fact: Information Security Officer

reasoning: The paragraph names the Information Security Officer as primarily responsible for cybersecurity, details reporting lines (to CRO, IT Steering Committee, Audit Committee, Board). Person-removal test: stripping the ISO, reporting lines, and committee membership leaves only generic risk management framing ('designed to identify, assess, and mitigate risks'), so the substance is about management's organizational role → MR. The Information Security Officer (cybersecurity-specific title) and Information Technology Steering Committee (named non-generic committee) are firm-specific facts driving Level 3.

thinking:
Let me analyze this paragraph.

Content: Describes the risk management program broadly, then positions cybersecurity within it, and identifies the Information Security Officer's role, reporting lines, and committee relationships.

Category: The paragraph starts with general risk management, then focuses on who is responsible (Information Security Officer), reporting lines (to CRO, IT Steering Committee, Audit Committee, Board). The primary question answered is "How is management organized to handle cybersecurity?" - the ISO role, reporting to CRO, membership in committees. Person-removal test: remove ISO, reporting to CRO, committee membership → left with "Our risk management program is designed to identify, assess, and mitigate risks...

Cybersecurity is a critical component of this program, given the increasing reliance on technology and potential of cyber threats." That's generic framing, not a substantive program description. So → MR.

Specificity: The Information Security Officer is a firm-specific cybersecurity role, and the Information Technology Steering Committee is a named non-generic committee, while Chief Risk Officer, Audit Committee, and board of directors are standard across most organizations. This puts it at Level 3 with the ISO and IT Steering Committee as the distinguishing firm-specific facts.


content_category: Board Governance

fact: vulnerability assessments

fact: January 2024 cybersecurity training session for the board

category_confidence: high

specificity_confidence: high

reasoning: The paragraph primarily answers how the board oversees cybersecurity: the audit committee (delegated by the board) receives regular updates from management, engages with external specialists, and is involved in strategic cybersecurity decisions — classic BG oversight structure. Specificity reaches Level 4 because 'January 2024' is a specific date tied to a concrete cybersecurity event (board training session), which is independently verifiable.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

**Content Category:** The paragraph primarily answers "How does the board oversee cybersecurity?" - it describes the audit committee's oversight role as delegated by the board, how management reports to the audit committee, and how the board/committee engages with cybersecurity decisions. This is Board Governance.

**Specificity:** Let me scan for facts:
- "vulnerability assessments" - domain term
- "January 2024" - specific date tied to a cybersecurity training session → QV
- "internal audit firm" - unnamed, not QV

- "audit committee" - standard governance structure, not firm-specific

So January 2024 is the only quantifiable, firm-specific detail here that qualifies as Level 4 specificity.


content_category: Strategy Integration

reasoning: The first sentence states a backward-looking and forward-looking materiality conclusion ('have not materially affected or are reasonably likely to materially affect... business strategy, results of operations or financial condition'), which is the SEC's Item 106(b)(2) assessment language → SI. The cross-reference to Item 1A is subordinate to the materiality assessment. No domain terminology, firm-specific facts, or verifiable claims are present — 'Bio-Techne' is just a company self-reference — so specificity remains Level 1.

thinking: Materiality assessment paragraph with cross-reference.


reasoning: The paragraph states backward-looking and forward-looking materiality conclusions ('have not materially affected' and 'are not reasonably likely to materially affect'), which are SI assessments per Rule 5. It also mentions cybersecurity insurance, reinforcing the business/financial framing. No domain terminology, firm-specific facts, or verifiable claims are present — 'insurance coverage' is generic business language, the materiality statements are boilerplate SEC language, and negative self-assertions are not externally verifiable.

thinking:
Let me analyze this paragraph.

Content: The paragraph makes materiality assessments ("have not experienced any cybersecurity threat or incident that has materially affected," "not identified any risks...that have materially affected, or are reasonably likely to materially affect") and discusses insurance. This is primarily answering "How does cybersecurity affect the business or finances?" → Strategy Integration.

The materiality statements are clear SI per Rule 5. The speculative language ("there is no guarantee," "there can be no assurance") is generic speculation, not assessments.

Specificity: Let me scan for facts.

The insurance mention is just a general business claim with no dollar amounts or named insurers, the threat statements are negative self-assertions that aren't verifiable, and the language about risks and preventative measures is standard SEC boilerplate. There's no domain-specific terminology, no firm-specific details, and no quantifiable facts here.


content_category: Third-Party Risk

reasoning: The paragraph describes specific due diligence factors applied to vendors (information security controls, disaster recovery, geographic risk), directly answering 'how are third-party cyber risks managed?' — making it TP. Despite listing review criteria, all terms ('information security and related controls,' 'third-party audit,' 'disaster recovery and business continuity,' 'country risk') pass the ERM test as standard vendor risk management language a non-security professional would use. 'VRM' is just an abbreviation for the generic 'Vendor Risk Management' program, not a distinguishing identifier. No domain terminology, firm-specific facts, or verifiable claims elevate specificity above Level 1.

thinking:
Let me analyze this paragraph.

Content: Describes specific factors VRM (Vendor Risk Management) considers when performing due diligence on high-risk and vital vendors, including information security controls, disaster recovery, and geographic location.

Category: This is about how third-party/vendor cyber risks are managed - requirements and assessments imposed on vendors. → Third-Party Risk

Specificity: Let me check for facts.
- "VRM" - this is a named internal program/team (Vendor Risk Management) - firm-specific
- "third-party audit" - this is about reviewing vendor's audit, domain term? It's about assessing vendors' security controls via third-party audit. "Third-party audit" in context of information security controls - this is a general business concept.

- "Information security and related controls" - general
- "disaster recovery and business continuity program" - general/L1
- "Geographic location (country risk)" - general risk concept

Now I'm reconsidering whether "VRM" actually qualifies as firm-specific. It's an abbreviation for Vendor Risk Management, which is a generic program name. Without any distinguishing identifiers that make it unique to this company, it doesn't meet the threshold for firm-specific terminology. The substantive concepts being discussed—information security controls, disaster recovery, and geographic risk assessment—are all standard industry practices, not proprietary to this organization. I'm second-guessing whether "third-party audit" in the security context pushes this into domain-specific territory—it could reference SOC 2 reports or similar frameworks. But the language stays general enough that a non-security ERM professional would recognize it as standard vendor due diligence. I'll classify this as Level 1 generic boilerplate. As for "VRM" as a team identifier, it's just an abbreviation for Vendor Risk Management, which is too generic to qualify as a distinguishing program name.


content_category: Risk Management Process

category_confidence: medium

reasoning: The paragraph describes the company's general approach to cybersecurity ('established a strong cybersecurity program intended to continue to monitor and improve our cybersecurity posture'), which answers 'what does the program do?' albeit at a very high level. No domain terminology, firm-specific facts, or verifiable claims are present — every phrase could appear in any company's filing unchanged.


content_category: Management Role

fact: over twenty years of experience managing IT and cybersecurity

type: quantified

fact: Master of Science degree in Telecommunications and Computer Networks

fact: Project Management Professional certified

fact: Certified Scrum Master

fact: IT Infrastructure Library (ITIL) certified

reasoning: The paragraph's primary content describes the Head of IT's reporting line to the CFO, qualifications, credentials, and responsibility for cybersecurity — answering 'how is management organized?' The materiality assessment ('not reasonably likely to materially affect us') is a secondary SI element but the management role content occupies the most text. Note: 'Head of IT' fails the firm-specific test per codebook, but multiple individually verifiable certifications (PMP, CSM, ITIL) and the specific 'over twenty years' lower-bound experience claim drive specificity to Level 4.

thinking:
Let me analyze this paragraph carefully.

**Content Category:**

This paragraph covers multiple topics:
1. Head of IT's qualifications and reporting line (MR)
2. Responsibility for assessing/managing cybersecurity risks (MR/RMP)
3. ERM integration (RMP)
4. Materiality assessment - "not reasonably likely to materially affect us" (SI)
5. Cross-reference to Item 1A (N/O)

The paragraph starts with management role details (Head of IT, reporting to CFO, qualifications), then describes responsibility for risk management, then makes a materiality assessment, then cross-references.

The primary focus is on the Head of IT's role and responsibilities, with the materiality conclusion serving as a secondary element. The MR content dominates the text, though there's a meaningful SI component in the materiality statement that suggests this paragraph straddles both categories. I'm seeing several verifiable qualifications here—over twenty years of experience, a named Master's degree, and three specific certifications (PMP, CSM, ITIL)—which pushes this to Level 4. The materiality language about cybersecurity threats is substantive information content, and the overall focus is on management's organizational structure and credentials, so this lands in MR.


reasoning: The first sentence states a conclusion about materiality ('not aware of any cybersecurity incidents that have materially affected or are reasonably likely to materially affect us') — this is a backward-looking and forward-looking materiality assessment, making it SI. The second sentence is a cross-reference to Item 1A, which is subordinate. No domain terminology, firm-specific facts, or verifiable claims are present — the negative assertion about no material incidents is not externally verifiable.


reasoning: The paragraph states a conclusion about materiality using SEC Item 106(b)(2) language ('does not believe there are currently any known risks from cybersecurity threats that are reasonably likely to materially affect us or our business strategy, results of operations, or financial condition'), making it a forward-looking materiality assessment → SI. No domain terminology, firm-specific facts, or verifiable claims are present — 'management,' 'consultants,' and the materiality boilerplate are all generic.

thinking:
Let me analyze this paragraph.

Content: Management evaluates cybersecurity risks and concludes they are not reasonably likely to materially affect the company. This is a materiality assessment - "does not believe there are currently any known risks from cybersecurity threats that are reasonably likely to materially affect us or our business strategy, results of operations, or financial condition."

Category: This states a conclusion about materiality using SEC Item 106(b)(2) language → Strategy Integration.

Specificity: Let me scan for facts.
- "management" - generic
- "consultants" - unnamed, generic
- "reasonably likely to materially affect us or our business strategy, results of operations, or financial condition" - this is boilerplate SEC language

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

Level 1.


fact: cybersecurity awareness training

specificity_confidence: medium

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' — it describes the CEO and SVP Finance/CFO's responsibilities, experience in enterprise risk management, meeting cadence with IT operations staff, and sponsorship of training. Person-removal test leaves only thin generic process language, confirming MR. For specificity, CEO and CFO are not cybersecurity-specific titles (every company has them), so they are not firm-specific. 'Cybersecurity awareness training' is a domain term (security awareness training appears on the domain terminology list), elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Category: The paragraph is about how management is organized to handle cybersecurity. It describes the CEO and SVP Finance/CFO's responsibilities, their experience, their meeting cadence with IT operations, and their sponsorship of training. The person-removal test: remove all person-specific content → "assessing cybersecurity risks and confirming we have an appropriate cybersecurity strategy... meet regularly with individuals charged with day-to-day IT operations... review and assess potential cybersecurity threats... sponsor periodic cybersecurity awareness training for all employees." Some program description remains but the primary content is about WHO is responsible and their qualifications. The paragraph is primarily answering "how is management organized?" → MR.

Reconsidering the person-removal test more carefully: stripping away titles, experience, and reporting lines leaves mostly generic statements about assessing risks, developing strategy, meeting with IT operations, and sponsoring training. The substance is thin and doesn't really describe a distinct cybersecurity program—it's fundamentally about the roles and qualifications of the CEO and SVP/CFO. → MR.

Looking at specificity: CEO and CFO are explicitly non-firm-specific per the codebook, and SVP Finance is just a standard business title. There's no domain terminology that qualifies except "security awareness training," which appears in the domain terminology list as a Level 2 term. No firm-specific facts, no QV facts.

This comes out to Level 2.


fact: backdoor into ISG systems or network

reasoning: The paragraph's central topic is how third-party supplier cyber risks are managed — risk assessment processes, contractual security addendums, and remediation with suppliers — directly answering 'how are third-party cyber risks managed?' The term 'backdoor' is a cybersecurity-specific threat concept that an ERM professional would not naturally use, elevating to Level 2. The remaining language (processes to assess risk, contractual addendums, working with suppliers) is generic and fails the ERM test.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party supplier cyber risks and how ISG manages them - processes to assess third-party risk, contractual addendums, working with suppliers on deficiencies.

Category: This is primarily about how third-party cyber risks are managed → Third-Party Risk (TP). The central topic is vendor/supplier cybersecurity oversight.

Specificity: Let me scan for facts:
- "third-party suppliers" - generic
- "processes and procedures to continuously assess third-party cybersecurity risk" - generic process description, fails ERM test
- "security and privacy addendums to our contracts" - this is a contractual security requirement, but is it domain terminology? "Security and privacy addendums" - an ERM professional could use this language.

Now I'm reconsidering the terminology. "Backdoor" is definitely a cybersecurity-specific threat concept that an ERM professional wouldn't naturally use in conversation, so that passes the domain test. But "security and privacy addendums" leans more toward legal and compliance language rather than cybersecurity domain-specific terminology. So "backdoor" as a threat type qualifies as a domain term at Level 2, though I need to think through how it's being used here. I'm reconsidering whether "backdoor" alone is enough to push this into Level 2 territory, or if the overall generic nature of the risk description keeps it at Level 1. The term is definitely cybersecurity-specific, but it's used here as part of a straightforward threat scenario rather than as specialized jargon. I think Level 2 is the right call given the domain-specific language, even if the rest of the paragraph reads fairly plainly.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — it describes vendor diligence, ongoing monitoring, contractual requirements, and cybersecurity audits imposed on third parties, making TP the clear category. Despite the length, all language is generic risk management vocabulary (diligence, monitor, contractual requirements, audits) that any ERM professional would use; no cybersecurity domain terms (e.g., SOC 2, encryption, penetration testing), no firm-specific facts, and no verifiable claims are present, keeping specificity at Level 1.

thinking:
Let me analyze this paragraph.

Content: This is about how the company manages third-party cybersecurity risks - vendor oversight, diligence, monitoring, contractual requirements. The central topic is oversight of external parties' cybersecurity. → Third-Party Risk

Specificity: Let me scan for facts.
- "third-party service providers, including our suppliers and manufacturers" - generic
- "diligence on third parties" - generic
- "continually monitor cybersecurity threat risks" - generic
- "require those third parties... to agree by contract to manage their cybersecurity risks" - generic

- "cybersecurity audits" - borderline domain term, but an ERM professional would use this language naturally
- "patient and employee data" - hints at healthcare context but isn't a domain-specific term itself

The language throughout is quite general—"perform diligence," "monitor cybersecurity threat risks," "contractual requirements," "cybersecurity audits." These are all standard business and risk management terms that any ERM professional would use. There are no specific technical indicators like SOC 2 certifications or other domain-specific frameworks mentioned.

This looks like Level 1 - Generic Boilerplate. The processes described are all standard vendor risk management language that could apply to any organization.


content_category: None/Other

reasoning: The paragraph acknowledges generic cybersecurity risks and vaguely references past threats ('from time to time'), but its primary function is a cross-reference directing readers to Item 1A Risk Factors — it contains no substantive cybersecurity disclosure about governance, processes, or specific incidents. None/Other always receives Generic Boilerplate.

thinking:
Let me classify this paragraph.

Content: Acknowledges cybersecurity risks, mentions past threats/incidents vaguely, then cross-references Item 1A Risk Factors.

Category: This is primarily a cross-reference paragraph pointing to Item 1A. The mention of past incidents is vague ("from time to time, experienced threats to and incidents"). There's no substantive disclosure of what happened, no program description, no governance. The cross-reference to Item 1A dominates. → N/O

Specificity: N/O always gets Level 1.


content_category: Incident Disclosure

fact: March 2023 - specific date of the incident

fact: $2.7 million of loss recognized (net of funds recovered and professional fees)

fact: Independent forensic investigation engaged

reasoning: The paragraph primarily answers 'what happened in a cybersecurity incident?' — describing a fraudulent wire transfer scheme in March 2023, the company's discovery and response actions, and the outcome. While it includes financial impact ($2.7M loss), the incident narrative frame dominates per Rule 4. Specificity is Level 4 due to the specific date (March 2023) and quantified loss ($2.7 million), both independently verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes an actual incident - fraudulent wire transfers in March 2023, self-discovery, response actions, $2.7 million loss, forensic investigation.

Category: This is primarily about what happened in a cybersecurity incident - timeline, response, impact. But it also has significant financial impact ($2.7 million loss). The incident frame dominates with timeline, discovery, response actions, but the $2.7M loss figure is a business/financial impact. Per Rule 4, mixed with incident frame dominant → ID.

Actually, let me reconsider. The paragraph describes: (1) the incident (March 2023, fraudulent wire transfers), (2) response actions (contacted bank, law enforcement, informed audit committee), (3) financial impact ($2.7 million loss). The incident narrative dominates - what happened, how they responded. The $2.7M is part of the incident story. → ID.

The specificity here pushes this to Level 4 - I've got a concrete date in March 2023 and a precise dollar figure of $2.7 million, both of which are quantifiable facts tied directly to the incident.


fact: cybersecurity certifications

fact: third-party audit results

fact: technical and organizational controls

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' by describing security and risk assessments imposed on suppliers, including reviewing their certifications, audit results, and controls — squarely Third-Party Risk. Domain terms like 'cybersecurity certifications,' 'third-party audit results,' and 'technical and organizational controls' elevate beyond generic ERM language to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: About assessing third-party suppliers' cybersecurity risk. Central topic is vendor oversight → Third-Party Risk.

Specific facts:
- "cybersecurity certifications" - domain term
- "third-party audit results" - this is about reviewing vendors' audits → TP context
- "technical and organizational controls" - somewhat generic but in cybersecurity context

Domain terms: "cybersecurity certifications", "third-party audit results" - actually let me think about ERM test. "security and risk assessments" is generic. "cybersecurity certifications" references domain. "technical and organizational controls" - this is domain-adjacent.

The language here leans toward domain-specific terminology—particularly "cybersecurity certifications" and "technical and organizational controls"—rather than generic ERM speak. There's no firm-specific information or QV content, so this lands at Level 2 - Domain-Adapted.


fact: CISO provides updates to the Board

fact: CIO provides updates on cybersecurity matters

reasoning: The paragraph primarily answers 'How does the board oversee cybersecurity?' — describing Board and Audit Committee oversight structure, briefing cadence, and information flow from management to the board. CISO, CIO, and the distinctive 'Security & Resiliency global practice leader' title are firm-specific roles elevating specificity to Level 3, but no externally verifiable claims (specific dates, numbers, certifications) push it to Level 4.

thinking:
Let me analyze this paragraph.

Content: Board oversight of cybersecurity, Audit Committee role, reporting from CISO/CIO to Board.

Category: Board Governance - answers "How does the board oversee cybersecurity?" The paragraph describes Board/Audit Committee oversight, how information flows to the board from CISO/CIO.

Specificity: Let me scan for facts.
- "semi-annually" - generic cadence, not QV
- "Audit Committee" - not firm-specific (every company has one)

- "CISO" and "CIO" are firm-specific roles, and "Security & Resiliency global practice leader" is a unique titled position that's also firm-specific, so this pushes toward higher specificity.

Level 3.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing mechanisms, controls, technologies, and processes to prevent data loss and security incidents; the person-removal test leaves a substantive program description, so it is RMP not MR. All language is generic business/ERM vocabulary ('mechanisms, controls, technologies, systems, policies, processes,' 'assessing, identifying, and managing cybersecurity risks,' 'outside advisors and experts') — none passes the ERM test as domain terminology, no firm-specific or verifiable facts are present.

thinking:
Let me classify this paragraph.

Content: Describes what the cybersecurity program does - mechanisms, controls, technologies, systems, policies, processes to prevent/mitigate data loss, theft, etc. Also mentions consulting outside advisors.

Category: "What does the cybersecurity program do?" → RMP. The mention of "executive management team" is brief attribution. Person-removal test: remove "managed by our executive management team" and the rest still describes program activities. Outside advisors serve the company's program → RMP not TP.

Specificity: Let me scan for facts.

- "executive management team" — generic, not firm-specific
- "mechanisms, controls, technologies, systems, policies, and other processes" — generic business language
- "prevent or mitigate data loss, theft, misuse, or other security incidents or vulnerabilities" — "data loss" could be domain but here it's used generically, not as "DLP" the specific practice
- "outside advisors and experts" — unnamed, generic
- "assessing, identifying, and managing cybersecurity risks" — generic ERM language

Everything here is generic. No domain terminology that passes the ERM test. No firm-specific facts. No QV facts. This is Level 1.


fact: Security & Technology Committee

reasoning: The paragraph describes how the Board and a committee receive information about cybersecurity incidents, answering 'how does the board oversee cybersecurity?' — this is about the oversight/reporting structure, not incident details. The 'Security & Technology Committee' is a named non-generic committee, elevating specificity to Level 3.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing processes for assessing, identifying, and managing cybersecurity risks integrated into ERM. However, all language is generic business risk vocabulary ('processes for assessing, identifying and managing,' 'industry standards,' 'enterprise risk management,' 'information assets,' 'unauthorized access or attack') — none of these terms pass the ERM test as cybersecurity domain terminology. No firm-specific or verifiable facts present.


fact: Deutsche Bank Group named as entity managing security incident process

fact: DWS named as intermediary entity in communication protocol

fact: Team composition specified: compliance, legal and data privacy

reasoning: The paragraph describes the security incident management process that protects the company — covering response to cyberattacks, management/reporting processes, and notification protocols — answering 'what does the cybersecurity program do?' Deutsche Bank Group and DWS are the parent entities providing cybersecurity services (not external third-party vendors), and the named team composition ('compliance, legal and data privacy') makes this firm-specific, but these entities are organizational parents rather than independently-contracted external firms, so they are firm-specific rather than QV-eligible.

thinking:
Let me analyze this paragraph.

Content: Describes Deutsche Bank Group's security incident management process, covering cybersecurity events, management/reporting processes with compliance/legal/data privacy involvement, and a communication protocol for notifying affected parties including the registrant.

Category: This is about how a parent/affiliated entity (Deutsche Bank Group/DWS) manages cybersecurity incidents and notifies the company. It describes processes - incident management, response to cyberattacks, communication protocols. The central topic is the incident management process, not third-party vendor oversight per se. Deutsche Bank Group appears to be the parent company managing cyber for this subsidiary.

I'm reconsidering whether this is actually a third-party vendor relationship or a parent-subsidiary arrangement. Since Deutsche Bank Group/DWS is the parent entity providing cybersecurity services to RREEF, this describes the company's own risk management program rather than third-party oversight—the parent's incident management and notification protocols are part of the company's internal cybersecurity infrastructure. I'm trying to determine whether Deutsche Bank Group and DWS count as named external entities for verification purposes. They're technically the parent company and a subsidiary rather than third-party vendors, but they are specifically named organizations whose security programs could be independently verified. The question is whether internal organizational references qualify the same way external firms would under the QV test. I'm reconsidering whether Deutsche Bank Group and DWS qualify as QV examples—they're named entities, but as the parent company and subsidiary, they're more about firm-specific organizational structure than external third-party cybersecurity providers like Mandiant or CrowdStrike. The team composition details (compliance, legal, data privacy) also feel firm-specific rather than broadly verifiable. For domain terminology, "cyberattacks" seems to meet the ERM threshold as a specific threat concept in modern business contexts.


fact: phishing attempt

reasoning: The paragraph's primary purpose is stating a materiality conclusion using SEC Item 106(b)(2) language ('reasonably likely to materially affect... business strategy, results of operations or financial condition'), making it SI. While a past phishing incident is mentioned, it is subordinate to the materiality assessment frame. 'Phishing' is a domain-specific threat type (Level 2). The year '2019' alone (no month) does not meet the specific-date threshold for QV, and the materiality assertion is a negative self-report not independently verifiable.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. "While we have not experienced any material losses relating to cyber-attacks, in 2019 we were the subject of a successful phishing attempt."
2. "We do not believe that there are currently any known risks from cybersecurity threats that are reasonably likely to materially affect us or our business strategy, results of operations or financial condition."

Category: The second sentence is a materiality assessment using the SEC's Item 106(b)(2) language ("reasonably likely to materially affect"). Per Rule 5, this is SI. The first sentence mentions a past incident (phishing in 2019) but it's brief and subordinate to the materiality framing.

The dominant frame is the materiality assessment, though the first sentence does reference an actual incident—a successful phishing attempt in 2019. Per Rule 4, when mixing a concrete incident with a financial/business materiality frame, this falls under Strategy Integration. The overall purpose is stating a conclusion about materiality.

For specificity, "phishing attempt" is a domain-specific threat type, and "2019" is a concrete date tied to an actual cybersecurity event that occurred, not a hypothetical or forward-looking statement. The negative assertion "We do not believe...reasonably likely to materially affect" isn't externally verifiable since it's a self-assertion. Combined with "phishing" being a domain-specific term at Level 2, and "2019" falling short of the specific date requirement without a month, this lands at Domain-Adapted specificity.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — the Audit Committee oversees IT/cybersecurity risks and receives periodic reports from management, which is a classic BG oversight-structure description. No domain terminology, no firm-specific facts (Audit Committee exists at every public company, 'third-party consultants' is unnamed, 'periodic' is a generic cadence), and no verifiable claims — Level 1.


fact: Chief Information Officer (CIO) provides updates to the Board

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — the full Board's oversight responsibility, the reporting cadence, and the topics covered in briefings are all about the oversight structure. Specificity reaches Level 3 due to the CIO as a cybersecurity-specific leadership role (VP+ level), but the remaining content (quarterly updates, topics covered) uses general business language without domain-specific terminology or verifiable facts.

thinking:
Board oversight, reporting structure, CIO reports to board.

Category: Board Governance - clearly answers "how does the board oversee cybersecurity?"

Specificity: Let me scan for facts.
- "Chief Information Officer" (CIO) - this is a firm-specific cybersecurity leadership role at VP+ level
- "quarterly scorecard assessments" - "quarterly" is generic cadence, not specific. "Scorecard assessments" is somewhat specific but not really domain terminology.

Domain terms: "emerging threat landscape" - borderline, but I think this is general enough. "Information security" - general. "Cybersecurity risk management program" - general.

The CIO title is firm-specific and positioned at VP+ level, which gives this a Level 3 rating. There aren't any quantifiable facts like specific numbers, dates, or named external certifications present.


reasoning: The paragraph states only that the company has IT vendor agreements and is 'exploring' cybersecurity vendors — it describes no actual cybersecurity measure, process, oversight mechanism, or vendor risk management practice. This is a general business statement about procurement that does not substantively answer any of the six cybersecurity disclosure questions. No domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Content: About third-party agreements for IT services and exploring vendors for cybersecurity.

Category: This is about third-party relationships but it's very generic - just says they have agreements with third parties for IT services and are exploring vendors. It's not really describing how third-party cyber risks are managed (no oversight, no requirements imposed on vendors). It's more of a general statement about using third parties.

Is this TP? The TP category asks "How are third-party cyber risks managed?" This paragraph doesn't describe management of third-party risks - it just says they use third parties and are exploring more. There's no vendor oversight, no requirements, no assessments.

Is this RMP? It mentions third parties as part of operations but doesn't describe cybersecurity processes. This is too thin to substantively answer any of the six questions - it's just stating they have IT vendor agreements and are exploring cybersecurity vendors without describing actual cybersecurity measures. I think this lands in N/O.

Actually, wait. They do mention third-party relationships for cybersecurity needs, even if they're just exploring vendors. But there's no actual oversight or management of third-party risk described, and the "exploring" language suggests they don't even have cybersecurity vendors in place yet. This feels like it should be Third-Party Risk at Level 1, though I'm second-guessing myself on whether it meets that threshold.

Let me reconsider: the paragraph is really just saying they have IT vendors and are looking for cyber vendors. There's no substantive program, no oversight mechanisms, nothing concrete about how they manage third-party cybersecurity risk. This is too generic and vague to be anything other than N/O.


reasoning: This paragraph states a backward-looking materiality conclusion ('have not...materially affected us, our business strategy, results of operation or financial condition'), which is an SI assessment per the materiality rule. No domain terminology, firm-specific facts, or verifiable claims are present — 'As of the date of this report' is generic reporting context, not a specific cybersecurity date, and the negative assertion about absence of material impact is not externally verifiable.


fact: Software Approval Board

fact: Cross-functional members from Quality, Internal Audit, Information Security, Business Systems, and R&D

reasoning: The paragraph primarily answers 'how are third-party cyber risks managed?' — it describes diligence on high-risk third parties, software risk evaluation for third-party software, and contractual cybersecurity requirements imposed on vendors. The named 'Software Approval Board' and its specific cross-functional composition (Quality, Internal Audit, Information Security, Business Systems, R&D) are firm-specific organizational details that elevate this to Level 3, but no externally verifiable facts push it to Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes diligence on high-risk third parties, a Software Approval Board with specific cross-functional membership, contractual requirements on third parties.

Category: The paragraph is primarily about how third-party cyber risks are managed - vendor diligence, requirements imposed on vendors, contractual requirements. This is Third-Party Risk (TP). Though the Software Approval Board is internal, it serves the purpose of managing third-party software risk.

Wait, let me reconsider. The Software Approval Board evaluates new software before purchase - this could be seen as an internal process (RMP). But the framing is about third-party software risk and vendor management.

The paragraph centers on third-party diligence and software evaluation for third-party products, with contractual oversight - so TP is the right category since the majority of the content focuses on managing third-party cyber risks. For specificity, the Software Approval Board is a named committee with explicitly listed cross-functional members from Quality, Internal Audit, Information Security, Business Systems, and R&D, which indicates firm-specific details at Level 3.


reasoning: The first two sentences answer 'how are third-party cyber risks managed?' with vendor due diligence and ongoing monitoring of third parties — this occupies the majority of the paragraph, making TP the primary category over RMP (the final sentence about internal assessments). All language is generic ERM vocabulary — 'vendor due diligence,' 'risk-based approach,' 'periodic assessments,' 'industry-standard guidelines and tools' — none of which passes the ERM test for domain terminology, and there are no firm-specific or verifiable facts.

thinking:
Let me analyze this paragraph.

Content: Vendor due diligence, third-party monitoring, risk-based approach, annual cybersecurity assessments using industry-standard guidelines.

Category: The first two sentences are about third-party risk management - vendor due diligence and ongoing monitoring of third parties. The third sentence shifts to the company's own annual cybersecurity assessments. The majority of text is about third-party oversight → Third-Party Risk.

Wait, let me re-read. First sentence: vendor due diligence for third parties with access to information assets.

Second sentence covers ongoing monitoring of third parties using a risk-based approach, while the third sentence addresses the IT team's annual cybersecurity assessments of internal systems. Two out of three sentences focus on third-party oversight, so this falls under Third-Party Risk Management.

Now I'm checking the specificity of the language used. The terms like "vendor due diligence," "cybersecurity practices," "vendor management program," and "risk-based approach" are all fairly generic business and ERM terminology. The "annual cybersecurity assessments" reference a standard cadence, and "information technology team" is a generic IT reference without specific cybersecurity details.

Looking at the remaining language—"industry-standard guidelines and tools" is also generic with no named standards cited. Even "cybersecurity assessments" and "cybersecurity practices" are just generic terms with cybersecurity as a qualifier. If I swap "cybersecurity" for "financial," the language still works perfectly, which suggests this is standard ERM boilerplate rather than domain-specific content.

The "information technology team" conducting assessments isn't a cybersecurity-specific title or firm-specific reference either. This is Level 1—Generic Boilerplate.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — the audit committee receives reports and oversees management's cybersecurity efforts, which is a classic BG oversight-structure description. No domain terminology, no firm-specific facts (audit committee is generic, 'annually' is a generic cadence), and no verifiable claims, so specificity remains Level 1.

thinking:
Classify this paragraph.

Category: This is about how the board (via audit committee) oversees cybersecurity. It answers "How does the board oversee cybersecurity?" → Board Governance.

Specificity: Let me scan for facts.
- "audit committee" — generic, every public company has one → not firm-specific
- "annually" — generic cadence → not firm-specific
- "management" — generic → not firm-specific
- No domain terminology — "cybersecurity threats and risks," "cybersecurity strategy and program" are generic business language
- No QV facts

- The language here is entirely boilerplate oversight language with no company-specific details. Level 1.


fact: February 2023 cyberattack — specific month+year tied to an actual cybersecurity incident

reasoning: The paragraph's core function is stating a materiality conclusion — the February 2023 cyberattack 'did not have... a material adverse impact on our consolidated financial position, results of operations or liquidity' — which is a backward-looking materiality assessment (SI per Rule 5). The remaining text is forward-looking speculation ('we cannot assure you...') and hypothetical risk language, which are subordinate. The specific date 'February 2023' tied to an actual cyberattack is a QV-eligible fact (externally confirmable event date), elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

The paragraph discusses the aftermath of a February 2023 cyberattack and future risk speculation. Let me classify it.

Content: It mentions a specific past incident (February 2023 cyberattack) but the primary thrust is a materiality assessment - stating that the attack "did not have... a material adverse impact on our consolidated financial position, results of operations or liquidity." The rest is speculation about future risks.

Category: The paragraph STATES A CONCLUSION about materiality - "the February 2023 cyberattack and our remediation efforts did not have...

a material adverse impact" - this is a backward-looking materiality assessment tied to an actual incident with business/financial framing, so it falls under Strategy Integration. The specific date "February 2023" linked to a real cybersecurity event qualifies for quantitative verification, though the materiality conclusion itself is a negative self-assertion that can't be externally verified. This puts it at Level 4.


fact: NIST Cybersecurity Framework

type: framework

fact: FFIEC Cybersecurity Assessment Tool

fact: Information Security Officer

fact: Information Technology Officer

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' — describing objectives, framework alignment (NIST CSF, FFIEC), and review cadence. The person-removal test confirms RMP: removing the officer references leaves a substantive program description intact. Specificity reaches Level 3 due to the Information Security Officer, a cybersecurity-specific leadership role unique to this company's organizational structure; the named frameworks (NIST CSF, FFIEC tools) provide domain terminology at Level 2.

thinking:
Let me analyze this paragraph.

Content: Describes the objective of managing cybersecurity risk, mentions alignment with frameworks (NIST CSF, FFIEC), and mentions the Information Security Officer and Information Technology Officer leading the program.

Category: "What does the cybersecurity program do?" - describes program objectives, framework alignment, review cadence. The mention of officers is brief attribution. Person-removal test: remove "led by our Information Security Officer in conjunction with our Information Technology Officer" → still has substantive program description about safeguards, framework alignment, review frequency. → RMP

Specificity:
- NIST Cybersecurity Framework → domain term (Level 2)

- FFIEC Information Technology Examination Handbooks and Cybersecurity Assessment Tool → domain terms/frameworks (Level 2)
- "Information Security Officer" → firm-specific cybersecurity role (Level 3)
- "Information Technology Officer" → IT title without security qualifier, so not firm-specific (Level 2)

Overall Level 3 due to the Information Security Officer designation.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing contractual requirements imposed on vendors, vendor risk profiling, monitoring, and a cyber review process as part of onboarding. Despite covering vendor oversight comprehensively, the language is entirely generic business/ERM terminology ('evaluation and monitoring,' 'contractually require,' 'risk profiles,' 'cybersecurity program') with no domain-specific terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
This paragraph is primarily about how third-party cyber risks are managed - vendor evaluation, monitoring, contractual requirements, onboarding review.

Category: Third-Party Risk - the central topic is oversight of external parties' cybersecurity.

Specificity: Let me scan for facts.
- "contractually require certain third parties... to maintain cybersecurity programs and to report actual or suspected security incidents" - this is generic process description
- "monitor and identify cybersecurity risks posed by third-party vendors based on their criticality and risk profile" - generic
- "cyber review process that is part of vendor onboarding" - generic process

No domain terminology that passes the ERM test. No firm-specific facts. No QV facts.

The language here is all standard business terminology without any concrete details about how this organization actually implements these controls. Everything described could apply to any company with vendor management practices, so this rates as Level 1.


reasoning: The paragraph's primary function is stating a materiality conclusion — 'have materially affected or are reasonably likely to materially affect our company, including our business strategy, results of operations, or financial condition' — which is the SEC's Item 106(b)(2) assessment language, making this SI. Specificity is Level 1: 'December 31, 2024' is reporting-period context not a cybersecurity fact, the negative materiality assertion is not externally verifiable, and the remaining language about sophisticated attacks is generic speculation with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

Content: The paragraph starts with a materiality assessment ("not aware of any risks... which have materially affected or are reasonably likely to materially affect"), then follows with speculation about future risks and sophistication of attacks.

Category: The first sentence is a clear materiality assessment - stating a conclusion about whether cybersecurity has affected business outcomes. This is SI per Rule 5. The remaining sentences are generic speculation but the materiality assessment is the primary content.

Specificity: Let me check for facts.

The reporting date is just context, not a cybersecurity fact. The materiality language is straight from the SEC's required disclosure template. There's no domain-specific terminology, no firm-specific details, and the statement about not being aware of risks is just a negative assertion that can't be verified. This is clearly Level 1 - Generic Boilerplate, the standard materiality assessment without any substantive cybersecurity information.


reasoning: The paragraph answers 'How does the board oversee cybersecurity?' — describing the Audit Committee's direct oversight role, periodic updates to the board, and notification protocols for significant threats. For specificity, 'Audit Committee' and 'Board of Directors' exist at every public company and are not firm-specific; 'Chief Business Officer' is not a cybersecurity-specific title; the 'outside information technology management/cybersecurity consultant' is unnamed; and no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me classify this paragraph.

Content: Describes how the Audit Committee and Board oversee cybersecurity risk, receive updates from the Chief Business Officer and outside IT consultant, and get notified about significant threats/incidents.

Category: This answers "How does the board oversee cybersecurity?" → Board Governance. The focus is on oversight structure and information flow to the board.

Specificity:
- "Audit Committee" — not firm-specific (every public company has one)
- "Chief Business Officer" — this is not a cybersecurity-specific title (like CISO, CTO, CIO). It's a general business role. NOT firm-specific.

- The outside IT consultant is unnamed and generic, not firm-specific or a qualified vendor fact
- No domain terminology that meets the ERM test, no qualified vendor facts

This doesn't contain any firm-specific facts or domain expertise → Level 1.


reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' — the CFO coordinates cybersecurity efforts and an escalation process routes issues through CEO/senior management to the board. Person-removal test: removing CFO, CEO, and senior management leaves only a thin description of communication and escalation, confirming MR. No domain terminology (prevention/detection/mitigation/remediation is general risk language), no firm-specific facts (CFO, CEO, Audit Committee are all generic roles present at every company), and no verifiable claims, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: Describes the CFO's role in coordinating cybersecurity efforts, communication with the cybersecurity team, and an escalation process from management to the board.

Category: This is about how management is organized - the CFO coordinates efforts, there's an escalation process through CEO, senior management, to Audit Committee and Board. The primary question answered is "How is management organized to handle cybersecurity?" The governance chain here is described from management's perspective - the CFO's coordination role and the escalation process. This is more about management's organizational role than board oversight.

Actually, I need to reconsider what's really central here. The CFO's coordination role is the main focus, and when I remove the specific titles, what remains is just the basic structure of communication and escalation - that's pretty thin. The passage is fundamentally about the roles these people play in the cybersecurity process rather than the governance framework itself. And checking the specificity - CFO and CEO are generic C-suite positions, not firm-specific details. This looks like it should be categorized as MR.

Looking at the language used throughout, there's nothing that stands out as domain-specific terminology or firm-specific facts. The terms like "prevention, detection, mitigation, and remediation" are standard risk management language, and "escalation process" is generic governance language. The Audit Committee and Board of Directors are standard corporate structures. This all points to Level 1 classification.


reasoning: This is a cross-reference pointing to Item 1A Risk Factors, with no substantive cybersecurity disclosure. N/O always receives Specificity 1.


reasoning: The paragraph describes the qualifications and experience of several officers (CFO, General Counsel, CAO) in managing risks including cybersecurity — this is about who handles cybersecurity and what qualifies them, making it MR. The titles listed (CFO, General Counsel, CAO) are generic C-suite roles not cybersecurity-specific, 'approximately 20 years or more' is a soft/hedged number failing the hard-number test, and 'managing risks arising from cybersecurity threats' is general business language — no domain terminology, firm-specific facts, or verifiable claims survive validation.

thinking:
Let me analyze this paragraph.

Content: Describes qualifications of several officers (SVP/CFO, SVP/General Counsel, SVP/CAO) - their degrees and experience managing risks including cybersecurity risks.

Category: This is about management qualifications and experience. Person-removal test: remove all person-specific content → almost nothing remains. This is MR.

But wait - these are generic C-suite titles (CFO, General Counsel, CAO) - not cybersecurity-specific roles. The paragraph describes their general risk management experience including cybersecurity.

Category: MR - it's about who manages cybersecurity risks and their qualifications.

Now I'm looking at how specific the experience claims are. The "approximately 20 years or more" phrasing is interesting - it sets a lower bound but the "approximately" qualifier softens it. The codebook treats clear lower bounds like "more than 20 years" as quantified, but this hedged version feels borderline. I'm leaning toward this not being quantified enough to count.

The roles listed - SVP CFO, SVP General Counsel, SVP CAO - aren't cybersecurity-specific positions according to the codebook, which explicitly excludes general executive titles like CEO and CFO. There's no domain terminology either, just generic business language about managing risks. This looks like Level 1 - Generic Boilerplate.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — it describes requirements imposed on vendors and additional diligence processes, making it TP. Specificity is Level 1 because 'Franklin Templeton' is a company self-reference (the Advisor's parent), and the remaining language ('confidentiality, security, and privacy requirements,' 'questionnaires and inquiries') is generic risk management vocabulary that any ERM professional would use, with no cybersecurity domain terminology, firm-specific facts, or verifiable claims.

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

Facts:
- "Franklin Templeton" - named entity (the Advisor's parent company), firm-specific
- "questionnaires and inquiries" - generic diligence terms
- "confidentiality, security, and privacy requirements" - generic

Category: Third-Party Risk - central topic is managing vendor/third-party cyber risks

Specificity: The mention of "Franklin Templeton" as a named entity - but this is basically a company self-reference (the Advisor's parent). Per the rules, "The Company, company self-references, subsidiary names" are NOT firm-specific.

Since Franklin Templeton is a self-reference and the other terms are generic without domain-specific language, this doesn't meet the threshold for higher classification. Level 1.


fact: ISO (Information Security Officer) — cybersecurity-specific leadership role

fact: Interagency Guidelines for Safeguarding Customer Information — named regulatory framework

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — the ISO reports directly to the board on the Information Security Program, making this a classic information-flow-to-board paragraph (BG). The ISO is a firm-specific cybersecurity leadership role (Level 3), and the Interagency Guidelines is a named framework (Level 2); the highest is Level 3. No QV-eligible facts are present (cadence is generic 'at least annually,' and compliance is self-reported, not an externally verifiable certification claim).

thinking:
Let me analyze this paragraph.

Content: The ISO (Information Security Officer) reports to the board annually on the Information Security Program status and compliance. Material findings are discussed.

Category: This describes how information flows to the board - the ISO reporting to the board. This is about board oversight structure - how the board receives information about cybersecurity. BG.

Specificity:
- "ISO" (Information Security Officer) - this is a cybersecurity-specific role at VP level or above? Actually, ISO = Information Security Officer. This is a firm-specific cybersecurity leadership role.
- "Interagency Guidelines for Safeguarding Customer Information" - this is a named regulatory standard/framework, domain terminology

- "Information Security Program" - could be a named internal program, though it's fairly generic
- "at least annually" - generic cadence, not particularly specific
- "security breaches" - general term
- "risk assessment, risk management" - general ERM terms

The ISO is a firm-specific cybersecurity role, and the Interagency Guidelines is a named external framework that qualifies as domain terminology. The question is whether compliance with this guideline counts as a QV-eligible fact - it's a real external reference, but the paragraph frames it as alignment rather than formal certification, which puts it more at the domain-adapted level.

The Interagency Guidelines for Safeguarding Customer Information is a specific named regulatory framework that qualifies as domain terminology, while ISO as an Information Security Officer role is firm-specific, making this Level 3.


fact: CDO (Chief Digital Officer) leading cybersecurity strategy

fact: Interim CISO

fact: CDO reports to the CEO

fact: CDO has over 20 years of experience

fact: Interim CISO brings nearly 20 years of experience

fact: Master's degree from Ecole Supérieure de Commerce de Chambéry, Rhône-Alpes, France

fact: Bachelor's degree from Miami University

reasoning: The paragraph is entirely about management's cybersecurity leadership — who holds the roles (CDO, interim CISO), their qualifications, experience, and education. Person-removal test leaves nothing substantive. Multiple QV-eligible facts: specific years of experience as lower bounds ('over 20 years', 'nearly 20 years') and named universities (Ecole Supérieure de Commerce de Chambéry, Miami University) are independently verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes CDO and interim CISO roles, their qualifications, experience, and education.

Category: This is about management's organizational role - who holds responsibilities, qualifications, credentials, career history. Person-removal test: remove all person-specific content and nothing substantive about a cybersecurity program remains. → MR

Specificity:
- CDO (Chief Digital Officer overseeing cyber) → firm-specific named role
- interim CISO → firm-specific named role

- Multiple quantified experience metrics (20+ years, nearly 20 years) and named institutions (Ecole Supérieure de Commerce de Chambéry, Miami University) with specific credentials (MBA, bachelor's in MIS and marketing) → all verifiable facts tied to individuals → Level 4


fact: CIO (Chief Information Officer) leads Information Security team

fact: CIO has led IT efforts since 2016

fact: More than 20 years of experience as an IT leader in the homebuilding industry

fact: Reports to Corporate General Counsel

reasoning: The paragraph answers 'how is management organized?' by detailing the CIO's qualifications, career history, responsibilities, and reporting line — person-removal leaves near-nothing. 'Since 2016' and 'more than 20 years of experience' are verifiable lower-bound claims, elevating to Level 4.

thinking:
Management Role - about CIO's qualifications, experience, reporting lines.

Facts: CIO (firm-specific role), "since 2016" (specific date), "more than 20 years of experience" (quantified, lower bound), reporting to Corporate General Counsel.

"More than 20 years of experience" is a lower bound quantified fact → QV.
"Since 2016" is a specific date → QV.


fact: CIO/CDO informs the Audit Committee on cybersecurity matters

reasoning: The paragraph primarily answers 'How does the board oversee cybersecurity?' — describing Board and Audit Committee oversight structure, briefing content, and information flow from management to the board. The CIO/CDO is a firm-specific cybersecurity leadership role (C-suite level) that elevates specificity to Level 3, while 'Audit Committee' and 'Board' are generic governance structures present at every public company.

thinking:
Let me analyze this paragraph.

Category: This describes how the Board and Audit Committee oversee cybersecurity. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

Specificity: Let me scan for facts.
- "CIO/CDO" — cybersecurity-specific leadership role at VP+ level → firm-specific (Level 3)
- "Audit Committee" — every public company has one, NOT firm-specific
- "Board" — generic, not firm-specific

- "annual reports" — generic cadence

The CIO/CDO is a firm-specific fact since it's a named C-suite role with cybersecurity oversight, and both titles appear in the codebook as cybersecurity-specific positions. So this rates Level 3.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing vendor diligence, contractual requirements imposed on third parties, and ongoing monitoring of vendor cybersecurity risks, making it TP. Despite the length, it uses only general business language (diligence, risk assessment, contractual requirements, audits) without any cybersecurity domain terminology that passes the ERM test; all terms would appear naturally in a non-cyber vendor risk management context.

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


fact: data encryption

reasoning: The paragraph is split between program activities (network security, data encryption, employee training, AI/LLM data protection) and board reporting structure, but the program description occupies the majority of text, so RMP wins over BG. 'Data encryption' is cybersecurity domain terminology (encryption as a security measure), elevating to Level 2. Other terms ('network security,' 'employee training,' 'measures to protect systems and data') are general business/IT language. 'Audit Committee,' 'Board of Directors,' and 'quarterly'/'annual' cadences are not firm-specific.

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. General cybersecurity measures (network security, data encryption, employee training)
2. AI/LLM data protection concern
3. Board/Audit Committee reporting structure

Primary question: This is split between RMP (what the program does) and BG (board oversight). The first two sentences describe program activities, the last sentence describes board oversight. The program description occupies more text.

Actually, let me re-read. The first sentence is quite generic - "network security, data encryption, employee training and other measures to protect our systems and data." The second sentence adds an AI angle. The third sentence is about board oversight.

By text volume, the program activities clearly dominate over the board oversight piece, so this falls under RMP. Looking at specificity, most of these terms are fairly generic—network security and employee training are standard IT language, while data encryption is slightly more domain-specific. The board and audit committee references aren't firm-specific either, and quarterly reports is just standard practice language. Category: RMP.

For specificity, "data encryption" as a security measure does qualify as domain terminology according to the codebook, which pushes this to Level 2 (Domain-Adapted).


fact: CISO

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing the audit committee receiving periodic reports from the CISO on threats, risks, and mitigation — a classic oversight-flow description. The CISO is a firm-specific cybersecurity leadership role (Level 3); the audit committee is generic and does not qualify. No QV-eligible facts are present.

thinking:
Classify this paragraph.

The paragraph describes how the audit committee receives reports from the CISO about cybersecurity threats/risks. This answers "How does the board oversee cybersecurity?" → Board Governance.

Specific facts:
- CISO (named cybersecurity role → firm-specific, Level 3)
- "audit committee" → every public company has one, NOT firm-specific

No QV facts. CISO is firm-specific → Level 3.


reasoning: The paragraph states materiality conclusions both backward-looking ('have not identified any known cybersecurity threats... that have materially impacted us') and forward-looking ('are reasonably likely to materially affect us'), making it SI per the materiality assessment rule. The cross-reference to Item 1A is subordinate to the actual assessments. Specificity is Level 1: 'more than 5 years' and 'penalties and settlements, of which there were none' are negative self-assertions not externally verifiable per the codebook, and all remaining language is standard SEC materiality boilerplate with no domain terminology or firm-specific facts.

thinking:
Let me analyze this paragraph carefully.

The paragraph has several components:
1. A cross-reference to Item 1A risk factors describing how cybersecurity risks may materially affect the company
2. A statement about not having identified material cybersecurity threats for more than 5 years
3. A statement about no penalties or settlements
4. A forward-looking statement about facing risks that are reasonably likely to materially affect

Let me classify:

**Content Category:** The paragraph primarily states conclusions about materiality - both backward-looking ("have not identified any known cybersecurity threats... that have materially impacted us") and forward-looking ("are reasonably likely to materially affect us").

Per Rule 5, these are materiality assessments → **Strategy Integration**.

The cross-reference portion alone would be N/O, but the substantive materiality assessments dominate.

**Specificity:**
"For more than 5 years" is a quantified timeframe, but it's attached to a negative assertion about the absence of material cybersecurity threats. Since negative self-assertions aren't externally verifiable per the codebook, I need to reconsider whether this specific timeframe claim actually qualifies as verifiable.

The statement about penalties and settlements being none is also a negative assertion without external verification. The remaining language is standard materiality boilerplate with no domain-specific terminology, firm-specific facts, or verifiable claims—this is Level 1 Generic Boilerplate that could fit any filing.


fact: SOC 2 Type II (SOC2 T2) documentation requested from vendors

fact: penetration testing documentation requested from vendors

fact: ISO 27001 certification and scope requested from vendors

fact: Third Party Cyber Risk Management Plan (named internal program)

reasoning: The paragraph's central topic is oversight of external parties' cybersecurity — due diligence, questionnaires, contractual requirements imposed on vendors, and ongoing review — squarely answering 'how are third-party cyber risks managed?' The named 'Third Party Cyber Risk Management Plan' is a firm-specific program identifier elevating to Level 3. Domain terms (SOC 2 Type II, penetration testing, ISO 27001) are present but these are standards requested FROM vendors, not certifications the company itself holds, so they remain at Level 2. No QV-eligible facts (no specific numbers, dates, named external firms, or company-held certifications).

thinking:
Let me analyze this paragraph.

Content: About third-party cyber risk management - questionnaires, assessments, contractual requirements imposed on vendors.

Category: Third-Party Risk (TP) - central topic is oversight of external parties' cybersecurity.

Specificity: Let me scan for facts.
- "Third Party Cyber Risk Management Plan" - named internal program with distinguishing identifier → firm-specific
- "SOC2 T2" (SOC 2 Type II) - domain term AND this is documentation requested FROM vendors, referencing a named standard
- "penetration testing" - domain term

- "ISO 27001 certification" - also requested from third parties as a named external standard, so domain terminology
- "security and privacy clauses" - generic language
- "at least annually" - generic cadence

The key distinction here is that SOC 2 Type II and ISO 27001 are both named frameworks the company requires vendors to provide documentation for, making them domain terms rather than firm-specific identifiers.

"Third Party Cyber Risk Management Plan" is the firm-specific element—it's a named internal program with a distinguishing identifier, similar to how "Cyber Incident Response Plan (CIRP)" would qualify. There are no quantifiable facts like specific numbers, dates, or named external firms involved, and "at least annually" is just a soft cadence.

This falls under TP, Level 3.


reasoning: The paragraph is split between describing third parties that serve the company's program (RMP) and requirements imposed on those providers (TP). The lengthy third sentence detailing certification requirements, security measure obligations, and breach reporting requirements imposed ON service providers tips the balance toward Third-Party Risk as the central topic. All language is general business/risk management vocabulary (risk assessment, policies and procedures, security measures, report breaches) with no cybersecurity domain terminology passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Describes third-party service providers in two roles: (1) helping design/implement the company's own cybersecurity program, and (2) requirements imposed on third-party providers regarding security measures.

Category: The first part describes third parties hired to serve the company (assessors helping with risk assessment, designing policies) → RMP per Rule 3. The second part describes requirements imposed ON service providers → TP. Need to determine which dominates.

Looking more carefully: "engage consultants... in connection with risk assessment processes" and "assist us in designing and implementing our cybersecurity policies" → RMP (third parties serving the company).

The third sentence shifts to requirements the company imposes on its vendors to maintain security measures, which is TP. But these are the same consultants mentioned earlier—the company is both using them to build its program and holding them to specific security standards. The paragraph is really about how the company manages third-party service providers across both dimensions: leveraging their expertise for RMP while also imposing contractual security obligations on them as TP. The third sentence about requirements takes up roughly as much space as the first two combined, and the overall arc moves from describing what these third parties do for the company toward what the company must require of them. That pushes me toward Third-Party Risk as the primary classification. Looking at the specifics, I'm not finding firm names or concrete details—just general references to consultants and risk assessment processes.

Scanning through the language, everything reads as standard boilerplate: cybersecurity policies, monitoring safeguards, vendor certifications, breach reporting. No domain-specific terminology, no company facts, no quantifiable details. This is Level 1 generic language.


reasoning: The paragraph's central topic is how the company manages cybersecurity risks from third-party providers—due diligence, contractual requirements, and third-party incident response—directly answering 'how are third-party cyber risks managed?' No cybersecurity domain terminology is used (due diligence, contractual provisions, and 'appropriate cybersecurity measures' are all generic business/ERM language), no firm-specific facts, and no verifiable claims, so specificity remains Level 1.

thinking:
Let me classify this paragraph.

Content: About managing third-party cyber risks - due diligence, contractual provisions, incident response for third-party incidents. Central topic is vendor/third-party oversight → Third-Party Risk.

Specificity: Let me scan for facts.
- "due diligence on cybersecurity practices and controls" - generic
- "contractual provisions requiring providers to maintain appropriate cybersecurity measures" - generic, no specific requirements mentioned
- No domain terminology, no firm-specific facts, no QV facts

This is all general business language about vendor management. No cybersecurity domain terms pass the ERM test.

The language around cybersecurity practices and measures lacks any concrete specifics—no mention of SOC 2, encryption standards, or other technical requirements. This lands it at Level 1.


reasoning: The first sentence states a materiality conclusion — no threats or incidents materially affected (backward-looking) or are reasonably likely to materially affect (forward-looking, SEC 106(b)(2) language) the business, making this SI per Rule 5. Specificity is Level 1: the 2023 negative assertion is a self-reported claim about absence, which is not externally verifiable; there is no domain terminology, no firm-specific facts, and the remaining text is generic speculation and a cross-reference.

thinking:
Let me analyze this paragraph.

Content: States no material incidents in 2023, acknowledges residual risk, cross-references Risk Factors.

Category: The first sentence is a materiality assessment - "did not identify any cybersecurity threats or incidents that materially affected or are reasonably likely to materially affect our business strategy, results of operations, or financial condition." This is SI per Rule 5 (backward-looking + forward-looking materiality assessment). The rest is speculation/disclaimer and a cross-reference, which are subordinate.

The statement itself is a negative self-assertion without external verification or domain-specific details—just a bare claim that no material incidents occurred in 2023, which doesn't meet the threshold for verifiable facts. This lands at Level 1.


reasoning: This is pure speculation about potential breaches without describing any substantive cybersecurity measures, processes, or assessments. The mention of 'Koichi' is a named individual but in a context of vague belief about 'adequate internal security measures' with no actual program description — this is closer to a disclaimer than a disclosure. N/O at Level 1.


reasoning: The paragraph primarily answers 'how are third-party cyber risks managed?' — it acknowledges third-party cyberattack risk and describes outreach to providers to assess downstream implications of known breaches, making vendor oversight the central topic. All language is generic business prose ('significant measures,' 'outreach to our providers,' 'ascertain potential downstream implications') with no cybersecurity domain terminology, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party cyberattack risk, mentions high-profile attacks at other companies, and describes measures including "outreach to our providers and other third-parties" to assess downstream implications of breaches.

Category: The central topic is about third-party cyber risk management. It acknowledges third-party risk and describes what they do about it (outreach to providers to ascertain downstream implications). This answers "How are third-party cyber risks managed?" → Third-Party Risk.

Wait, let me reconsider. The paragraph starts with third-party risk acknowledgment, then discusses high-profile attacks generally, then mentions measures including outreach to providers.

The measures described are about assessing vendor and third-party breach implications, which is clearly third-party risk management. The language about taking significant measures to prevent and mitigate issues caused by attacks, including outreach to providers, centers on managing third-party cyber risk.

Now I'm checking the specificity. Looking at the facts mentioned: references to healthcare companies, credit bureaus, and financial institutions are just general industry examples, not specific to this firm. The description of outreach to providers and third-parties is generic without concrete details. There's no specialized domain terminology, no firm-specific facts, and nothing that would qualify as quantitative or verifiable information. Everything here is standard business language about cyberattacks.

This is Level 1 generic boilerplate—the topic is cyberattacks but the measures described are vague and lack any substantive detail.


reasoning: The paragraph describes management reporting to the audit committee about cybersecurity risks, which answers 'how does the board oversee cybersecurity?' — per Rule 1, management reporting TO the board describes the oversight flow and defaults to BG. Specificity is Level 1: 'audit committee' exists at every public company (not firm-specific), 'members of management' is generic, and 'cybersecurity threat risks' is general business language that fails the ERM test.

thinking:
Classify this paragraph.

"As discussed above, these members of management report to the audit committee about cybersecurity threat risks, among other cybersecurity related matters."

Category: This describes management reporting TO the board (audit committee) about cybersecurity. Per Rule 1, "Management reports TO the board (describing oversight flow)" → BG.

Specificity: "audit committee" is not firm-specific (every public company has one). "members of management" is generic. No domain terminology beyond general risk language. "cybersecurity threat risks" - does this pass the ERM test? No, "threat risks" is generic.

So this is Level 1 specificity.


fact: Franklin Templeton (named parent entity)

reasoning: The paragraph describes third-party service provider relationships for cybersecurity containment and remediation, making TP a reasonable fit since it's about external parties' role. However, these third parties serve the company's own program (containment/remediation), which could point to RMP. The central topic is the existence of third-party relationships, tipping toward TP. 'Franklin Templeton' is a named entity providing firm-specific context, but the third-party providers themselves are unnamed ('a number of third party service providers'), and 'containment and remediation' are general terms that don't pass the ERM test as domain terminology. Franklin Templeton as the named parent organization is a firm-specific identifier.


fact: cyber threat detection and response

fact: security engineering

fact: CIO (chief information officer) leads cybersecurity program

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' — it details the CIO's responsibilities, reporting lines to CEOs, the CompX director of IT's reporting structure, and team experience across entities. Person-removal test: removing all role/reporting/experience content leaves only brief mentions of third-party assessments and annual reviews, confirming management organization is the substance. Specificity reaches Level 3 via the CIO as a cybersecurity-specific VP+ leadership role.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph describes management's organizational structure for cybersecurity across multiple entities. It covers the CIO's role, reporting lines, the CompX director of IT, their responsibilities, and team experience. There's also some program activity description (third-party assessments, audits, risk reviews).

Person-removal test: Remove CIO, director of IT, titles, reporting lines, qualifications, team composition. What remains? "Kronos and CompX each have their own cybersecurity programs... cybersecurity risks are reviewed and tested annually through third-party assessments and internal and external information technology audits...

Information technology teams review cybersecurity risks at least annually, integrating findings into strategic risk assessments." That's somewhat substantive but the bulk of the paragraph is about who leads what, reporting lines, and experience. The organizational structure is the primary content. → MR

Specificity:
- CIO (cybersecurity-specific VP+ title) → firm-specific
- "director of information technology" - this is "Director of IT" which per the codebook is NOT firm-specific (IT title below VP without security qualifier)
- Reporting lines to CEO → not firm-specific
- "vice president in charge of coordinating operational activities" - not a cybersecurity role
- Named entities: Kronos, CompX, Contran - these are subsidiary/company names

, not external firms
- "third-party assessments" - unnamed → not QV
- "extensive information technology and program management experience" - soft, not quantified
- "many years of experience" - soft number
- "annually" - generic cadence

The CIO role as a named cybersecurity leadership position pushes this to Level 3. Domain terminology like "cyber threat detection and response" and "security engineering" also appear, which would suggest at least Level 2, but the firm-specific CIO designation is the stronger signal here.

So: MR, Firm-Specific (Level 3) due to CIO.


reasoning: The paragraph opens with two sentences describing how the Audit Committee receives reports and has access to cybersecurity-related materials — answering 'how does the board oversee cybersecurity?' The final sentence is a boilerplate materiality assessment (SI), but the BG content occupies slightly more text and frames the paragraph. No domain terminology, firm-specific facts, or verifiable claims are present — 'Audit Committee' exists at every public company, 'cybersecurity function' is generic, and the materiality language is standard SEC boilerplate.

thinking:
Let me analyze this paragraph.

It has two main parts:
1. Audit Committee receives reports from cybersecurity function about threats/risks/processes - this is Board Governance
2. Materiality assessment statement - this is Strategy Integration

The materiality assessment is a clear SI conclusion. But the first part is BG. Which dominates?

The first two sentences describe board oversight (BG). The last sentence is a materiality assessment (SI). Text-wise, roughly split. The last sentence is a full materiality conclusion using SEC language.

When genuinely split, the category with the most text wins.

Looking at the actual content, the materiality statement is quite substantial—it's a comprehensive declaration that they haven't identified material cybersecurity risks affecting operations, strategy, or financial condition. That's using the exact SEC language. The oversight structure takes up two sentences, but the materiality assessment, while one sentence, is dense and substantive. I think this actually leans SI despite the sentence count, given how much weight that materiality statement carries. Looking at the specificity now—"Audit Committee," "cybersecurity function," and "materially affected" are all standard governance language without any firm-specific details or domain expertise. This is clearly Level 1 boilerplate.


reasoning: The paragraph opens with one sentence on board oversight but shifts its primary focus to identifying CFO and CEO as the management members responsible for cybersecurity — answering 'how is management organized?' More text is devoted to management's role than to board oversight, so MR wins over BG. For specificity, CEO and CFO are explicitly listed as NOT firm-specific (generic governance roles at every public company), no domain terminology is present, and 'subsequent to June 30, 2024' is the company's fiscal year-end used as a temporal reference rather than a specific cybersecurity event date, so no facts elevate above Level 1. The paragraph also appears truncated.

thinking:
This paragraph appears truncated. Let me classify it based on what's present.

The paragraph discusses both board oversight and management roles (CFO, CEO). The primary question: it starts with board oversight but then shifts to management's role. The board mention is brief ("Board of Directors is responsible for oversight of cybersecurity risk" - one sentence). Then it discusses CFO and CEO as responsible for managing cybersecurity practices.

This is a governance-chain paragraph. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure. But here the board mention is brief, and the focus shifts to management roles. However, the paragraph seems truncated so it's hard to tell the full intent.

Looking at the text more carefully, the board oversight is stated in one sentence while the management portion—specifically naming the CFO and CEO and their responsibilities—takes up more space and detail. The paragraph is really focused on identifying which management roles are responsible for what, which suggests this leans toward MR rather than BG.

But wait, I need to reconsider what counts as firm-specific. "Board of Directors," "CFO," and "CEO" are all generic governance titles that appear in every company's structure, not unique to this firm. However, the date reference "subsequent to June 30, 2024" is interesting—it's tied to when they started managing cybersecurity practices, which makes it a specific, verifiable fact about when this responsibility began. That temporal marker could push this toward QV.

Now I'm wrestling with how to categorize this paragraph. It's describing the governance chain—board provides oversight, CFO and CEO manage operations. The governance-chain rule suggests these default to BG when they're explaining the oversight structure, but the core question here is really about how management is organized, which leans more toward MR. The board context is secondary. I think MR is the right call since the focus is on who's responsible for managing these practices.

On specificity, the CFO and CEO aren't firm-specific details, but that date—June 30, 2024—is tied to a cybersecurity fact about when management took on these responsibilities. That makes it verifiable and QV-eligible, though I'm second-guessing whether a date alone carries enough weight without more context about what actually changed. I'm settling on this as a specific date boundary that qualifies for quantified-verifiable. Now I need to finalize the categorization—the paragraph mentions the board's oversight role, but the bulk of the content focuses on management's responsibilities for cybersecurity and risk assessment. Since the governance structure framing is relatively brief compared to the management duties described, I'm leaning toward management responsibility rather than board governance. The statement about the organizational change after June 30, 2024 does seem to indicate a specific, verifiable fact rather than just reporting context. So I'm settling on MR with Level 4 based on that date, though I'm questioning whether an external party could actually verify this claim independently. But that's different—here the date is actually tied to when they started managing cybersecurity, so it's marking a specific organizational change rather than just a reporting period. I'm going to stick with Level 4, though I'm less confident about it now.

Actually, I'm overcomplicating this. Let me step back and look at what firm-specific facts are actually present. The codebook says CFO and CEO aren't firm-specific, and I don't see domain terminology or named committees. Board of Directors, CFO, CEO, cybersecurity practices—none of these qualify as firm-specific either. This might actually be Level 1.

The date "subsequent to June 30, 2024" is tricky though. It's the company's fiscal year end, so using it to time an organizational change feels close to reporting context, but it's still dating something that happened. Even so, without any real firm-specific facts or domain terms, I'm settling on Level 1 with moderate confidence.

Actually, wait—I'm noticing the paragraph itself is truncated and clearly a cybersecurity disclosure, just extremely generic. The board gets mentioned briefly but the focus is really on management actions, so MR fits better than BG. This is Generic Boilerplate at Level 1.


fact: penetration testing firms

reasoning: The paragraph's central topic is how the company manages cybersecurity risks from third-party providers — describing a vendor management standard, risk assessments of vendors, security audits, and contractual obligations imposed on providers. While the first sentence mentions third parties hired to serve the company (which leans RMP per Rule 3), the bulk of the text describes oversight processes imposed ON vendors, making TP the dominant category. 'Penetration testing' is the sole domain term elevating specificity to Level 2; the remaining language (risk assessments, security documentation reviews, security questionnaires) is generic ERM vocabulary.

thinking:
Let me analyze this paragraph.

Content Category: The paragraph discusses third-party service providers and vendor management. The central topic is how third-party cyber risks are managed - vendor management standards, risk assessments of vendors, contractual obligations imposed on providers. This is Third-Party Risk (TP).

Wait, let me re-read. The first sentence describes third parties hired to serve the company (assessors, pen testers, consultants) → that's RMP per Rule 3. But then the paragraph shifts to vendor management processes, requirements imposed on vendors, security audits of vendors → that's TP.

The majority of the text is about vendor management processes.

The opening sentences provide context about the types of third parties engaged, but the bulk of the paragraph focuses on how vendors are overseen through management standards and security processes. That makes this fundamentally about vendor oversight, so it's TP. Looking at the specifics, I can identify "penetration testing" as a clear domain term, while the rest of the language is fairly generic—vendor management standards, risk assessments, security documentation reviews, and audits are all standard terminology without much distinguishing detail.


fact: Marco Technologies as Managed IT provider

fact: Red Canary for 24/7 endpoint monitoring

fact: High Point Networks for network data backup

fact: Return to Operations objectives of less than 24 hours

fact: cybersecurity trainings required monthly

fact: 24/7 monitoring on all endpoints with isolation triggers

fact: physical and cloud-based network data backup solutions

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing outsourced security functions via named third-party providers (Marco Technologies, Red Canary, High Point Networks) — these are firms hired to serve the company's own security, making this RMP per Rule 3. The CFO mention is subordinate. Multiple named external firms and the quantified RTO objective (<24 hours) elevate specificity to Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes third-party technology providers (Marco Technologies, Red Canary, High Point Networks) that handle IT infrastructure, cybersecurity training, endpoint monitoring, and data backup. Also mentions the CFO's role in coordinating these providers.

Category: This is primarily about third-party providers managing cybersecurity. The central topic is how external parties handle cyber risks. But wait - these are third parties hired to serve the company's own security program, not vendors whose cybersecurity posture is being assessed. Per Rule 3: "Third parties hired to serve the company (assessors, pen testers) → RMP."

These service providers essentially form the backbone of the company's outsourced cybersecurity function, so this falls under RMP rather than vendor risk assessment. The paragraph is answering what the cybersecurity program actually does—it's delegated to these external providers, with the CFO overseeing the coordination.

Looking at specificity, I've got named firms like Marco Technologies, Red Canary, and High Point Networks which are quantifiable vendors, plus domain-specific details like endpoint monitoring, 24/7 monitoring cadence, and the 24-hour recovery objective. The monthly training frequency is more generic, but the overall description has enough firm-specific and quantified elements to be substantive.


reasoning: The paragraph answers 'How does the board oversee cybersecurity?' by describing delegation of oversight to the Audit Committee. No domain terminology, no firm-specific facts (Board of Directors and Audit Committee exist at every public company), and no verifiable claims — remains Level 1.


fact: Chief Technology Officer (CTO)

fact: Chief Information Security Officer (CISO)

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — the board oversees the program and receives reports from named officers, fitting the governance-chain pattern that defaults to BG. CTO and CISO are cybersecurity-specific leadership titles (firm-specific), but no verifiable facts (no specific dates, numbers, certifications, or named external entities) are present, so specificity is Level 3.

thinking:
Governance-chain paragraph: Board oversees, receives reports from CTO/CISO.

Category: BG - answers "how does the board oversee cybersecurity?"

Specificity: CTO and CISO are firm-specific roles. No QV facts (no specific numbers, dates, named external entities, certifications).

Level 3.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — describing delegation to the Audit Committee, quarterly reporting from the CISO, incident escalation procedures, and annual board briefings. The VP/CISO title is firm-specific, but no QV-eligible facts (cadences like 'quarterly' and 'annually' are generic, and 'Audit Committee' exists at every public company), placing this at Level 3.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph answers "How does the board oversee cybersecurity?" - Board delegates to Audit Committee, Committee oversees, receives reports, reports to full Board. This is clearly Board Governance.

Specificity: Let me scan for facts:
- "Vice President and Chief Information Security Officer (CISO)" - named role, firm-specific (VP-level + CISO)
- "Audit Committee" - NOT firm-specific (every company has one)
- "quarterly reports" - generic cadence

- Annual reporting requirement - also generic cadence

The CISO/VP title is the only firm-specific detail here. No quantifiable facts, dates, named external entities, or certifications present. This lands at Level 3.


reasoning: This paragraph is a cross-reference directing readers to Item 1A for information about how cybersecurity threats may materially affect the business. Per the codebook, cross-references pointing elsewhere ('risks that may materially affect... see Item 1A') are N/O, not SI — no materiality conclusion is stated here. No substantive cybersecurity disclosure present.


reasoning: The paragraph contains a backward-looking materiality assessment ('no such incident has had any such impact to date'), which per the codebook constitutes an SI conclusion even though it is followed by a cross-reference to Item 1A. The cross-reference is subordinate to the assessment. Specificity is Level 1 because all language is generic business/risk terminology ('protocols, controls, and systems,' 'material adverse impacts') with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. Generic statement about monitoring and updating protocols/controls/systems
2. "no such incident has had any such impact to date" - negative assertion about materiality
3. Cross-reference to Item 1A for materiality assessment

The key question: what does this primarily answer?

The materiality language here is tricky. "no such incident has had any such impact to date" is a backward-looking negative assertion - that's SI-adjacent. But then it says "For additional information regarding whether any risks... have materially affected or are reasonably likely to materially affect... please refer to Item 1A" - this is a cross-reference pointing elsewhere for the materiality assessment.

So I'm looking at the structure more carefully. The "could cause" language is speculative, which wouldn't trigger SI. But the backward-looking statement that no incidents have had material impact - that's the SI piece. The cross-reference to Item 1A is just pointing elsewhere for the full materiality discussion, which makes it N/O. Per the codebook, when you have a negative assertion about past impacts combined with a cross-reference for forward-looking materiality, the backward-looking part codes as SI. The codebook example shows that even when a cross-reference follows, if there's an explicit materiality assessment in the paragraph itself, it counts as SI. Here the statement "no such incident has had any such impact to date" is that assessment, so despite the reference to Item 1A, this should be classified as SI.

For specificity, the language stays generic—no domain-specific terminology about actual security controls or systems, no company-specific facts, and the negative assertion about incidents isn't verifiable. The reference to the risk factor title is just a cross-reference, not a substantive cybersecurity detail. This points to Level 1.