of the company's cybersecurity program - specifically GRC. It's about internal processes (Risk Management Process). No named frameworks, no specific facts, no named roles.

Content: Risk Management Process - describes internal GRC processes
Specificity: Generic Boilerplate - no named standards, no firm-specific facts, just generic language about "industry best practices and regulatory requirements"