reasoning: The CISO is mentioned as attribution, but the paragraph's substance is entirely about processes: threat intelligence, monitoring tools, regulatory compliance, information sharing, training, and insurance. The person-vs-function test clearly points to Risk Management Process. Specificity reaches Quantified-Verifiable with two named external organizations (E-ISAC and DOE's CRISP program) that are independently verifiable, plus the named internal program CISS, named regulatory frameworks (NERC CIP, TSA Security Directives), and a cybersecurity-specific role (CISO).

thinking:
Let me analyze this paragraph carefully.

Content: The paragraph describes Exelon's cybersecurity processes led by the CISO through CISS. It covers threat intelligence, tools, regulatory compliance (NERC CIP, TSA Security Directives), information sharing (E-ISAC, CRISP), employee screening, training, and cyber insurance.

Category: The CISO is mentioned as attribution at the start, but the paragraph is overwhelmingly about what the program DOES - tools, processes, regulatory compliance, information sharing, training, insurance. Person-vs-function test: remove "The CISO, through Exelon's CISS" and the paragraph still makes complete sense as a process description. → Risk Management Process.

Now I'm identifying which facts are firm-specific versus externally referenced. The CISO role and CISS program are internal to Exelon, while NERC CIP and TSA Security Directives are industry standards. E-ISAC and CRISP are external organizations—E-ISAC as a third-party information sharing group and CRISP as a Department of Energy program—so those could potentially qualify as named firms for QV purposes. I'm checking whether E-ISAC and CRISP qualify as named third-party firms for the QV requirement—they're externally verifiable organizations, so I think they count. Combined with the Grid Security Exercises as a named specific program, I might have enough QV-eligible items to reach Firm-Specific level, though I'm still short on the hard metrics like dates, dollar amounts, or headcounts. I'm reconsidering whether E-ISAC and CRISP actually meet the QV threshold—they're coordination bodies rather than commercial vendors like the examples given, so I'm leaning toward Firm-Specific as the more conservative classification.

fact: Cyber Information and Security Services (CISS)

fact: North American Electric Reliability Corporation's Critical Infrastructure Protection (NERC CIP)

fact: TSA Security Directives

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

fact: Department of Energy's Cybersecurity Risk Information Sharing Program (CRISP)


content_category: Management Role

category_confidence: medium

specificity_confidence: high

reasoning: Management is the grammatical subject, described as responsible for implementing cybersecurity policies and reporting to the Board. However, this is borderline with Board Governance since the reporting-to-board relationship is prominent. No cybersecurity-specific titles (CISO, CIO, CTO) are named — only generic 'management' — and cadences ('at least annually') are generic, yielding no facts from the IS list.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Classify this paragraph.

Content: Management implements/maintains cyber policies, reports to Board. Updates at least annually.

Category: The grammatical subject is "Management" but it's describing their responsibility in generic terms. This is about management's role but in a very generic way. The second sentence is about reporting to the Board.

This is a borderline Board Governance vs Management Role. The primary actor in sentence 1 is "Management" - responsible for implementing and reporting to the Board. Sentence 2 is about updates to the Board. The paragraph is about management's responsibility and reporting relationship to the board.

Management is the subject describing their responsibilities, so this leans toward Management Role. But looking closer, there are no named roles like CISO or CIO, no specific qualifications, and no particular person—just generic "management." The language is vague: "at least annually" is a standard cadence with no specific frameworks or facts referenced. This reads as Generic Boilerplate.


content_category: Risk Management Process

category_confidence: high

reasoning: The paragraph describes the company's internal security training infrastructure (LMS) and its process for integrating acquired companies — these are internal cybersecurity processes. No named frameworks, cybersecurity-specific roles, specific dates, tools, or other facts from the IS list are present; 'Learning Management System (LMS)' is a generic term, not a named product or unique identifier.

thinking:
Classify this paragraph.

Content: Describes training programs housed in an LMS, and migrating acquired companies into it. This is about internal cybersecurity processes (training programs, systems used).

Category: Risk Management Process - describes internal security training infrastructure.

Specificity: The paragraph mentions "Learning Management System ('LMS')" - this is a generic program name with an abbreviation. Is "LMS" a specific fact? LMS is a very common term, not unique to this company. The paragraph describes a generic practice (security training in an LMS, migrating acquisitions). No named frameworks, no cybersecurity-specific roles, no specific dates, numbers, or named tools.

So this falls under Generic Boilerplate since it's just describing standard security training practices without any company-specific details or named products.


content_category: Board Governance

reasoning: The Audit Committee is the grammatical subject charged with overseeing cybersecurity risk, making this Board Governance. The CISO reporting line is subordinate detail supporting the board oversight frame. CISO is a cybersecurity-specific title on the IS list, elevating to Firm-Specific, but there are not two QV-eligible hard facts (named roles don't count toward QV).

thinking:
Let me analyze this paragraph.

Content: The Audit Committee oversees cybersecurity risk. CISO and SVP Internal Audit report to the Audit Committee and Board.

Category: The Audit Committee (board committee) is the grammatical subject of the first sentence. The second sentence describes reporting TO the committee. This is about board oversight. → Board Governance

Specific facts:
- CISO (cybersecurity-specific title) → IS list
- "Senior Vice President, Internal Audit and Risk" — this is not a cybersecurity-specific title per the IS list
- "Audit Committee" — NOT list (generic governance)

- One IS fact identified: CISO, which qualifies this as Firm-Specific. No quantifiable metrics like dates, dollar amounts, or headcounts are present, so this doesn't meet QV criteria.

Specificity level: Firm-Specific (3)

fact: CISO


reasoning: While the paragraph opens with reporting structure and briefly describes monitoring/escalation processes, the dominant content is about the persons holding cybersecurity leadership roles — their titles, years of experience, career histories, education, and certifications. The person-vs-function test confirms Management Role: the extensive credential detail (25 years, 20 years, CISM, Zero Trust Certified Architect, M.Sc.) is about who these people are, not what the program does. Multiple QV-eligible hard facts (two specific experience durations + two named certifications) place this at Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Reporting structure (CIO, Senior Director of Information Security)
2. What the team does (monitoring, prevention, detection, etc.)
3. Escalation procedures for incidents
4. Qualifications of the CIO and Senior Director

The primary content is about the people - their roles, reporting lines, experience, and credentials. The process description (monitoring, prevention, etc.) is relatively brief compared to the extensive credential/background information.

Applying the person-vs-function test: The paragraph spends significant text on who these people are - their titles, years of experience, career history, education, certifications.

Now I'm looking at the specific qualifications mentioned. The CIO and Senior Director of Information Security both have extensive experience - over 25 and 20 years respectively - along with relevant degrees and certifications that make them QV-eligible. This confirms the paragraph is fundamentally about identifying and describing the qualifications of these two key security leaders.

fact: Chief Information & Digital Officer (CIO)

fact: Senior Director, Information Security

fact: CIO has over 25 years of experience

type: quantified

fact: Senior Director has over 20 years of experience

fact: Certified Information Security Manager (CISM)

fact: Zero Trust Certified Architect certification

fact: M.Sc. in Computer Information Systems


reasoning: The CISO is the grammatical subject ('The CISO... regularly informs') and the paragraph's primary content is the reporting/escalation chain — CISO → CFO/President/CEO → Compliance Committee → Board. Per the decision table, 'Reporting lines as primary content' maps to Management Role. No credentials or background are given, but the person-vs-function test still points here because the paragraph is about who reports to whom, not about what the program does. CISO is a cybersecurity-specific title (IS list), and Compliance Committee is a named non-generic committee, yielding Firm-Specific. Neither qualifies as QV-eligible hard facts.

thinking:
Let me analyze this paragraph.

Content: Describes reporting lines - CISO reports to CFO, President, CEO about cybersecurity risks. Significant matters escalated to Compliance Committee and full Board.

Category: The paragraph is about reporting structure - who the CISO reports to and how information flows up to the board. The CISO is the grammatical subject performing the reporting. But the primary purpose is describing the reporting/escalation chain. This is about management reporting lines and how information flows to the board.

The CISO is the primary actor here - "The CISO... regularly informs..." - so this leans Management Role. But it's also about board oversight through the escalation process.

Looking at the reporting chain, the CISO is clearly the grammatical subject taking action, which points toward Management Role. The content focuses on reporting lines and escalation procedures rather than personal qualifications or background. Since there are no credentials or biographical details mentioned, and the table indicates that reporting structures and management committee composition fall under Management Role, this is definitely Management Role. The CISO title is cybersecurity-specific, which satisfies the specificity requirement.

Now checking whether this qualifies as Firm-Specific: the Compliance Committee appears to be a named non-generic committee—it's not the standard "Audit Committee"—so that's another IS-list fact. However, there are no specific dates, dollar amounts, headcounts, named third-party firms, products, or certifications that would make this QV-eligible. With at least one IS fact present but no QV eligibility, this is Firm-Specific.

fact: Compliance Committee


reasoning: The paragraph's opening frame is about the company's process for identifying and remediating cybersecurity risks integrated into the overall ERM system. While it contains substantial Management Role content (CISO credentials, 15 years experience, CISSP) and Board Governance content (Risk and Technology Committee oversight, Board's active role), the dominant communicative purpose is describing how the risk management system works — who is involved, how escalations flow, and how oversight is structured. The CISO credentials and board involvement are presented in service of explaining the risk management apparatus. Two QV-eligible hard facts: 'over 15 years' of experience and named CISSP certification.

thinking:
Let me analyze this paragraph carefully.

This is a dense, multi-topic paragraph. Let me identify the themes:

1. Risk management process integrated into overall risk management
2. CISO and CRO oversight, reporting to Board and Risk and Technology Committee quarterly
3. CISO provides ongoing oversight using qualitative and quantitative risk assessments
4. Risk escalations through ERM framework, Enterprise Risk Committee, Board via Risk and Technology Committee
5. Board takes active role in overseeing cybersecurity program
6. CISO has over 15 years of experience, previous senior leadership at major financial institutions, CISSP certification

7. The broader cybersecurity leadership team brings additional expertise and relevant certifications
8. The Enterprise Risk Committee includes the CRO, CLO, CTO, CCO, CPO, and FIS Business Presidents

The dominant themes here are the organizational structure for risk oversight and the qualifications of the leadership team managing it. The paragraph establishes both the governance framework and the credentials of those executing it. The paragraph really does blend all three categories—governance structure, management credentials, and risk processes—but the text distribution is genuinely split between describing the organizational hierarchy and oversight mechanisms versus the CISO's qualifications and experience. I'm leaning toward this being primarily about governance and oversight structure, since the bulk of the content focuses on who reports to whom, committee composition, and board involvement, even though the credentials section is substantial enough to make it a close call. I'm settling on Risk Management Process as the primary category since the paragraph frames everything around the risk management system itself, even though the people and their qualifications take up significant space. Now I'm checking which facts qualify as IS-list items and which are QV-eligible: the CISO title, both named committees, the 15+ years of experience, and CISSP certification all check the boxes, while the Chief Risk Officer, Chief Privacy Officer, and Chief Compliance Officer don't meet the cybersecurity-specific criteria.

Looking at the QV-eligible facts specifically, I've got two that count: the 15 years of experience and the CISSP certification. That gives me a Quantified-Verifiable classification. The "quarterly basis" mention is just a generic cadence, so that doesn't add anything.

fact: Chief Information Security Officer

fact: Risk and Technology Committee

fact: Enterprise Risk Committee

fact: Over 15 years of technology and cybersecurity experience

fact: CISSP certification

fact: Chief Technology Officer

fact: Committee composition: CRO, CLO, CTO, CCO, CPO, FIS Business Presidents


reasoning: The paragraph's primary content describes the company's internal cybersecurity program—policies, processes, controls, and framework alignment—making it Risk Management Process. Board and management are mentioned as brief attributions, not as primary actors. Named frameworks (Secure Controls Framework, NIST, ISO) push specificity to Sector-Adapted, but no firm-specific facts from the IS list (no cybersecurity-specific titles, dates, headcounts, named tools, or named firms) are present to reach Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Discusses management and Board recognizing importance of IT security, mentions ERM process identifying cybersecurity as key risk, describes policies aligned with Secure Controls Framework (meta-framework reflecting NIST and ISO), and the focus of the cybersecurity program.

Category: This spans multiple areas - mentions both management and Board, but the primary content is about the company's risk management processes, framework adoption, and program focus. The Board/management mentions are brief attributions. The bulk is about processes and frameworks. → Risk Management Process

Specificity:
- Names "Secure Controls Framework" - this is a named framework → Sector-Adapted at minimum

- Also references NIST and ISO as underlying standards, which are recognized sector frameworks
- The SCF itself is a real, recognized meta-framework, not firm-specific, so naming it still counts as Sector-Adapted
- No firm-specific facts present - no cybersecurity-specific titles, no dates, no named tools, no headcounts

Testing against the criteria: I don't have two or more hard verifiable facts that would push this higher, and there are no IS-list facts that would make it firm-specific.

Since there are named standards (NIST, ISO, and the Secure Controls Framework), this classifies as Sector-Adapted → Risk Management Process, Sector-Adapted.

fact: Secure Controls Framework (meta-framework)

type: framework

fact: NIST

fact: ISO


specificity_confidence: medium

reasoning: The paragraph describes the company's internal incident response process — how incidents are investigated, classified, assessed for threat level, and escalated. The named officers are part of the escalation procedure description, not about the persons themselves, so this is about the function (Risk Management Process), not the people (Management Role). The specific enumeration of the escalation group (CEO, CLO, EVP/Operations, CRO, CFO) constitutes a firm-specific team composition unique to this company's disclosure, though the individual titles are mostly generic C-suite roles.

thinking:
Let me analyze this paragraph.

Content: Describes incident response plans, cross-functional teams assessing threat levels, escalation procedures to specific officers.

Category: This is about the company's internal incident response process - how they investigate, classify, respond to, and manage incidents. The named officers are part of the escalation process description, not about the persons themselves. This is Risk Management Process.

Specificity: Let me check the facts:
- "Chief Executive Officer" - generic C-suite (NOT list)
- "Chief Legal Officer" - generic (NOT list - General Counsel equivalent)

- "Executive Vice President/Operations" - generic
- "Chief Risk Officer" - this is a specific title, but not on the cybersecurity-specific list which includes CISO, CTO, CIO, VP of IT/Security, and similar roles
- "Chief Financial Officer" - generic C-suite (NOT list)
- "cross-functional management teams" - generic
- "incident response plans" - generic program name (NOT list)

The escalation group composition itself—CEO, Chief Legal Officer, Executive Vice President/Operations, Chief Risk Officer, and Chief Financial Officer—describes a standard corporate governance structure for incident management rather than identifying specific individuals or sensitive security roles. The specific enumeration of who sits on this escalation group—CEO, CLO, EVP/Operations, CRO, and CFO—represents a unique organizational composition that not every company would have. While most of these titles are generic C-suite positions, the particular combination and inclusion of roles like CRO and EVP/Operations makes this a firm-specific team structure rather than a standard template.

fact: Escalation group composition: CEO, Chief Legal Officer, Executive Vice President/Operations, Chief Risk Officer, and Chief Financial Officer


reasoning: The paragraph describes the company's internal security awareness training program for personnel and customer education efforts — these are internal cybersecurity processes. No named frameworks, cybersecurity-specific roles, dates, tools, or other specific facts are present; 'security awareness training' and 'annual training' are common practices and generic cadences on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes security awareness training for personnel and customer education about protecting information. This is about internal processes - training programs and customer education.

Category: Risk Management Process - describes internal security awareness training and customer education programs. No board, no management person, no third-party vendor oversight, no incident, no materiality assessment.

Specificity: Let me check for specific facts:
- No named frameworks, standards
- No named roles (cybersecurity-specific)
- No dates, dollar amounts, headcounts
- No named tools or firms
- "mandatory initial and annual training" - generic cadence

- "security awareness" training is standard practice and appears on the exclusion list
- References to "the Bank" are just self-references, also on the exclusion list

No substantive facts from the inclusion list and no named standards, so this reads as generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes: third-party assessments, a 5-year plan, defense mechanisms (training, vulnerability management, MFA, tabletop exercises), and cloud supplier assessments. Third-party specialists serve the company's own program (Rule 3), and cloud supplier assessment is one component of the broader internal process, not the central topic. No named frameworks, cybersecurity-specific roles, named firms, dates, tools, or quantified facts appear — all entities are unnamed ('third party cybersecurity specialists') and practices are common/generic.

thinking:
Let me analyze this paragraph.

Content: Describes engagement with third-party specialists for assessment, a 5-year plan, defense mechanisms (training, vulnerability management, MFA, insurance, tabletop exercises), and assessment of third-party cloud suppliers.

Category: This is primarily about the company's internal cybersecurity processes. Third-party specialists are mentioned but they serve the company (Rule 3). Cloud supplier assessment is mentioned but it's one component of a broader description of internal processes. The dominant topic is Risk Management Process.

Specificity: Let me check for specific facts:
- "third party cybersecurity specialists" - unnamed, NOT list

- "5-year plan" - this is a named internal program? It's somewhat specific but generic enough. Not really a unique identifier.
- "employee training, vulnerability management, multi-factor authentication, cybersecurity insurance and table top exercises" - common practices, NOT list
- "Management" - generic, NOT list
- No named frameworks, no named roles (CISO etc.), no dates, no numbers, no named firms/tools
- "U.S. Steel" is just the company name. No specific facts from the IS list. No named standards.

→ Generic Boilerplate (1)


reasoning: The paragraph describes engaging external experts to evaluate and test the company's own risk management systems (audits, penetration testing, threat assessments). Per Rule 3, external assessors hired to test the company are Risk Management Process, not Third-Party Risk. No named firms, frameworks, dates, or specific facts are present — only generic practices and unnamed 'cybersecurity consultants.'

thinking:
Classify this paragraph.

The paragraph is about engaging third parties for risk management activities - audits, penetration testing, threat assessments. The third parties here serve the company's own security program (external assessors hired to test the company), so per Rule 3, this is Risk Management Process, not Third-Party Risk.

Specificity: No named frameworks, no named firms, no named roles, no specific dates or numbers. "cybersecurity consultants" is unnamed. "regular audits, network penetration testing, threat assessments" are common practices. → Generic Boilerplate.


reasoning: The Board is the grammatical subject ('Our Board considers... has delegated'), making this Board Governance. The delegation is to CEO and CFO, which are generic C-suite titles on the NOT list, and no named frameworks, specific dates, cybersecurity-specific roles, or other firm-specific facts are present — yielding Generic Boilerplate.

thinking:
Classify this paragraph.

The paragraph is about the Board delegating oversight to CEO and CFO. The board is the grammatical subject ("Our Board considers... and has delegated..."). This is Board Governance.

Specificity: CEO and CFO are generic C-suite titles (on the NOT list). "Board" is generic. No named frameworks, no specific dates, no firm-specific facts. This is Generic Boilerplate.


reasoning: The paragraph describes the company's internal incident management and reporting processes, including escalation timelines and disclosure procedures — all process-oriented content. It contains a specific reporting threshold (36 hours) and references the CMT by abbreviation, both firm-specific facts, but only one QV-eligible hard fact (the 36-hour threshold), so it remains Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes incident management through "the Plan," reporting requirements (36 hours), the CMT's role in disclosure determinations, and Form 8-K filing procedures.

Category: This is about the company's internal incident response and reporting processes. It describes how incidents are managed, timelines for reporting, and disclosure procedures. This is Risk Management Process - it's about the company's own internal processes for managing and reporting incidents.

Specificity: Let me check for specific facts:
- "the Plan" - generic program name, not specific
- "36 hours" - this is a specific number/threshold, which is a quantified fact

- "CMT" - this appears to be a named internal team/committee with a unique abbreviation
- "Form 8-K" - filing form type, on the NOT list

So the quantified fact is the 36-hour reporting threshold, while CMT is a named internal team but doesn't count toward QV since committees don't qualify. This makes it Firm-Specific based on the specific number combined with the named team reference.

fact: Material incidents must be reported within 36 hours

fact: CMT (named internal team with unique abbreviation)


reasoning: The paragraph describes the company's internal cybersecurity program — its design philosophy, framework adoption, and processes (training, monitoring, detection, containment, risk assessments). It names the NIST CSF, which triggers Sector-Adapted, but contains no firm-specific facts: the six core functions are part of the NIST standard itself, and the listed practices (training, threat monitoring, risk assessments) are generic and appear on the NOT list.

thinking:
Classify this paragraph.

Content: Describes the company's cybersecurity program, its use of NIST framework, and internal processes. This is about the function/program, not a person. → Risk Management Process.

Specificity: Names NIST Cybersecurity Framework. The six core functions listed are part of NIST, not firm-specific. The rest is generic practices (training, monitoring, detection, containment, risk assessments). No firm-specific facts from the IS list. → Sector-Adapted (2).

fact: NIST Cybersecurity Framework


content_category: Strategy Integration

reasoning: The paragraph is mostly generic regulatory context (banking oversight, SEC 8-K rule description), but concludes with a materiality-adjacent assessment: 'the Bank has not experienced any S1-Critical/Material incidents.' Per Rule 6 and the codebook example ('We have not identified any cybersecurity incidents or threats that have materially affected us' → Strategy Integration), this negative materiality claim about incidents makes Strategy Integration the best fit. The reference to 'S1-Critical/Material' is a firm-specific internal severity classification scheme with a unique identifier, pushing specificity to Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Discusses regulatory compliance (financial privacy laws, banking agency oversight), mentions SEC rules effective December 18, 2023, and states no material incidents.

Category analysis:
- The paragraph mentions regulatory requirements and ends with a materiality-like statement ("has not experienced any S1-Critical/Material incidents")
- The bulk is about regulatory context - what regulations exist
- The last sentence is a materiality/incident assessment
- Per the codebook, generic regulatory compliance language that just acknowledges regulations exist → None/Other

- But that final statement about no material incidents uses firm-specific classification language, which complicates things. The question is whether this counts as assessing whether incidents materially affected the business strategy or financial condition. The codebook's Strategy Integration category requires explicit language about material impact on business strategy, results of operations, or financial condition - and this paragraph just says no incidents occurred, not that they affected anything materially. So it doesn't quite fit that definition.

The bulk of the paragraph is generic regulatory description, which points toward None/Other per the codebook examples. The materiality-adjacent claim at the end is secondary and doesn't use the standard framing for Strategy Integration. I'm leaning toward None/Other because the dominant content is regulatory compliance language, with only a brief incident status statement tacked on. The statement about not experiencing S1-Critical/Material incidents is a negative materiality claim similar to the codebook example, so Strategy Integration fits. The "S1-Critical/Material" label is a firm-specific internal classification scheme, making it Firm-Specific for specificity purposes, though I need to verify whether this classification name itself truly qualifies as a unique identifier or if it's just a generic incident category. The statement is really about not experiencing material incidents rather than regulatory non-compliance affecting the business, but it still maps to Strategy Integration based on the parallel language in the codebook. The "S1-Critical/Material" classification is firm-specific, so my final answer is Strategy Integration with Firm-Specific specificity.

fact: S1-Critical/Material — named internal incident severity classification scheme


reasoning: The paragraph describes the company's use of internal teams and external assessors for penetration tests, security posture assessments, and technology consulting — all internal process validation activities. Third parties are mentioned as a component serving the company's own program (Rule 3: external assessors hired to test the company → RMP). No named frameworks, no named firms, no cybersecurity-specific titles, and no other IS-list facts are present; practices like penetration testing are on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes using internal teams and third-party experts for pen tests, security assessments, and consulting. The focus is on the company's own internal processes - they use third parties as a component of their program validation.

Category: Risk Management Process - the paragraph describes internal processes (pen tests, security assessments, technology consulting) with third parties mentioned as ONE component serving the company's internal program. Per Rule 3, "External assessor hired to test the company → Risk Management Process."

Specificity: Let me check for specific facts.

The language here is all generic - teams that specialize in cybersecurity, unnamed third-party experts, common practices like penetration tests and security assessments, and vague references to independent evaluations. There are no named frameworks, specific roles, or concrete details from the IS list, so this falls into Generic Boilerplate.


reasoning: The paragraph's primary subject is the CTO — describing their experience (25 years), reporting line (to CEO), and role overseeing the cybersecurity program. While it mentions briefing the Board, the CTO remains the grammatical subject throughout, making this about the person rather than the board's oversight. Specificity is Firm-Specific: CTO is a cybersecurity-specific title (one IS-list fact) and '25 years of experience' is one QV-eligible fact, but only one QV-eligible fact means it stays at Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph talks about the CTO - their experience (25 years), what they oversee (cybersecurity program), reporting line (to CEO), and what they do (briefs to Board about various cyber topics).

Person-vs-function test: The paragraph mentions the CTO's experience (25 years) and reporting line (to CEO). But it also describes what they do - oversee the program, provide briefs. Let me apply the test: if I remove "Our CTO, with over 25 years of experience" and the reporting line, what's left? "provides regular briefs to the Board...

about prevention, detection, mitigation, and remediation of cybersecurity incidents, as well as ongoing risks and threats." That's a mix - the briefing activity could be Board Governance or Management Role.

The paragraph's primary subject is the CTO. It describes who they are (experience), who they report to (CEO), and what they do (oversee program, brief the board). The person is the grammatical subject throughout. This is Management Role.

Now I'm checking the specificity: the CTO title is cybersecurity-specific, which qualifies. The 25 years of experience is a concrete number that could be QV-eligible. Reports to CEO is generic C-suite, so that doesn't help. The "regular briefs" language is too generic to add specificity.

Looking at what actually qualifies for QV eligibility - I need specific dates, dollar amounts, headcounts, named third-party firms, products, certifications, or years of experience as a number. The 25 years of experience fits that criteria, but the CTO role itself, while named, isn't QV-eligible. That leaves me with just one QV-eligible fact, which puts this at Firm-Specific level.

fact: Chief Technology Officer (CTO)

fact: over 25 years of experience in information technology


reasoning: The paragraph's communicative purpose is describing how the Board and Audit Committee are informed about cybersecurity risks — the briefing mechanism, topics covered, and information flow to the board. While the CISO and CIO are grammatical subjects, they function as the delivery vehicle for board oversight; the focus is on what the board receives, not on who these individuals are (no credentials, background, or career history). CISO and CIO are cybersecurity-specific titles on the IS list, triggering Firm-Specific, but named roles do not count toward QV.

thinking:
Let me analyze this paragraph.

The paragraph describes the CISO and CIO informing the Board about cybersecurity risks, providing briefings to the Board and Audit Committee. The primary actors are the CISO and CIO (management roles), but the content is about their briefing activities to the board.

Let me apply the decision rules:
- The grammatical subjects are "The CISO and CIO" - management roles
- But the content is about briefing the Board - this is about the reporting relationship
- The paragraph describes what they do (brief the board) rather than who they are (credentials, background)

- Looking at Rule 2 more carefully: when a management role reports to the board on specific topics, that's a Management Role classification, with the CISO and CIO as the primary actors here.

But I need to weigh this against the person-vs-function test. Briefing the board isn't really a cybersecurity process itself—it's about governance structure and oversight. The paragraph's real focus seems to be on how the board gets informed about cybersecurity matters, which points toward Board Governance. Yet the tiebreaker suggests that when management roles are the grammatical subjects and main focus, Management Role wins out. The CISO and CIO are doing the briefing, and that's what the paragraph emphasizes.

I'll go with Management Role since the CISO and CIO are clearly the primary actors performing the reporting action. I'm settling on Board Governance as the category. The paragraph's core purpose is explaining how the board stays informed about cybersecurity—the CISO and CIO are mentioned as the delivery mechanism, but the focus is really on the board's oversight and information flow. Since both CISO and CIO appear on the IS list and the topics covered are generic governance concerns rather than specific cybersecurity processes, this confirms the classification.

fact: Chief Information Security Officer (CISO)

fact: Chief Information Officer (CIO)


reasoning: The paragraph contains an explicit materiality assessment ('no cybersecurity incidents that materially affected or are reasonably likely to materially affect the Company'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference. The date 'December 31, 2023' is a standard fiscal year-end reporting period, not a cybersecurity-specific date, and the cross-reference to a Risk Factors section title is not a firm-specific fact. The materiality language is boilerplate that could appear in any company's filing.

thinking:
Materiality assessment present → Strategy Integration per Rule 6. Cross-reference appended doesn't change it.

Specificity: No named standards, no firm-specific facts from the IS list. "December 31, 2023" is a fiscal year-end date... but it's a standard reporting period date, not a cybersecurity-specific date. Let me check - the codebook says specific dates like "fiscal 2025" count. "Year ended December 31, 2023" is a specific date. That would make it Firm-Specific.

Wait - is "December 31, 2023" really a cybersecurity-specific fact? It's just the reporting period end date that every calendar-year company uses.

The codebook does list specific dates as IS facts, but looking at the calibration example with "The incident is not reasonably likely to materially affect our financial condition" → Generic Boilerplate, this materiality language is similarly standard. The date here is just the fiscal year end, a standard filing convention rather than anything tied to a cybersecurity event, so I'm classifying this as Generic Boilerplate.


content_category: Incident Disclosure

reasoning: The paragraph primarily describes an actual cybersecurity incident: what happened (data extraction including employee personal data), when (December 2022), and response actions (containment, investigation, third-party engagement). The closing materiality sentence is subordinate to the incident narrative. Only one hard verifiable fact (specific month/year) is present — third-party experts and legal counsel are unnamed — so this reaches Firm-Specific but not Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes a cybersecurity incident from December 2022 - unauthorized access, data extraction, response actions, and materiality assessment.

Category: This is primarily an Incident Disclosure - it describes what happened (cybersecurity threat, data extraction), when (December 2022), scope (personal data of employees), and response actions (containment, investigation, third-party experts). The last sentence is a materiality statement, but the dominant content is the incident narrative.

Specificity:
- "December 2022" = specific date (one hard fact)

- The third-party experts and legal counsel mentioned are unnamed, and there are no specific firm names, tools, dollar amounts, or headcounts provided. Looking at the Firm-Specific criteria, I only have one verifiable fact here - the date - which qualifies this as Firm-Specific (3).

fact: December 2022


reasoning: The paragraph's primary content is about the persons filling cybersecurity-relevant leadership roles — their committee memberships and professional experience/qualifications. While the first sentence mentions reporting cadence, the bulk of the paragraph describes who the CRO and interim CIO are and what makes them qualified, satisfying the person-vs-function test for Management Role. Two QV-eligible hard facts (15 years of experience, 30 years of experience) push specificity to Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph discusses:
1. Reporting cadence to committees (IT Steering Committee, ERM Committee)
2. Who is part of those committees (CRO, interim CIO)
3. CRO's experience (15 years managing IS risks)
4. Interim CIO's experience (30 years managing technology)

This is primarily about the people - their roles, committee memberships, and experience/qualifications. The person-vs-function test: if I remove the people's titles and qualifications, what's left? Just "Cybersecurity risks and activities are reported quarterly to committees." The bulk of the content is about who these people are and their qualifications.

Now I'm categorizing this as a management role discussion since it centers on the CRO and interim CIO themselves rather than their functions. The named committees—Information Technology Steering Committee and Enterprise Risk Management Committee—are specific to this organization, and the interim CIO title qualifies as cybersecurity-relevant. Both the 15 and 30 years of experience figures are concrete numbers that make this content eligible for qualification verification.

fact: Enterprise Risk Management Committee

fact: interim chief information officer

fact: over 15 years of experience managing Information Security risks

fact: over 30 years of experience managing technology


content_category: Third-Party Risk

reasoning: The paragraph's central topic is cybersecurity risks from third-party vendors and service providers, making Third-Party Risk the dominant category. However, the disclosure is entirely generic — no named vendors, no specific oversight processes, no standards, and no firm-specific facts — yielding Generic Boilerplate specificity.

thinking:
Classify this paragraph.

Content: Generic statement about considering third-party vendor cybersecurity risks. No specific processes, no named vendors, no standards.

Category: Third-Party Risk - the central topic is third-party vendor/service provider cybersecurity risks.

Wait - let me check Rule 3. "Third parties mentioned as ONE component of internal program → Risk Management Process" vs "Vendor oversight is the CENTRAL topic → Third-Party Risk."

This paragraph is specifically about third-party vendors and service providers. The central topic is third-party risk. → Third-Party Risk.

Specificity: No named standards, no specific facts. "online sales platforms" is generic.

So this lands in Generic Boilerplate.


reasoning: The paragraph contains an explicit materiality assessment ('we have not experienced a cybersecurity incident that we deemed to be material') plus a cross-reference to Risk Factors for further discussion of how cyber risks could 'materially and adversely affect' the company. Per Rule 6, materiality disclaimers are Strategy Integration even when boilerplate, and the appended cross-reference does not change the classification. No specific facts from the IS list are present—IT reliance, generic materiality language, and cross-references are all on the NOT list.

thinking:
Let me analyze this paragraph.

Content: The paragraph discusses reliance on IT systems, states no material cybersecurity incident has occurred, and cross-references Risk Factors.

Category analysis:
- "To date, we have not experienced a cybersecurity incident that we deemed to be material" — this is a materiality assessment → Strategy Integration per Rule 6
- The cross-reference to Risk Factors is appended to the materiality assessment, which per the codebook does NOT change classification
- The opening sentence about IT systems is general business context

This is Strategy Integration - contains an explicit materiality assessment.

The language here is boilerplate without specific frameworks or facts from the IS list, just generic materiality language paired with a cross-reference to Risk Factors.


reasoning: The paragraph blends Management Role content (Information Security Manager, CIO, 50 years of experience, reporting line) with Risk Management Process content (IR team composition, risk reduction activities, GRC platform, third-party assessors, 24/7 managed detection). Applying the person-vs-function test: four of six sentences describe what the program does (team operations, risk management activities, GRC platform, third-party engagement), while two sentences describe the persons' reporting line and experience. The dominant communicative purpose is describing the company's cybersecurity program operations. Specificity is Firm-Specific: multiple IS-list facts (specific team composition, cybersecurity-specific roles, 50 years of experience) but only one QV-eligible hard fact (the 50-year figure), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Cybersecurity incident response team composition (IT, Finance, Legal, HR)
2. Information Security Manager and CIO roles and experience
3. What they do (manage risks, respond to incidents, harden attack surface)
4. GRC platform
5. Third-party assessors and managed detection

Let me apply the person-vs-function test. The paragraph mentions the Information Security Manager and CIO, describes their combined experience (50 years), and then describes what they do. There's a mix of person (credentials/experience) and function (what the program does).

Looking at the structure more carefully, the paragraph opens with team composition, then layers in role details and credentials before describing the actual processes and operations. While the experience credentials are mentioned, the bulk of the content focuses on what the program accomplishes—the incident response processes, risk reduction, and security hardening activities. Looking at the specificity of the remaining details, "GRC platform" and "24/7 managed detection and response" are too generic to count as list items, and the third-party assessors aren't named. For quantifiable facts, only the "over 50 years of experience" qualifies—the named roles don't meet the QV criteria. That gives me just one QV-eligible fact, which puts this in the Firm-Specific category.

fact: Incident response team comprised of IT, Finance, Legal, and Human Resources

fact: Information Security Manager

fact: Over 50 years of combined IT experience


reasoning: The paragraph describes a specific, actual cybersecurity incident: the Fortra/GoAnywhere zero-day exploit, its scope (affected customer PHI/PII data but not the company's own systems), and response actions (engaged outside experts, provided notifications to data owners, individuals, and State Attorneys General). This is a detailed incident narrative. Specificity is Quantified-Verifiable with three or more hard verifiable facts: fiscal 2023 (date), Fortra, LLC (named firm), and GoAnywhere MFTaaS (named product/system).

thinking:
Let me analyze this paragraph.

Content: Describes a specific cybersecurity incident involving Fortra/GoAnywhere, a third-party vendor. Details what happened, the vulnerability, scope, affected data, and response actions.

Category: This is clearly Incident Disclosure - it describes what happened in an actual cybersecurity incident with timeline, scope, attack vector, and response actions.

Specificity: Let me count hard verifiable facts:
- "fiscal 2023" - specific date
- "Fortra, LLC" - named third-party firm
- "GoAnywhere" - named product/system

- "zero-day vulnerability" - standard incident language
- "HIPAA" - named regulation

QV-eligible: fiscal 2023 (date), Fortra LLC (named firm), GoAnywhere (named product) = 3+ hard verifiable facts → Quantified-Verifiable

fact: fiscal 2023

fact: Fortra, LLC

fact: GoAnywhere managed file transfer as a service system (MFTaaS)

fact: HIPAA (Health Insurance Portability and Accountability Act)

fact: zero-day vulnerability exploit


reasoning: The paragraph's dominant content is a detailed incident narrative describing the MOVEit/PBI cybersecurity event — including timeline, attack vector, scope of data exposure, and response actions. While it closes with a materiality assessment and cross-reference, the incident description occupies the majority of the text. Multiple QV-eligible hard facts: specific date (June 22, 2023), named vendor (PBI), named system (MOVEit), and quantified impact (2.5–2.7 million policyholders).

thinking:
Let me analyze this paragraph carefully.

This is a complex paragraph that covers multiple topics. Let me break it down:

1. Opens with mention of DSCP procedures for incident reporting
2. Describes the MOVEit/PBI incident in detail - dates, vendor name, what happened, scope
3. Provides impact numbers (2.5-2.7 million policyholders)
4. Ends with materiality assessment and cross-reference

The dominant content is clearly the incident description - the MOVEit cybersecurity incident via PBI. The paragraph describes what happened, when, the scope, and response actions.

Now I'm looking at the specific facts that make this disclosure material: the June 22, 2023 filing date, the PBI vendor involvement, the MOVEit system vulnerability, and the quantified impact of 2.5 to 2.7 million affected policyholders with specific data types exposed. These hard facts anchor the incident narrative and establish why this disclosure matters.

fact: Form 8-K filed on June 22, 2023

fact: PBI (named third-party vendor)

fact: MOVEit file transfer system

fact: Approximately 2.5 to 2.7 million policyholders affected


reasoning: The paragraph is primarily about the CIO as a person — their reporting line to the CEO, their team structure, and especially their qualifications and career background (two decades of experience across multiple cybersecurity domains). The person-vs-function test confirms: the extensive credential/experience description is the primary content. CIO is a cybersecurity-specific role (IS list), and 'over two decades' is a specific duration, but only one QV-eligible hard fact (years of experience), so Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the CIO's role, reporting line, team support, and extensive background/experience. The paragraph is primarily about the person - their reporting line, what their team does, and their qualifications/experience.

Person-vs-function test: The paragraph names the CIO role, describes reporting to CEO, mentions the IT team's support, and then spends significant text on the CIO's experience and background. The last sentence is clearly about the person's qualifications. The middle sentence describes what the team does - but it's framed as supporting the CIO. Overall, this is primarily about the person (Management Role).

Now I'm checking which facts qualify as specific and verifiable. The CIO title and over two decades of experience are concrete details, but the reporting structure to the CEO is too generic, and the IT team, incident response plan, and ERP systems are all standard terminology without specific names. That leaves just one qualifying fact - the experience metric.

fact: Chief Information Officer (CIO)

fact: over two decades of experience


reasoning: The paragraph describes an actual cybersecurity incident — a phishing attack — including its discovery, investigation, recovery of funds, and remediation steps taken afterward. Three hard verifiable facts (two specific dates and a dollar amount) exceed the two-fact QV threshold.

thinking:
Let me analyze this paragraph from Four Leaf Acquisition Corp (FORL), a 10-K filing.

This describes an actual cybersecurity incident - a phishing attack with specific details about what happened, when, the amount, and remediation.

Content category: Incident Disclosure - describes what happened (phishing attack), when (April 28, 2023), scope ($54,300 payment), response (investigation, fund recovery), and remediation (additional controls).

Specificity: Let me count hard verifiable facts:
- April 28, 2023 (specific date)

- $54,300 (dollar amount)
- June 29, 2023 (specific date)

That's three QV-eligible facts → Quantified-Verifiable (4)

fact: April 28, 2023 — date incident identified

fact: $54,300 — amount of incorrect payment

fact: June 29, 2023 — date funds recovered


reasoning: The paragraph spans Board Governance (Audit Committee oversight, board training, reporting cadence) and Management Role (CIO/CISO credentials, degrees, certifications, memberships). While the first half frames board oversight, the second half—which is the most detailed and specific portion—is devoted to the persons' qualifications: named universities (Purdue, Wayne State, Carnegie Mellon), CISSP certification, doctoral degree, professional group memberships, and editorial board service. The person-specific content dominates the substantive detail, making Management Role the primary communicative purpose. Multiple QV-eligible hard facts (named universities in credential context, CISSP certification) easily exceed the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

This is a long paragraph that covers multiple topics. Let me break it down:

1. Board oversight - first few sentences about Board/Audit Committee oversight
2. Management reporting to Board - CIO and CISO report to Board
3. CIO qualifications - degrees from Purdue and Wayne State
4. CISO qualifications - degrees, Carnegie Mellon CISO Certificate, CISSP, professional memberships

The dominant content: This paragraph starts with board governance but transitions heavily into management credentials. Let me assess which is dominant by text volume.

Board governance portion: ~4 sentences about Board/Audit Committee oversight, management reporting to board, cybersecurity training for board.

Management credentials section is substantial and detailed, taking up roughly half or more of the paragraph with CIO and CISO backgrounds, education, and certifications. The paragraph opens with board governance framing but clearly pivots toward detailing the qualifications and professional credentials of these key leadership roles. I'm weighing whether the board governance framing or the management credentials are the dominant focus here. The paragraph opens with board oversight but then pivots heavily into specific details about the CIO and CISO's educational background, certifications, and professional affiliations. Even though board governance takes up the first half, the substantive content—the degrees, universities, and credentials—is what really anchors the second half and seems to be the point being made.

So Management Role is the better category. For the QV count, I'm identifying the specific, verifiable facts: the three universities mentioned (Purdue, Wayne State, Carnegie Mellon) and the CISSP certification. That gives me four QV-eligible facts, which puts this in the Quantified-Verifiable bucket.

Looking at the additional details—the five-year cybersecurity threat assessment duration and the named organizations like the Greater Pittsburgh CISO Group and Steel City OTSEC Information Sharing Group—these further reinforce that this is definitely Quantified-Verifiable.

fact: CIO role

fact: CISO role

fact: Bachelor of Science in electrical engineering technology from Purdue University

fact: Master of Business Administration from Wayne State University

fact: Doctorate in Instructional Management and Leadership

fact: Chief Information Security Officer Certificate program at Carnegie Mellon University

fact: CISSP certification

fact: Greater Pittsburgh CISO Group membership

fact: Steel City OTSEC Information Sharing Group membership

fact: Editorial Review Board for International Journal of Cyber Research and International Journal of Information and Communication Technology Education

fact: 5-year cybersecurity threat assessment


reasoning: The paragraph's primary content is about who implements the cybersecurity program — the IT Lead's years of experience and the external agency's expertise — making it about the person/team rather than the processes themselves. Two quantified facts (11 years of experience, ~8 years of agency expertise) meet the QV threshold, though 'about 8 years' is approximate and 'IT Lead' is a borderline generic IT title (not on the cybersecurity-specific IS list), which slightly lowers confidence.

thinking:
Let me analyze this paragraph.

The paragraph discusses the IT Lead's experience (11 years), their role in cybersecurity risk management, and an external agency with 8 years of expertise.

Person-vs-function test: The paragraph starts with processes but quickly shifts to WHO implements them - the IT Lead's experience and qualifications. The primary content is about the person (11 years experience) and their support (external agency with 8 years expertise).

But wait - "IT Lead" - is this a cybersecurity-specific title? Looking at the IS list: "CISO, CTO, CIO, VP of IT/Security, Information Security Officer, Director of IT Security..." - "IT Lead" is not explicitly listed.

It's a generic IT title that falls into the NOT category alongside "Head of IT" and "Director of IT". Even though the paragraph frames this person's cybersecurity oversight responsibilities, the title itself isn't specialized enough. The content focuses on the person and their background rather than specific functions, which points to Management Role. The specificity breaks down too - "IT Lead" is generic, the 11 years is concrete and QV-eligible, but the external agency's "about 8 years" is approximate and vague. "IT Lead" is a generic title like the others on the NOT list, so that doesn't count. With "11 years" as a clear quantified fact and "about 8 years" as an approximate but still specific number—similar to how "over 20 years" counts in the codebook—I have two QV-eligible facts, making this Quantified-Verifiable.

fact: IT Lead has 11 years of experience in cybersecurity risk management oversight

fact: External agency with about 8 years of expertise in cybersecurity


reasoning: The paragraph is framed as an overview of the company's cybersecurity program and its key areas (Governance, Collaborative Approach), making it a programmatic description rather than a board governance or management role paragraph. The Governance bullet describes Audit and Compliance Committee oversight and CIO reporting as one component of the overall program, and the Collaborative Approach bullet describes cross-functional internal processes. The CIO title (a cybersecurity-specific role on the IS list) makes it Firm-Specific, but there are no two hard verifiable facts (no dates, dollar amounts, named firms, or named tools) to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the company's cybersecurity program with two bullet points: Governance and Collaborative Approach.

Content Category: This spans multiple categories. The Governance bullet discusses Board/Audit Committee oversight (Board Governance) and mentions CIO reporting (Management Role). The Collaborative Approach bullet describes internal processes (Risk Management Process). The framing is about the company's cybersecurity program as part of ERM.

The dominant content: The paragraph opens by framing this as part of ERM, then has two sub-sections. The Governance bullet is about board oversight (Audit and Compliance Committee delegation, reporting). The Collaborative Approach is about internal processes.

The Governance section covers board delegation to the Audit and Compliance Committee, with the CIO and CCO reporting directly to them and cybersecurity as a standing agenda item, while the Collaborative Approach outlines cross-functional threat identification and mitigation processes with escalation procedures. Both sections carry roughly equal weight, but the opening framing emphasizes the company's cybersecurity program and key areas, which leans toward Risk Management Process as the primary category.

For specificity, the CIO title is on the IS list as cybersecurity-specific, while "Audit and Compliance Committee" is essentially a variant of the generic "Audit Committee" on the NOT list, and "Chief Compliance Officer" isn't a cybersecurity-specific title either.

Since CIO appears, this qualifies as Firm-Specific at level 3. For the QV check, I don't have two hard verifiable facts—CIO is just a named role without dates, dollar amounts, named firms, or tools—so it doesn't meet the QV threshold.

fact: Chief Information Officer (CIO)


reasoning: The paragraph describes the company's internal cybersecurity policy framework, business-unit-level program design, risk assessment responsibilities, and reporting procedures. Third-party vendor oversight is mentioned but only as one component. No named frameworks, cybersecurity-specific titles, tools, dates, or other IS-list facts are present — 'senior management' and 'individuals with appropriate qualifications' are generic.

thinking:
Let me analyze this paragraph.

Content: Describes companywide cybersecurity policy, business unit structure, reporting lines to senior management, program design, policies for third-party vendor oversight.

Category: This is about the company's internal cybersecurity processes - policy framework, risk assessment, program design, incident response procedures. Management is mentioned generically ("senior management"), not specific persons. Third-party vendors are mentioned but as one component. This is Risk Management Process.

Specificity: Let me check for specific facts:
- No named frameworks (NIST, ISO, etc.)

- No cybersecurity-specific titles (just "senior management", "individuals with appropriate qualifications")
- No named committees, tools, dates, firms
- "Each business unit" - generic organizational structure
- Third-party vendors mentioned generically

Everything here is generic. No IS-list items. No named standards. → Generic Boilerplate (1).


reasoning: The paragraph makes an explicit materiality assessment — past threats 'haven't significantly impacted us' and future ones 'could potentially have a material adverse effect on our business strategy, results of operations, and financial condition.' Per Rule 6, any paragraph assessing whether cybersecurity risks have materially affected the company is Strategy Integration. No named frameworks, roles, dates, or other specific facts are present.

thinking:
Let me analyze this paragraph.

Content: Acknowledges past cybersecurity threats, states they haven't significantly impacted the company, and notes future threats could have material adverse effect. This is a materiality assessment - "haven't significantly impacted us thus far" + "could potentially have a material adverse effect on our business strategy, results of operations, and financial condition."

Category: Strategy Integration - per Rule 6, materiality disclaimers are Strategy Integration.

Specificity: No named frameworks, no specific facts from the IS list. Generic boilerplate language throughout. → Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity training program and policy communication—core risk management activities. The 'information technology partner' is mentioned as a delivery mechanism for the company's own program, not as the central topic of vendor oversight, so this is Risk Management Process rather than Third-Party Risk. No named frameworks, tools, firms, roles, dates, or other specific facts from the IS list are present; 'regular, mandatory training' and 'information security policies, standards, processes' are generic practices applicable to any company.

thinking:
Classify this paragraph.

Content: Describes training for personnel regarding cybersecurity threats, communicating security policies/standards/processes/practices, done through an IT partner.

Category: This is about the company's internal cybersecurity processes - specifically training and policy communication. The "information technology partner" is mentioned as a component of how they deliver training, not as the central topic of vendor oversight. → Risk Management Process

Specificity: No named frameworks, no named roles, no specific dates, no named firms ("information technology partner" is unnamed), no specific facts from the IS list. Generic practices (training, policies).

This reads as generic boilerplate language without concrete details or specificity.


reasoning: The paragraph primarily describes an actual cybersecurity incident — the MOVEit breach — including the investigation with PBI, the scope of affected individuals (2.5-2.7M), and the type of data exposed (SSNs). While it concludes with a materiality assessment, the incident narrative is the dominant content, not a brief mention. Multiple QV-eligible hard facts are present: specific date (February 29, 2024), named firm (PBI), named product (MOVEit), and specific headcount (2.5-2.7M affected), well exceeding the two-fact threshold.

thinking:
Let me analyze this paragraph carefully.

Content: Describes the MOVEit incident - investigation, scope (2.5-2.7M policyholders affected), data types exposed (SSNs), and concludes with a materiality assessment.

Category: This is a mixed paragraph. It describes an actual incident (MOVEit), including scope and response, but also concludes with a materiality assessment. The dominant content is the incident narrative - what happened, the investigation, the scope of data exposed. The materiality conclusion is at the end. By the dominant category rule, the incident description takes up most of the paragraph. → Incident Disclosure

Looking at the tiebreakers more carefully - the paragraph provides substantial detail about what happened with MOVEit (the investigation with PBI, the 2.5-2.7M affected policyholders, SSNs exposed), not just a brief mention. The materiality assessment is secondary to the incident narrative itself. This confirms Incident Disclosure as the category.

Now checking for QV-eligible facts - I see the Form 8-K filing date of February 29, 2024 as a specific, verifiable detail.  PBI is named as the third-party investigator. The affected population is quantified precisely at 2.5 to 2.7 million policyholders. MOVEit is the named product involved. The DSCP program is mentioned but that's firm-specific rather than QV-eligible. So I'm counting four QV-eligible facts: the specific date, the named firm, the specific numbers, and the named product - which meets the threshold for Quantified-Verifiable classification.

fact: DSCP (Disclosure Sub-Committee Protocol) — named internal program

fact: Form 8-K filed on February 29, 2024

fact: MOVEit Cybersecurity Incident — named system/product

fact: PBI — named third-party firm

fact: Approximately 2.5 million to 2.7 million policyholders affected

fact: Social security numbers exposed


reasoning: The paragraph describes internal auditing of the company's own Information Security program to ensure regulatory alignment — an internal process activity. No named frameworks, no named audit firms, no specific dates or cybersecurity-specific roles are mentioned, keeping this at Generic Boilerplate.

thinking:
Classify this paragraph.

Content: Internal audit of the information security program for regulatory alignment. This is about the company's own internal processes - specifically auditing their security program. The "Internal Audit provider(s)" are serving the company, so this is Risk Management Process per Rule 3.

Specificity: No named frameworks, no named firms, no specific dates, no cybersecurity-specific titles, no named tools. "Internal Audit provider(s)" is unnamed. "Information Security program" is generic. "Regulatory expectations" is vague.

→ Generic Boilerplate


reasoning: The paragraph mentions the Director of Information Technology and their experience, but the bulk of the content describes what the technology team does — defining work plans, setting improvement objectives, incorporating third-party assessment feedback, and investing in system upgrades. Applying the person-vs-function test, removing the title and experience still leaves a coherent process description, so the paragraph is about the function. 'Director of Information Technology' is generic IT leadership (NOT list), not a cybersecurity-specific title, so it does not count as a specific fact. The '20 years of experience' is one quantified fact, yielding Firm-Specific but not Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes a technology team under a Director of IT, their experience, and what the team does (work plan, improvement objectives, third-party assessments, investments in systems).

Category: This is about both a person (Director of IT) and what the program does. Let me apply the person-vs-function test. The paragraph mentions the Director of IT title and "over 20 years of technology management experience" - that's about the person. But then it goes on to describe what the team does: defines work plans, sets improvement objectives, identifies investments.

If I remove the person's title and experience, the paragraph still describes what the technology team does.

The bulk of this is really about the function, though there's definitely some personal background mixed in. Now I'm checking whether "Director of Information Technology" is cybersecurity-specific—it's not, it's generic IT leadership, so that title wouldn't count toward specificity. The "over 20 years" is quantified and specific, but that's where the specificity ends. "Director of Information Technology" matches the NOT list as generic IT leadership, so that's not a qualifying fact. The only quantified fact here is "over 20 years of technology management experience" — that's one firm-specific fact. The paragraph's main focus is on what the team does and their processes rather than the person's role, so this falls under Risk Management Process as the dominant category.


reasoning: The Board and Audit Committee are the grammatical subjects throughout, describing delegation of cybersecurity oversight, briefing cadence, and committee expertise — all hallmarks of Board Governance. The CIO is a cybersecurity-specific title on the IS list, providing one firm-specific fact, but no second QV-eligible hard fact exists (quarterly cadence and Audit Committee are on the NOT list).

thinking:
Let me analyze this paragraph.

Content: Board/Audit Committee oversight of cybersecurity, delegation, briefing cadence, committee expertise. The grammatical subject is the Board/Audit Committee throughout.

Category: Board Governance - clear. The Board and Audit Committee are the primary actors throughout.

Specificity: Let me check facts:
- CIO is mentioned - that's a cybersecurity-specific title on the IS list? Let me check... CIO is listed as a cybersecurity-specific title: "CISO, CTO, CIO, VP of IT/Security..."
- "Audit Committee" - NOT list (generic governance)

- "quarterly" - NOT list (generic cadence)
- "reporting thresholds" - generic
- Committee member expertise - generic description

So CIO = one firm-specific fact. That's one IS-list fact → Firm-Specific.

No QV facts (no dates, dollar amounts, headcounts, named third-party firms, named tools, named certifications, specific numbers).

Specificity: Firm-Specific (3)


content_category: None/Other

reasoning: This paragraph is a general business description of the company's stage and therapeutic focus. It contains no cybersecurity disclosure content whatsoever — no mention of cyber risk, governance, processes, or incidents.

thinking:
Classify this paragraph.

This is a general business description of Virpax Pharmaceuticals - a pre-clinical stage biopharma company. No cybersecurity content whatsoever.


reasoning: The paragraph describes the audit committee receiving periodic cybersecurity briefings and relaying updates to the full Board — classic board/committee oversight content. No firm-specific facts are present: CFO is a generic C-suite title (NOT list), 'IT consultant' is an unnamed generic entity, 'audit committee' is standard governance, and 'periodic' is a vague cadence.

thinking:
Classify this paragraph.

The paragraph describes briefings to the audit committee from CFO and IT consultant, and the audit committee updating the board. The primary actors are the audit committee and board receiving briefings - this is about board/committee oversight.

Content category: Board Governance - the audit committee is receiving briefings and providing updates to the board. The grammatical subjects are "CFO and IT consultant" (providing briefings) and "audit committee" (providing updates to board). The dominant theme is the oversight flow: information goes to audit committee → board.

Specificity: Let me check the facts.

All the key entities here are generic - the CFO is a standard C-suite role that's explicitly excluded, the IT consultant is unnamed and not cybersecurity-specific, and the audit committee and board are standard governance bodies. There are no named standards or specific facts from the inclusion list, and no mention of specialized roles like CISO or CTO. This falls into Generic Boilerplate.


reasoning: The paragraph describes the structure, composition, and testing of the company's Incident Response Team — all process/function content. The CISO is mentioned as attribution ('leads'), but the substantive content is about what the IRT does and who is on it; removing the CISO reference leaves a coherent process description → Risk Management Process. Specificity is Firm-Specific: the IRT has a unique abbreviation, and the departmental composition (notably the company-specific 'ECDP' department) is firm-identifying. However, no QV-eligible hard facts (dates, dollar amounts, headcounts, named third-party firms, named tools) reach the two-fact threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes an Incident Response Team (IRT) and its composition, testing cadence, etc. Let me apply the person-vs-function test.

The CISO is mentioned as leading the IRT, but the paragraph is about the IRT structure and processes - what the team does, who's on it, how they test. Remove "The CISO also leads" and replace with "The Company maintains" - it still makes sense as a process description. This is Risk Management Process.

Specific facts:
- CISO (cybersecurity-specific title) → named_role ✓ IS

- "Incident Response Team ("IRT")" with its unique abbreviation is a named internal program → other_specific ✓ IS
- The team pulls from specific departments: Information Technology and Security, Legal, ECDP, Finance, and Public Relations → named_team ✓ IS
- "IRP" (Incident Response Plan) is their named framework
- "ECDP department" is a company-specific department name → named_team ✓ IS
- "annually" and "tabletop exercise" are generic practices, not firm-specific

This has multiple company-specific identifiers and department names that make it clearly firm-specific information.

Now I'm checking for quantifiable values—specific dates, dollar amounts, headcounts, percentages, named third parties, products, certifications, or years of experience. None of those are present here, so this doesn't reach the threshold for a higher classification level. This is Firm-Specific (level 3).

fact: CISO leads the Incident Response Team

fact: Incident Response Team ("IRT") — named internal program with unique abbreviation

fact: Team composition: Information Technology and Security, Legal, ECDP, Finance, Public Relations

fact: ECDP department — company-specific department name


reasoning: The Audit Committee is the grammatical subject of the first sentence and the recipient of briefings in the second, framing the paragraph as board-level oversight of cybersecurity. The CIO/CISO are mentioned as information providers to the board, not as the primary actors. Two cybersecurity-specific roles (CIO, CISO) place this at Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named firms, tools, or certifications) are present.

thinking:
Classify this paragraph.

The paragraph has two sentences:
1. Audit Committee oversight of cybersecurity - Board Governance
2. CIO and/or CISO provide updates to Audit Committee - This could be Board Governance (board receiving briefings) or Management Role

The primary actor in sentence 1 is the Audit Committee. In sentence 2, the CIO/CISO provide updates TO the Audit Committee - this is about the board's oversight mechanism (receiving briefings). The frame is board oversight. → Board Governance

Specificity:
- "Audit Committee" - NOT list (generic)

- "Chief Information Officer" / "CISO" - These are named cybersecurity roles, making this Firm-Specific rather than QV-eligible
- "regular updates" - generic cadence, not a specific list
- The topics covered (cybersecurity events, vulnerability management, ransomware readiness, global trends) are standard practices, not firm-specific facts

No quantifiable facts like dates, dollar amounts, headcounts, or named tools appear here, so this remains Firm-Specific based solely on the named roles.

fact: CISO


reasoning: The paragraph describes a management-level committee (Engineering Risk Steering Group), its mandate, its chair (CISO), and its reporting line to another named committee (Firmwide Technology Risk Committee). Per the codebook, management committees responsible for cybersecurity and their reporting structures fall under Management Role. The activities mentioned (oversees risk decisions, monitors controls, reviews compliance) describe the committee's charter at a high level rather than detailed processes. Three firm-specific facts (two named non-generic committees, one cybersecurity-specific role) place this at Firm-Specific; however, named roles and committees are not QV-eligible, so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: The Engineering Risk Steering Group oversees engineering risk decisions, monitors control performance, reviews compliance approaches. Chaired by the CISO, who serves on the Firmwide Technology Risk Committee, and reports to that committee.

Category: This is about a specific committee (Engineering Risk Steering Group) and its oversight role. The grammatical subject is the committee, not the board. It's describing organizational structure - a management-level committee. The CISO chairs it. It describes reporting lines and committee structure.

This is Management Role - it's about management committee structure, reporting lines, who chairs what.

The paragraph actually covers both what the committee does and how it's structured, so I need to think about whether this is primarily about the committee's functions or its organizational position. The functions listed—overseeing risk decisions, monitoring controls, reviewing compliance—are what the committee does, but the structure and reporting lines are equally important to the description. This feels like it's fundamentally about the committee's role within the management hierarchy rather than a specific process or board-level governance.

Looking at the specificity test, I've got named committees and a cybersecurity-specific title, which are firm-specific facts but don't qualify for QV since they're organizational roles and named entities. This lands in Firm-Specific territory.

fact: Engineering Risk Steering Group

fact: CISO (chairs the committee)

fact: Firmwide Technology Risk Committee


reasoning: The entire paragraph is about oversight of third-party service providers — risk-based vendor screening, vendor code of conduct, questionnaires, due diligence, collecting audit reports, and contractual security terms. This makes Third-Party Risk the clear dominant category. No named frameworks, tools, firms, dates, or other IS-list facts appear; 'vendor code of conduct,' 'vendor questionnaires,' and 'cybersecurity audit reports' are generic program elements, yielding Generic Boilerplate.

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

Content: Describes vendor oversight processes - risk-based approach, vendor code of conduct, questionnaires, due diligence, audit reports, contract terms. Central topic is oversight of external parties.

Category: Third-Party Risk - vendor oversight is the central topic.

Specificity: No named frameworks, no named tools, no specific dates, no dollar amounts, no cybersecurity-specific titles. "Vendor code of conduct" and "vendor questionnaires" are generic program names. All practices described are common. No IS-list items.

This falls into generic boilerplate territory.


reasoning: The paragraph's primary communicative purpose is explaining how cybersecurity risk management is organizationally structured — operations managed by the General Partner, delegated to the Investment Manager, with ultimate reliance on parent company Blackstone for assessing and managing cyber risks. While it mentions the Board briefly ('oversight rights'), the board is not the grammatical subject performing the primary action. Named entities (Blackstone, General Partner, Investment Manager) are all company/parent self-references, not cybersecurity-specific facts per the IS list, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: This describes the organizational structure - General Partner, Investment Manager, Sponsor relationship - and states reliance on Blackstone for cybersecurity. It's setting up context for Blackstone's cybersecurity program description.

Category: This is about organizational structure and delegation of cybersecurity management. The paragraph describes who manages operations, delegation chains, and reliance on Blackstone. It's not really about board governance (board is mentioned briefly with "oversight rights"), not about a specific person's qualifications, not about processes/frameworks. It's more of an introductory/structural paragraph explaining the relationship. The primary content is organizational structure and the fact that they rely on Blackstone.

The key distinction here is that this is about organizational entities and management roles rather than individual people - the General Partner and Investment Manager are both Blackstone subsidiaries, so the cybersecurity responsibility ultimately flows through Blackstone's organizational structure.

Looking at the next section, it's framed as a preamble introducing Blackstone's cybersecurity program details, but the substantive content is really about how the company manages cybersecurity risk through delegation to its parent company. I'm settling on Risk Management Process as the classification since it explains the organizational approach to managing cybersecurity risk, even though there are no specific named frameworks mentioned.

The entities referenced—Blackstone Infrastructure Strategies Associates, Blackstone Infrastructure Advisors, and Blackstone itself—are all self-references or parent company references, so they don't count as third-party firms per the guidelines. There are no cybersecurity-specific roles, dates, or numbers here either, which points to Generic Boilerplate.


reasoning: The paragraph's primary content is about the people managing cybersecurity: the CTO's qualifications (30 years IT, 20 years cybersecurity), the specific team composition (CTO, Compliance Manager, ISM/ISO, Enterprise Risk Manager), and their roles. While process elements and third-party engagement are mentioned, the dominant communicative purpose is identifying who manages cybersecurity and their credentials. Two QV-eligible quantified facts (30 years and 20 years of experience) meet the threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Cybersecurity risk management process integrated into overall risk management
2. CTO's experience (30 years IT, 20 years cybersecurity)
3. Team composition (CTO, Compliance Manager, Information Security Manager/ISO, Enterprise Risk Manager)
4. Third-party engagement for security products/services
5. Management of third parties by Information Security Manager/Officer

Person-vs-function test: The paragraph starts with process description, then describes the CTO's qualifications, then describes the team composition working together, then describes third-party engagement.

The CTO's credentials stand out as significant, but the real substance here is the management structure—who's responsible for what. The team roles are clearly defined, and the CTO's extensive background in both IT and cybersecurity establishes credibility for leading this effort. The paragraph also touches on how third-party services fit into this structure, with the Information Security Manager overseeing those relationships. I'm checking whether these are truly separate quantified facts—30 years and 20 years of experience for the same person. They both meet the QV criteria as specific numbers, so that's two quantified facts pointing toward Quantified-Verifiable status.

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

fact: over 30 years of experience in information technology

fact: over 20 years of experience in cybersecurity

fact: Information Security Manager/Information Security Officer

fact: Team composition: CTO, Compliance Manager, Information Security Manager/ISO, Enterprise Risk Manager


reasoning: The paragraph's primary communicative purpose is how the board's risk committee exercises cybersecurity oversight — receiving reports and escalation notifications from management. While CISO and CRO are grammatical subjects in two sentences, they are described in terms of supporting the board's oversight responsibilities, and the risk committee is the subject receiving reports in the central sentence. The Risk Committee (a non-generic named committee on the IS list) and CISO (cybersecurity-specific title) are firm-specific facts, but no QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph.

Content: CISO and CRO support board/risk committee oversight, risk committee receives periodic reports, escalation process exists.

Category: The risk committee (a board committee) is receiving reports and being notified. But the grammatical subjects are "CISO and CRO" in the first and third sentences, and "risk committee" in the second. The paragraph describes how management (CISO/CRO) interact with the board's risk committee. The primary frame is about the reporting relationship and how the risk committee gets informed.

Looking at Rule 2: "CISO reports quarterly to the Board on..." → Management Role (CISO is primary actor). But here, the risk committee's oversight is also prominent.

The second sentence shifts focus to the risk committee as the subject receiving those reports. Reading through again, I see the CISO and CRO are the primary actors in sentences 1 and 3, but they're described in terms of supporting the board's oversight function rather than their own capabilities. The phrase "support the cybersecurity risk oversight responsibilities of the Board and the risk committee" really frames this as Board Governance—it's about how the board committee exercises oversight through management's reporting and escalation mechanisms.

For specificity, I'm looking at what's actually named here: CISO is a cybersecurity-specific title that qualifies, and Risk Committee is explicitly listed as a named committee. CRO isn't on the IS list and doesn't fall into the NOT list either, so it's not a match. "Periodic reports" is too generic. That gives me two firm-specific items but neither qualifies for QV, so this lands in Firm-Specific.

fact: Risk Committee


reasoning: This paragraph enumerates generic cybersecurity risk scenarios (data breaches, service disruption, IP theft, remediation costs) and their potential consequences. It contains no substantive cybersecurity disclosure — no description of processes, governance, incidents, or materiality assessments. It reads as general risk language that could apply to virtually any technology or content company, with no program, framework, or action described.

thinking:
This paragraph lists generic cybersecurity risk scenarios (data breaches, service disruption, IP theft, response costs). It doesn't describe any actual program, process, incident, or governance structure. It's generic risk language that could apply to almost any company.

Let me check: does it make a materiality assessment? No - it just lists potential consequences. No "materially affected" language.

It's essentially a risk factor description within Item 1C. It describes potential impacts but no actual cybersecurity disclosure content (no processes, no governance, no incidents, no strategy).

This is None/Other - it's general risk language with no substantive cybersecurity disclosure.

Even though the next section mentions specific data types like nicknames, email addresses, and identification numbers, the paragraph still doesn't disclose anything substantive about the company's actual cybersecurity practices or governance—it's just listing generic risk scenarios with slightly more concrete examples of what could be lost. This remains generic boilerplate with no real disclosure content.


reasoning: The Board of Directors is the grammatical subject overseeing cybersecurity risk, with delegation to the Audit Committee. No firm-specific facts are present — 'Board of Directors,' 'executive officers,' and 'Audit Committee' are all on the NOT list as generic governance terms.

thinking:
Classify this paragraph.

The paragraph is about the Board of Directors overseeing cybersecurity risk. The board is the grammatical subject. It mentions the Audit Committee and executive officers, but the primary focus is board oversight.

Content category: Board Governance - the Board is the grammatical subject performing oversight.

Specificity: Let me check the facts:
- "Board of Directors" - generic governance, NOT list
- "executive officers" - generic
- "Audit Committee" - generic, NOT list

No IS-list facts, no named standards.

This falls under Generic Boilerplate.


reasoning: The company explicitly states it was a SPAC with no business operations and has not adopted any cybersecurity risk management program or formal processes. Per the SPAC/no-operations rule, the absence of a program is not a description of a program, so this is None/Other despite touching on risk acknowledgment.

thinking: SPAC/shell company, no operations, no program.


reasoning: The paragraph opens by naming two roles (Chief Compliance Officer, Head of Global IT) but immediately pivots to describing the company's risk identification and assessment methods — monitoring, automated tools, threat analysis, audits, vulnerability assessments, tabletop exercises. Applying the person-vs-function test: remove the role titles and the paragraph still fully describes internal processes, so this is Risk Management Process. For specificity, Chief Compliance Officer is generic C-suite (NOT list) and Head of Global IT is a generic IT leadership title (NOT list); all listed activities (vulnerability assessments, tabletop exercises, threat assessments) are common practices on the NOT list, with no named frameworks, tools, dates, or numbers.

thinking:
Let me analyze this paragraph.

Content: Mentions Chief Compliance Officer and Head of Global Information Technology helping identify/assess/manage cybersecurity threats. Then describes various methods: manual and automated tools, analyzing reports, evaluating threats, audits, threat assessments, vulnerability assessments, tabletop exercises.

Category: The first sentence names two roles, but then the paragraph pivots to describing what the company does - monitoring, evaluating, using tools, assessments, exercises. Apply the person-vs-function test: remove the role titles and the paragraph still describes processes. → Risk Management Process.

Wait - "Head of Global Information Technology" - is this a cybersecurity-specific title? It's more of a generic IT leadership title.

Both roles are on the NOT list - Chief Compliance Officer is generic C-suite, and Head of Global Information Technology is essentially the same as Head of IT. The practices mentioned like vulnerability assessments, tabletop exercises, and threat assessments are all standard boilerplate activities. There are no named frameworks, specific tools, dates, or numbers to make this concrete. This is clearly generic boilerplate.


reasoning: Colombier Acquisition Corp. II is a SPAC that explicitly states it is an 'early-stage company without significant investments in data security protection' and 'lack[s] sufficient resources to adequately protect against... cyber incidents.' Per the codebook's SPAC rule, companies that explicitly lack a cybersecurity program receive None/Other regardless of incidental mentions of board reporting (which here is purely hypothetical — 'In the event of') or generic risk language. The absence of a program is not a description of a program.

thinking:
This is a SPAC/early-stage company with no significant cybersecurity program. Let me analyze carefully.

The paragraph says:
- Management Team will report to Board in event of incident (hypothetical)
- "early-stage company without significant investments in data security protection"
- "lack sufficient resources to adequately protect against... cyber incidents"
- Generic risk language about material adverse consequences
- "We have not encountered any cybersecurity incidents since our Initial Public Offering"

This fits the SPAC/no-operations pattern. The company explicitly states it lacks resources and investments in data security. The board mention is hypothetical ("In the event of...").

The codebook says SPACs and shell companies explicitly stating they have no operations, no cybersecurity program, or no formal processes should be coded as None/Other regardless of board oversight mentions. This company doesn't use those exact words, but "early-stage without significant investments" and "lack sufficient resources" is essentially the same thing—they're describing a company with no real cybersecurity infrastructure. The materiality language about "material adverse consequences" is just standard risk disclosure boilerplate, not an actual materiality assessment.

The no-incident statement since IPO is worth noting, but given that Colombier Acquisition Corp. II is explicitly a SPAC with no meaningful cybersecurity program, this falls squarely under the Rule 5 exception and SPAC guidance. The answer is None/Other, which automatically gets Generic Boilerplate for specificity.


reasoning: This is a SPAC/shell company that explicitly states it has no cybersecurity risk management program or formal processes. Per the codebook's SPAC rule, the absence of a program is not a description of a program. The board mention is perfunctory ('as deemed necessary'), and the materiality assessment is subordinate to the overarching disclosure that no substantive cybersecurity program exists. Matches Case 8 almost exactly.

thinking:
SPAC/shell company with no operations, no cybersecurity program. Per Case 8 and the None/Other rules for SPACs.

Wait - there's a materiality assessment in the last sentence. Let me check the rules.

The codebook says: "SPACs and shell companies explicitly stating they have no operations, no cybersecurity program, or no formal processes → None/Other regardless of incidental mentions of board oversight or risk acknowledgment."

Case 8 example is very similar and is None/Other. The absence of a program is not a description of a program.


reasoning: The paragraph describes the company's own internal cybersecurity processes—layered defenses, monitoring, simulations, penetration testing, and policy reviews. Third-party experts are mentioned as one component of internal processes, not as the central topic. No named frameworks, tools, firms, roles, dates, or quantified facts appear; all items (penetration tests, simulations, end-user training) are common practices on the NOT list.

thinking:
Classify this paragraph.

Content: Describes internal cybersecurity processes - investments in IT security, training, layered defenses, monitoring, testing, simulations, penetration tests, reviewing policies with third-party experts.

Category: Risk Management Process - describes the company's own internal processes, tools, methodologies. Third parties mentioned as one component.

Specificity: Let me check for specific facts.
- No named frameworks
- No cybersecurity-specific titles
- No named committees
- No specific dates
- No named tools/products/firms
- No specific numbers
- "third-party experts" is on the NOT list

- "penetration tests" and "simulations and drills" are common practices on the NOT list

No IS-list facts and no named standards present, so this falls into Generic Boilerplate.


reasoning: The paragraph makes an explicit materiality assessment ('no material cybersecurity threats and incidents') and states cybersecurity threats 'could materially affect our business strategy, results of operations, or financial condition,' which triggers Strategy Integration per Rule 6. The appended cross-reference to Risk Factors does not change the classification. No firm-specific facts, named standards, or verifiable details are present — all language is boilerplate.

thinking:
Let me analyze this paragraph.

Content: First sentence is a materiality assessment ("no material cybersecurity threats and incidents"). Then generic risk language. Then a forward-looking statement about potential material impact with a cross-reference.

Category: The paragraph opens with a materiality assessment and includes "materially affect our business strategy, results of operations, or financial condition." Per Rule 6, materiality disclaimers → Strategy Integration. The cross-reference doesn't change this.

Specificity: No named standards, no firm-specific facts. All boilerplate language. → Generic Boilerplate.