reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing its integration into the overall ERM program, making it RMP. All language is generic ERM terminology ('common methodologies, reporting channels and governance processes,' 'operational, financial and strategic risks') with no cybersecurity domain terms, firm-specific facts, or verifiable claims, keeping it at Level 1.

thinking:
Classify this paragraph.

Content: Describes integration of cybersecurity into ERM. "What does the cybersecurity program do?" → RMP. It's about how the program is structured within the broader ERM framework.

Specificity: Let me scan for facts.
- "enterprise risk management program" - general business language, L1
- "common methodologies, reporting channels and governance processes" - generic
- "operational, financial and strategic risks" - generic
- "MAMMOTH ENERGY SERVICES, INC." - company self-reference, not firm-specific

Everything here is generic ERM language.

No domain terminology, no firm-specific facts, no QV facts. This is clearly Level 1.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing risk assessments, employee training, security tools, incident response planning, and monitoring — all RMP activities. Despite covering multiple program elements, every term used (risk assessments, employee awareness training, security analytical tools, incident response plan, incident classification) is general business/ERM language that fails the ERM test — none are cybersecurity domain-specific terminology. No firm-specific facts or verifiable claims are present.

provider: anthropic

generationId: agent-sdk

stage: benchmark


content_category: Third-Party Risk

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing ongoing compliance monitoring of service providers via weekly calls and issue remediation, making it TP. No domain terminology (compliance monitoring and weekly calls are general business language passing the ERM test), no firm-specific facts (no named roles, committees, or unique organizational details), and no verifiable claims — 'weekly' is a generic cadence, not a specific date or quantified fact.

thinking:
Classify this paragraph.

Content: About managing third-party service provider risks through weekly calls and compliance monitoring.

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

Specificity: "weekly calls" is a specific cadence but generic. No domain terminology, no firm-specific facts, no QV facts. This is generic business language about vendor oversight. Level 1.

Wait - "weekly" is a generic cadence. No domain terms, no named roles, no verifiable facts.

Level 1.


content_category: Strategy Integration

reasoning: The paragraph states a materiality conclusion — 'we have not identified any prior cybersecurity incidents that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition' — which is the SEC's Item 106(b)(2) language, making this SI. The remainder is generic resource mentions, a cross-reference to Item 1A, and boilerplate disclaimers. No domain terminology, firm-specific cybersecurity facts, or verifiable claims are present; the company self-reference ('Okta') and business description ('identity and security solutions') are not cybersecurity posture facts, so specificity stays at Level 1.

thinking:
Let me analyze this paragraph.

Content: This paragraph discusses resources devoted to cybersecurity, acknowledges Okta as an attractive target, references Risk Factors, mentions past incidents without material effect, states a materiality conclusion, and includes forward-looking disclaimers.

Category: The key sentence is "To date we have not identified any prior cybersecurity incidents that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition." This is a materiality assessment → SI.

The paragraph also has generic resource mentions, cross-reference to Item 1A, and disclaimers.

But the materiality conclusion is really what matters here. Looking at the specificity, I'm not finding much—just self-references to Okta, generic descriptions of the business, boilerplate SEC language around materiality, and no actual domain-specific cybersecurity facts or verifiable claims. This reads as Level 1 disclosure.

The acknowledgment that "in the past we have experienced cybersecurity incidents" is there, but it's vague and doesn't actually describe what happened. The real substance is just the materiality assessment, which uses standard SEC language that could apply to almost any company with minimal changes.


content_category: Board Governance

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — describing delegation to the Audit Committee and reporting cadence, which is classic BG. No domain terminology, no firm-specific facts (Audit Committee exists at every public company, 'senior management' is generic, cadences are unspecified), and no verifiable claims — remains Level 1.


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


content_category: Management Role

fact: over 20 years of experience in information security, risk management, and compliance

type: quantified

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' — it identifies the DIT as primarily responsible, describes their qualifications and experience, and notes senior management support. The person-removal test leaves only generic fragments ('assessment and management of material cybersecurity risks'), confirming MR over RMP. The audit committee mention is subordinate framing. 'Over 20 years of experience' is a lower-bound quantified fact verifiable against a resume, elevating to Level 4. Note: 'Director of Information Technology' lacks a security qualifier and does not qualify as firm-specific per codebook rules.

thinking:
Let me analyze this paragraph.

**Category:** This paragraph describes who is responsible for cybersecurity - the DIT, their qualifications, and support structure. The person-removal test: remove "Chief Executive Officer," "Director of Information Technology (DIT)," "over 20 years of experience," "served essential security and audit roles at other organizations," "supported by members of senior management who provide cross-functional support." What remains? "the assessment and management of material cybersecurity risks" and "facilitate the response to any cybersecurity incidents" - generic, not a substantive program description. → **MR**

Now looking at the specificity angle. The DIT title itself doesn't qualify as firm-specific since it lacks a security qualifier like "Director of Cybersecurity" or "Director of Information Security" - it's just a standard IT director role. The experience metric of "over 20 years" is just a lower bound without additional detail.

But "over 20 years of experience in information security" is verifiable against a resume - I can check whether someone's actual experience meets or exceeds that threshold. That makes it QV-eligible and pushes this to Level 4.


reasoning: The paragraph states a materiality conclusion — 'have not identified risks...that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition' — which is both a backward-looking and forward-looking assessment, making it SI per Rule 5. The opening risk acknowledgment and cross-reference to Item 1A are subordinate to this assessment. Specificity is Level 1 because the entire paragraph uses standard SEC boilerplate language (quoting the SEC's own definition, generic risk factors cross-reference, and the formulaic materiality assessment), with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

Content: The paragraph has two parts:
1. Generic risk acknowledgment about cybersecurity threats with SEC definition and cross-reference to Risk Factors
2. A materiality assessment: "we have not identified risks...that have materially affected or are reasonably likely to materially affect us"

The second part is a clear materiality conclusion (both backward and forward-looking) → SI per Rule 5.

The first part is generic risk language with a cross-reference. But the second part is a substantive materiality assessment. SI wins.

Specificity: Let me scan for facts.

The language here is all boilerplate—references to the CIA triad and SEC definitions, generic mentions of subcontractors and suppliers, and a standard cross-reference to Risk Factors. There are no firm-specific facts or domain-specific details. This is Level 1 - Generic Boilerplate.


content_category: Incident Disclosure

fact: Form 8-K filed on July 14, 2023

fact: on or about May 31, 2023 (date informed of vulnerability)

fact: zero-day vulnerability

fact: MOVEit (named managed file transfer software)

fact: First National 1870 (named division)

fact: Guardian Mortgage (named division)

reasoning: The paragraph describes an actual cybersecurity incident — a zero-day vulnerability in MOVEit discovered around May 31, 2023 — answering 'what happened?' and making it Incident Disclosure. Multiple QV-eligible facts are present: specific dates (July 14, 2023 and May 31, 2023), a named software product (MOVEit), and named divisions, all independently verifiable.

thinking: Incident disclosure with specific dates, named software, and named divisions.


content_category: None/Other

reasoning: This paragraph describes the general threat landscape facing Okta (hackers, malware, ransomware, phishing, APTs, nation-state actors) and states a generic commitment to protection, but does not answer any of the six substantive questions — it describes no program activities, governance structure, management roles, incident, or materiality assessment. It is introductory/contextual framing. As N/O, specificity is automatically Level 1.

thinking:
Let me analyze this paragraph.

Content: Lists threat types facing Okta, then states commitment to protection. No actual program description, no governance, no incident. This is general threat landscape language.

Category: This doesn't answer any of the six substantive questions directly. It describes the threat environment but doesn't describe what the program does (RMP), how the board oversees (BG), etc. The last sentence is a generic commitment statement. This is N/O... but wait, let me reconsider.

Actually, it does mention specific threat types (ransomware, malware, phishing, APT, denial-of-service, password spraying).

The real question is whether simply naming threats qualifies as substantive disclosure. The paragraph doesn't detail any actual measures, processes, or risk assessments—it's just setting the threat context. Even mentioning third-party service providers face these risks doesn't change that the core content is introductory framing rather than describing program activities, governance structures, or incident handling. I'm leaning toward N/O since Rule 5 requires substantive cybersecurity disclosure, and listing threats without describing what the company actually does doesn't meet that threshold.

Though the paragraph does show some domain knowledge by specifying threat types, it's still fundamentally about the threat landscape rather than answering what the cybersecurity program does. That makes it contextual framing, not RMP. So N/O with Specificity 1.


reasoning: This paragraph describes the company's general IT and OT infrastructure for business operations (refinery processes, pipelines, accounting) — it answers none of the six substantive cybersecurity disclosure questions and contains no cybersecurity measures, governance structures, or risk assessments. While IT/OT are mentioned, the context is business operations rather than cybersecurity; no domain terminology, firm-specific cybersecurity facts, or verifiable claims are present.

thinking:
Let me classify this paragraph.

This describes general IT/OT infrastructure and business systems - not cybersecurity measures, governance, or any of the six substantive categories. It's background about the company's technology environment.

No cybersecurity-specific content. No domain terminology. No firm-specific cybersecurity facts.

This is N/O.

Wait - "IT and OT" - OT (Operational Technology) could be considered domain-relevant in a cybersecurity context. But here it's describing business operations (refinery processes, pipelines), not cybersecurity measures. The paragraph is about what systems they use for business, not how they secure them.

The mention of "IT and OT" is just standard industrial language here, not cybersecurity terminology. This is clearly N/O with a specificity rating of 1.


reasoning: The paragraph acknowledges the company lacks manpower, expertise, and resources to address cybersecurity — it describes the absence of a program rather than any substantive cybersecurity measures, governance, or strategy, fitting the N/O rule for no-operations/resource-lacking companies. All language is generic risk/business terminology ("identify, detect, prevent," "cybersecurity risks," "vulnerabilities") with no domain-specific practices, firm-specific facts, or verifiable claims.

thinking:
This is a company acknowledging it lacks cybersecurity capabilities. Let me classify.

Content: The paragraph says the company doesn't have manpower, expertise, or resources to handle cybersecurity. This is essentially saying they have no program. It's a risk acknowledgment without any substantive disclosure of measures taken.

Category: This feels like N/O or SI. There's no program described, no governance, no management role. It's pure speculation/risk acknowledgment. "No assurance or guarantee" - speculation. The company is essentially a SPAC-like entity with no cybersecurity program. N/O.

Specificity: Level 1 - no domain terms that pass the ERM test.

The language here is all generic—terms like "IT security vulnerabilities" and "cybersecurity risks" lack any firm-specific detail or concrete practices. There's no mention of actual security measures like penetration testing or SIEM systems, just vague references to identification and remediation. This stays at Level 1.


fact: threat intelligence

category_confidence: medium

specificity_confidence: medium

reasoning: This is a governance-chain paragraph that begins with the Audit Committee reporting to the Board and Board receiving briefings from management, then describes management's responsibilities within that oversight structure. While management content occupies more text, the paragraph's purpose is mapping the oversight flow (Board ← Committee ← Management), defaulting to BG under Rule 1. The person-removal test shows generic responsibility language rather than specific program activities, reinforcing this as oversight-structure description. For specificity, 'threat intelligence' is domain terminology (passes ERM test), but no firm-specific or verifiable facts are present — Audit Committee is generic, consultants are unnamed, and all other language is general.

thinking:
Let me analyze this paragraph.

Category: This paragraph starts with Audit Committee reporting to the Board (BG), then shifts to management's role. Let me assess the balance.

- "Audit Committee reports to the full Board regarding cybersecurity activities" → BG
- "The full Board also receives briefings from management on cyber risk issues" → BG
- "Our management team is responsible for assessing and managing our material risks" → could be MR or RMP
- Rest describes what the management team does - developing methodology, supervising personnel, preventing/detecting/mitigating risks through various means.

This is a governance-chain paragraph.

Applying the person-removal test, I can see the core management responsibilities underneath: assessing and managing material risks, developing cybersecurity risk methodology, supervising internal and external security personnel, and implementing prevention, detection, mitigation and remediation efforts. The paragraph is really describing the oversight structure—how the Board receives information from management and what management is accountable for—so it's fundamentally about governance even though most of the text focuses on management's specific duties. I'm going back and forth on whether this is governance-chain (BG) or management responsibilities (MR). The paragraph does describe the oversight structure from Board down through management, which would make it BG by default. But the bulk of the text actually focuses on what management does—assessing risks, developing methodology, supervising personnel—rather than the oversight flow itself. The person-removal test suggests these are management responsibilities, not structural oversight. I think the deciding factor is that governance-chain paragraphs default to BG when describing oversight structure, and that's fundamentally what this paragraph is doing, even though management's role takes up more space.

Now I'm checking for specificity. Most of this is generic—Audit Committee, management team, cybersecurity risk methodology, internal and external personnel. But "threat intelligence" stands out as domain-specific terminology that a non-security professional wouldn't naturally use. That pushes this to Level 2 specificity.


reasoning: The paragraph answers 'How does the board oversee cybersecurity?' — describing board expertise, oversight documentation, and reporting mechanisms for cybersecurity risks, which maps directly to BG. No domain terminology passes the ERM test (terms like 'cybersecurity risks,' 'incident response,' 'reporting mechanisms,' and 'oversight' are general business/governance language), no firm-specific facts beyond the generic 'Board of Directors,' and no verifiable claims, leaving this at Level 1.

thinking:
Board governance paragraph about board oversight of cybersecurity.

Category: Board Governance - answers "How does the board oversee cybersecurity?" Covers board expertise, oversight, reporting mechanisms.

Specificity: Let me scan for facts.
- "Board of Directors" - not firm-specific (every company has one)
- "substantial cybersecurity expertise" - generic claim
- "reporting mechanisms" - generic
- No domain terminology that passes the ERM test
- No firm-specific facts (no named roles, committees beyond the Board)
- No QV facts

This is generic boilerplate - could be pasted into any filing.

The next thinking just says "Level 1" which appears to be a classification or rating. I'm categorizing this content at the lowest specificity level since it contains only generic governance language without any firm-specific details or concrete facts.


fact: Chief Information Officer (CIO)

fact: Chief Information Security Officer (CISO)

fact: Cyber Incident Response Teams

fact: Partnership with Risk and Legal (specific team composition)

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' — it describes the CIO-CISO reporting line, the CISO's team responsibilities, and the Cyber Incident Response Teams' role alongside Risk and Legal. Person-removal test: removing roles, reporting lines, and team structure leaves only generic fragments about 'information security strategy' and 'monitoring cybersecurity posture,' confirming MR. Specificity is Level 3 due to multiple firm-specific roles (CIO, CISO) and a named team (Cyber Incident Response Teams) with specific departmental partnerships, but no externally verifiable facts push it to Level 4.

thinking:
Let me analyze this paragraph.

Category: This describes management roles (CIO, CISO), their responsibilities, reporting lines, and team structure. Person-removal test: remove CIO, CISO, titles, reporting lines, team composition → what remains? "Information Security is built into the Company's larger technology strategy" and "enterprise-wide information security strategy, policy, standards, architecture, and processes" and "monitoring and analyzing the Company's cybersecurity posture." There's some program description but the primary content is about WHO does WHAT - role allocation, reporting lines, team structure. This is MR.

The specificity markers confirm it's firm-specific: named roles like CIO and CISO, the Cyber Incident Response Teams with their particular composition, and the partnerships with Risk and Legal. No quantifiable facts or external references—this is Level 3 specificity.


reasoning: The paragraph describes 'information security processes designed to identify, assess and manage material risks from cybersecurity threats' — answering 'what does the cybersecurity program do?' No domain terminology passes the ERM test; 'processes to identify, assess, and manage risks' and 'measures to protect systems and data' are explicitly listed as Level 1 general business language. The enumeration of protected assets (networks, communications, hardware, software, data) is generic asset categorization any company could use.


reasoning: The paragraph's central topic is oversight of cybersecurity risks from third parties (vendors, service providers, external users), directly answering 'How are third-party cyber risks managed?' No domain terminology, firm-specific facts, or verifiable claims are present — the language ('comprehensive, risk-based approach,' 'assessing and overseeing') is generic ERM vocabulary any business professional could write.

thinking:
TP vs RMP analysis: Central topic is third-party cyber risk management. The paragraph describes their approach to assessing/overseeing cybersecurity risks from vendors, service providers, and external users.

Category: Third-Party Risk - answers "How are third-party cyber risks managed?"

Specificity: Let me check for domain terms, firm-specific facts, QV facts.
- "risk-based approach" - generic ERM language
- "vendors, service providers" - generic
- "cybersecurity incident" - topic not domain expertise
- No domain terminology, no firm-specific facts, no QV facts

This is generic boilerplate - could be pasted into any filing.

The maturity level here is 1 - this is just standard disclosure language without any meaningful detail about how they actually manage third-party cyber risks.


fact: CISO

fact: Security Governance Committee

reasoning: The paragraph describes who comprises the Security Governance Committee and the CISO's qualifications, directly answering 'how is management organized?' → MR. 'Over 20 years' is a verifiable lower bound on experience, elevating to Level 4.

thinking:
Classify this paragraph.

Content: About the CISO and Security Governance Committee membership, plus CISO's experience.

Category: Management Role - about who holds responsibilities, committee membership, qualifications.

Specific facts:
- CISO (named_role, firm-specific)
- Security Governance Committee (named_committee, firm-specific)
- "over 20 years of cybersecurity and technology management experience" (quantified - verifiable lower bound)

Specificity: Level 4 (QV) due to "over 20 years"


fact: ransomware

fact: malware

fact: phishing

reasoning: The opening sentence states a materiality conclusion ('not aware of any material cybersecurity incidents that impacted the Company in the last three years'), making this SI per the materiality assessment rule — even though the remainder is generic risk speculation and a cross-reference to Item 1A. Specificity reaches Level 2 via domain-specific threat types (ransomware, malware, phishing); the date 'December 31, 2024' anchors a negative self-assertion and is not externally verifiable, so it does not qualify as QV.

thinking:
Let me analyze this paragraph.

Content: Mixed paragraph with negative materiality assertion, risk language, and cross-reference.

First sentence: "As of December 31, 2024, we are not aware of any material cybersecurity incidents that impacted the Company in the last three years." - This is a materiality assessment (negative assertion). Per Rule 5, "Have not experienced any material cybersecurity incidents" → SI.

Rest: speculation about risks ("could"), generic risk language, and cross-reference to Item 1A.

The first sentence IS a materiality conclusion → SI. The rest is speculation/cross-reference which would be N/O.

But I'm realizing the materiality assessment itself is the substantive content here. Looking at the specificity of the language—terms like "ransomware," "malware," and "phishing" are domain-specific, while "cyber-attacks" and "cyber intrusions" are more general. The key issue is whether that negative assertion "not aware of any material cybersecurity incidents" is actually verifiable. The codebook is clear: this kind of negative self-assertion isn't externally verifiable, whether it's framed as "we have not experienced" or anchored to a specific date.


fact: executive risk committee

fact: comprised of Chief Financial Officer, Chief Legal Officer and Senior Vice President, Engineering Operations

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' by describing the executive risk committee's composition, the cybersecurity team's qualifications, and individual members' expertise — person-removal leaves little substantive content. Specificity is Level 3: the named executive risk committee with its specific composition (CFO, CLO, SVP Engineering Operations) are firm-specific facts, but 'decades of technical experience' is a soft number and no certifications or named external entities push it to Level 4.

thinking:
Let me analyze this paragraph.

Category: This describes management's organizational structure for cybersecurity. It covers the executive risk committee composition, the cybersecurity team's qualifications, and the committee members' expertise. The person-removal test: remove all person-specific content and what remains? Very little - maybe "cybersecurity risk assessment and mitigation activities" and "regular reports... regarding the nature, timing and extent of incidents." The bulk is about WHO is on the committee, their qualifications, team composition. This is MR.

Specificity: Let me scan for facts:
- "executive risk committee" - named committee → firm-specific

- The CFO and CLO titles are standard roles, but SVP Engineering Operations is more specialized. Looking at the codebook criteria, it doesn't explicitly match the listed security-specific titles like "VP of Information Security," so I need to determine if this counts as a named cybersecurity role or just a generic executive title in a cybersecurity context.

- The team's qualifications—computer science degrees, cybersecurity assurance credentials—are generic descriptors without specifics.

- "Decades of experience" is vague and doesn't constitute a quantifiable fact.

- The firm-specific elements here are the executive risk committee as a named governance structure and the specific composition with SVP Engineering Operations overseeing cybersecurity, which suggests a named role even if not explicitly security-titled.

- No quantifiable facts present—no specific numbers, dates, external certifications, or named entities beyond the committee itself.

- This lands at Level 3.


reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing ERM integration and listing assessment activities (maturity assessments, IT risk assessments, third-party security assessments); the Audit Committee mention is subordinate context. All terminology ('risk assessments,' 'program maturity assessments,' 'enterprise risk management') is standard ERM language that fails the domain-expertise test, with no firm-specific or verifiable facts.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity risk management as part of ERM, overseen by Audit Committee, includes maturity assessments, IT risk assessments, and third-party security risk assessments.

Category: "What question does this paragraph primarily answer?" It describes what the program does - periodic assessments, IT risk assessments, third-party assessments. The Audit Committee mention is subordinate. This is primarily about the risk management process activities. → RMP

Specificity: Let me scan for facts:
- "Audit Committee" - NOT firm-specific (every company has one)

- "program maturity assessments" - general ERM language
- "information technology risk assessments" - general IT/ERM
- "third-party security risks assessments" - general

No domain terminology that passes the ERM test. No firm-specific facts. No QV facts. All the language here is standard business and ERM terminology without any distinguishing details. This is Level 1 - Generic Boilerplate.


fact: CTO (Chief Technology Officer) directs cybersecurity program

fact: CFO co-directs the cybersecurity program

fact: CTO has over 26 years of information technology experience

fact: Prior roles: Director of Technology, Information Technology Manager, Technical Manager, Systems Analyst

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' — describing who holds responsibility (CFO and CTO), the CTO's qualifications and career history, and team composition. Person-removal test leaves almost nothing substantive. Specificity reaches Level 4 because 'over 26 years' is a verifiable lower bound on the CTO's experience.

thinking:
Let me analyze this paragraph.

Content Category: This is primarily about management's organizational role - who handles cybersecurity (CFO, CTO), their qualifications, experience, and responsibilities. Person-removal test: remove CFO, CTO, titles, qualifications, experience, reporting lines → very little remains. → MR

Specificity: Let me scan for facts:
- CFO (not cybersecurity-specific per codebook - "CEO, CFO, COO... not cybersecurity-specific roles") - wait, but CFO is listed as NOT firm-specific. However, CTO IS listed as firm-specific.

- CTO is a firm-specific cybersecurity leadership role at VP level or above
- The "over 26 years" of IT experience is a verifiable lower bound → QV
- Career history includes Director of Technology, Information Technology Manager, Technical Manager, and Systems Analyst roles
- Mentions certified information security professionals but no specific certifications named

So the quantifiable fact here is that "over 26 years" of IT experience, which gives us a specific lower bound. Level 4.


reasoning: The paragraph splits between RMP (using third-party auditors/experts to validate and implement the company's own program) and TP (requiring service providers to certify security measures and report breaches). The longest, most detailed sentence imposes requirements ON vendors, and vendor oversight is the most distinctive content, tipping the balance to Third-Party Risk. All language is generic business/contractual language — 'risk management program,' 'security measures,' 'policies and procedures,' 'monitor and test safeguards' — none passes the ERM test for domain terminology, and no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. Third parties hired to help the company (auditors, experts assisting with design/implementation/monitoring) → RMP
2. Requirements imposed on third-party service providers (certification requirements, security measures, breach reporting) → TP

The second part about requirements on service providers is substantial. Let me weigh which is dominant.

Sentences:
1. "We engage independent third party auditors to validate our risk management program." → RMP (third parties serving the company)

2. "Third party experts assist us to design and implement our cybersecurity policies and procedures, as well as to monitor and test our safeguards." → RMP (third parties serving the company)
3. "We require each third-party service provider to certify that it has the ability to implement and maintain appropriate security measures..." → TP (requirements on vendors)

The third sentence is quite lengthy and detailed about what we require from service providers, but the first two sentences together also cover substantial ground about third parties we engage. This is genuinely split between describing the third parties we use versus the requirements we impose on them. The TP sentence is notably long and specific about certification and security measures.

Let me reconsider Rule 3 here. The first two sentences clearly fit RMP—they're about experts we hire to help us. The third sentence is distinctly TP because it's about requirements we place on vendors. By text volume alone, the third sentence probably outweighs the first two combined, so I'd lean toward classifying this as TP overall. The third sentence about vendor requirements is actually longer and more detailed, so I'm leaning toward Third-Party Risk as the classification, though I recognize the paragraph genuinely straddles both categories depending on how you weight the opening framing versus the substantive content. Looking at the specific language used here—"third party auditors," "risk management program," "cybersecurity policies," "monitor and test safeguards"—none of this rises to domain-specific terminology. There are no firm-specific facts or quantitative details that would signal anything beyond generic boilerplate. This is Level 1 language that any risk management professional could produce.


fact: cloud-based technology to scan and analyze for vulnerable software or misconfigurations (vulnerability scanning)

reasoning: The paragraph splits between describing internal security software (vulnerability scanning) and third-party oversight processes (questionnaires, contractual security controls, monitoring, discontinuation based on cybersecurity posture). The third-party risk management content occupies the majority of the text and is the most substantive portion, making TP the best fit. 'Scanning for vulnerable software or misconfigurations' is domain terminology (vulnerability scanning) elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. First sentence: describes security software used (cloud-based scanning for vulnerabilities/misconfigurations) - this is about the company's own security tools/processes
2. Second sentence: systems developed internally or by third parties
3. Rest: describes how they assess third-party cybersecurity controls - questionnaire, contractual requirements, monitoring, ability to discontinue

The central topic shifts. The first part is about their own security tools (RMP), but the bulk of the paragraph (sentences 3 onward) is about third-party risk management - assessing vendors, imposing requirements, monitoring them, discontinuing if standards not met.

The third-party risk management content takes up most of the paragraph by volume, so that's really what's being emphasized here. The opening mentions their own vulnerability scanning, but then it pivots to how they handle third-party cybersecurity controls through questionnaires, contractual obligations, ongoing monitoring, and the ability to terminate relationships if needed.

Looking at the specificity level, they're using domain terminology like "vulnerability scanning" and "cloud-based technology," which puts this at Level 2. The cybersecurity questionnaire and contractual security controls are process descriptions but fairly standard across the industry. There's nothing quantifiable here—no numbers, dates, or named certifications—and nothing that seems unique to this particular company. So this lands at Level 2: Domain-Adapted.


fact: Namecheap (named hosting provider)

fact: GoDaddy (named hosting provider)

fact: Cloudflare (named hosting provider)

reasoning: The paragraph describes the company's cybersecurity risk posture and how it is addressed through third-party hosting services. Per Rule 3, third parties hired to serve the company's own operations are RMP, not TP—no requirements are imposed on vendors nor is vendor cybersecurity assessed. Specificity is Level 4 because Namecheap, GoDaddy, and Cloudflare are named external entities whose use is independently verifiable.

thinking:
Let me analyze this paragraph.

Content: Small company saying their only cyber risk is from websites, hosted by Namecheap, GoDaddy, and Cloudflare.

Category: This describes third-party hosting but in the context of their overall risk posture. It's saying "here's our risk and we use these vendors." The central topic is really about how they manage their (minimal) cybersecurity risk through third-party providers. This feels like Third-Party Risk - they're describing their reliance on external hosting companies for security.

Actually, let me reconsider.

The company is identifying their cybersecurity risk and naming the hosting providers they rely on, but they're not actually describing how they manage vendor security or impose requirements on these third parties. They're just stating that they use reputable companies, which is more of a risk posture disclosure than active third-party risk management. This leans toward a basic risk management program description rather than third-party vendor management practices.

Since the hosting companies serve the company's operations, this falls under RMP. The fact that they've named specific external entities like Namecheap, GoDaddy, and Cloudflare—which are externally verifiable—pushes this to Level 4 specificity.


reasoning: This paragraph is a generic commitment statement about protecting IT assets and data. It does not answer any of the six substantive cybersecurity questions — no program details, no governance structure, no management roles, no incidents, no materiality assessment. No domain terminology, firm-specific facts, or verifiable claims are present.


fact: data encryption

category_confidence: low

reasoning: This paragraph describes the regulatory landscape and the company's response of monitoring for compliance. It barely qualifies as substantive cybersecurity disclosure — the only active measure is 'we actively monitor legislative and regulatory developments to ensure compliance,' which is a generic compliance activity. However, the mention of 'data encryption' as a regulatory requirement is domain terminology that passes the ERM test, elevating specificity to Level 2. The category is borderline N/O vs RMP; the final sentence describes an actual activity (monitoring for compliance), tipping it narrowly to RMP.


reasoning: The paragraph opens with a backward-looking and forward-looking materiality assessment ('have not materially affected... not reasonably likely to materially affect'), which is the SEC's Item 106(b)(2) language — making it SI per the materiality rule. The subsequent speculation ('could be significant') and cross-references to Item 1A are subordinate. No domain terminology, firm-specific facts, or verifiable claims are present — all language is generic boilerplate.


reasoning: The paragraph contains a backward-looking materiality assessment ('we do not believe that any prior cybersecurity-related threats or incidents have materially affected our company'), which is SI per the materiality rule. While the third-party requirements sentence is longer, it is introduced with 'In addition,' signaling it is supplementary to the main disclosure point. All language is general business terminology — 'reasonable and appropriate security measures,' 'consistent with all applicable laws,' 'suspected breach' — none of which passes the ERM test for domain terminology, and there are no firm-specific or verifiable facts.

thinking:
Let me analyze this paragraph.

It has three parts:
1. Generic threat acknowledgment
2. Materiality assessment - "we do not believe that any prior cybersecurity-related threats or incidents have materially affected our company" - this is a backward-looking materiality conclusion → SI
3. Third-party requirements - requiring service providers to certify security measures

The materiality assessment is SI. The third-party content is TP. Which dominates?

The materiality statement is one sentence. The third-party content is also one sentence but longer. Let me re-read...

Actually, the paragraph has: (1) generic threat statement, (2) materiality conclusion, (3) third-party requirements.

The materiality conclusion and third-party requirements are roughly equal in text. But the "what question does this paragraph primarily answer?" test shows the materiality statement is a clear SI marker per Rule 5, while the third-party content describes requirements imposed on vendors → TP. This is genuinely split between SI and TP. Looking at text volume, the third-party sentence is longer and more detailed, so when genuinely split, the category with the most text wins.

But re-reading the full third-party requirement about certifying security measures and reporting breaches—that's substantial TP content. The SI content is just one sentence. The paragraph opens with a threat acknowledgment, then the materiality assessment, then the TP requirements. The first two sentences set context, and the third describes TP obligations. This is close, but I'm leaning toward TP since that sentence is quite detailed and lengthy. Actually, let me reconsider—the materiality assessment is the key disclosure point that directly answers how cybersecurity affects the business, making the TP content feel supplementary. But the TP sentence is still longer and more substantive, so I'll go with TP. The "In addition" phrasing confirms the materiality assessment is the main point, making this Strategy Integration. Looking at the specificity markers, there's nothing domain-specific here—just generic language about security measures and third-party providers with no named entities, numbers, or certifications. This is clearly Level 1 boilerplate.


reasoning: The paragraph mentions maintaining cybersecurity insurance and that costs may not be fully insured, which is a substantive (if brief) disclosure about how cybersecurity affects the business financially, making it SI over N/O. The 'could have a material adverse effect' language is speculation (not an assessment), and the cross-reference to Item 1A is subordinate. No domain terminology, firm-specific facts, or verifiable claims are present — all language is generic business boilerplate.

thinking:
Let me analyze this paragraph.

Content: Generic concluding language about cybersecurity priorities, speculation about incidents, mention of cybersecurity insurance, cross-reference to Risk Factors.

Category: The paragraph mentions cybersecurity insurance (SI marker) and has a "could have a material adverse effect" speculation. The insurance mention is a substantive fact - "maintains cybersecurity insurance" and "costs... may not be fully insured." The "could have a material adverse effect" is speculation (not SI per rules). But the insurance mention is a real business/financial integration point. The cross-reference to Item 1A is N/O-type content.

The paragraph has: generic aspirational language, speculation ("could have a material adverse effect" → not SI), cybersecurity insurance mention ("maintains cybersecurity insurance, costs may not be fully insured" → SI), and a cross-reference.

The insurance statement reveals how cybersecurity directly impacts the company's finances through coverage gaps and potential uninsured costs. While the "could have a material adverse effect" language is speculative and doesn't count as SI, the insurance disclosure itself is substantive—it's a real business fact showing the financial dimension of cybersecurity risk. The insurance mention, combined with the business continuity framing, makes this SI rather than N/O, even though the bulk of the paragraph is generic aspirational language and speculation.

"Cybersecurity insurance" is a financial product that any ERM professional would recognize, not domain-specific jargon. There are no domain terms, firm-specific facts, or quantitative values here, so this stays Level 1.


reasoning: The paragraph answers 'what does the cybersecurity program do?' — though it describes aspirational integration rather than an existing program. It uses only general business language ('confidentiality, integrity, and availability' is borderline but widely used in generic risk contexts; 'comprehensive risk management framework' and 'protect...critical systems and information' are standard ERM language). No domain terminology, firm-specific facts, or verifiable claims are present.


fact: Chief Information Officer (CIO) presents to Audit Committee on cybersecurity

reasoning: The paragraph answers 'How does the board oversee cybersecurity?' — describing how the Audit Committee receives reports from management, reports to the full Board, and how the Board receives briefings on cyber risk management. This is a classic governance-chain paragraph with the oversight structure as primary content → BG. The mention of the Chief Information Officer (a VP-level cybersecurity-adjacent role) elevates specificity to Level 3; CFO and Audit Committee are generic governance fixtures that don't qualify, and no QV-eligible facts (no specific numbers, dates, named external entities, or certifications) are present.

thinking:
Let me classify this paragraph.

Content: Describes how the Audit Committee and Board receive reports on cybersecurity risks, incidents, and cyber risk management. Information flows from management to Audit Committee to Board. Mentions CIO and CFO presenting to the Audit Committee.

Category: This answers "How does the board oversee cybersecurity?" — Board Governance. The Audit Committee receiving reports, reporting to the Board, Board receiving briefings — all oversight structure.

Specificity: Let me scan for facts.
- "Audit Committee" — NOT firm-specific (every public company has one)
- "Chief Information Officer" — CIO is a cybersecurity-specific VP+ title → firm-specific

- "Chief Financial Officer" — NOT firm-specific (generic governance role)
- "internal security staff" — generic
- "external experts" — unnamed, not specific
- "cyber risk management program" — generic
- "internal control over financial reporting" — generic

The CIO is the only firm-specific fact here—a VP-level role with IT and cybersecurity responsibilities. No specialized domain terminology or QV facts present.

Level 3 — Firm-Specific due to CIO.


reasoning: The paragraph describes Board-to-Audit Committee delegation of cybersecurity oversight, answering the BG question. All terms (Board, Audit Committee, ERM, internal controls) are generic governance language present at every public company, yielding Level 1.


reasoning: The paragraph discusses cybersecurity insurance as a tool to manage financial statement risk from cyber-attacks, directly answering how cybersecurity affects the business/finances — squarely SI. No domain terminology passes the ERM test (cybersecurity insurance and cyber-attacks are general business language), no firm-specific facts, and no verifiable claims, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: Discusses cybersecurity insurance to manage financial risk, with caveats about coverage limits. This is about how cybersecurity affects finances → Strategy Integration.

The materiality/business impact framing: cybersecurity insurance is explicitly listed under SI covers. The paragraph discusses insurance as a financial risk management tool.

Specificity: Let me scan for facts.
- "cybersecurity insurance" - this is a business/financial concept, not domain terminology per se. It's listed under SI covers but is it domain terminology? The ERM test: would a non-security ERM professional use "cybersecurity insurance"? Actually, insurance is a general business concept.

But "cybersecurity insurance" is specific to cyber risk, though it's fundamentally a financial and business term rather than security domain terminology—an ERM professional would definitely use this phrase, so I'd classify it as Level 1. "Information systems" is generic, and "cyber-attacks" is a broad threat category that an ERM professional would also recognize, making it Level 1 as well, even though more specific threat types like ransomware or APT exist in the domain terminology list.

There's no firm-specific information, no QV facts, and nothing that passes the ERM domain test, so this is Level 1 generic boilerplate.


reasoning: The paragraph contains a backward-looking materiality assessment ('we have not experienced any significant impacts from cybersecurity threats'), which is a conclusion about whether cybersecurity has affected business outcomes, making it SI. However, it's borderline with N/O due to the heavy cross-reference and speculative language. The remaining content is speculation ('could have a material impact') and a cross-reference to Item 1A. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: This is a single generic sentence about the threat environment with no substantive cybersecurity disclosure — no measures, processes, or assessments described. No domain terminology, firm-specific facts, or verifiable claims present.


reasoning: This paragraph discusses general IT investments for business operations, customer experience, and growth — it does not address any of the six substantive cybersecurity questions. There is no cybersecurity-specific content, no domain terminology, and no firm-specific or verifiable facts.


fact: Brian Fellon named as cybersecurity leader

fact: Vice President, Chief Information Officer and Chief Information Security Officer (VP, CIO and CISO)

fact: Appointed in September 2024

fact: 28 years of experience in information technology

fact: Puget Sound Energy from 2016 to September 2024

reasoning: The paragraph is primarily about management's organizational role — naming Brian Fellon, his title, qualifications, career history, reporting line to the CFO, and prior experience. The person-removal test leaves only a generic sentence about management having responsibility. Specificity is Level 4 due to multiple verifiable facts: 28 years of experience (specific number), September 2024 appointment date, and named prior employer Puget Sound Energy with specific tenure dates.

thinking:
Classify this paragraph.

Category: This is primarily about management's organizational role - naming Brian Fellon, his title, qualifications, experience, career history, reporting lines. Person-removal test: remove all person-specific content and very little remains beyond "management team has primary responsibility for cybersecurity risk management program and supervises internal personnel and external consultants." That's generic. The bulk is about the person. → MR

Specificity: Let me scan for facts:
- VP, CIO and CISO → firm-specific (cybersecurity leadership role at VP level)
- Named individual: Brian Fellon → firm-specific
- "September 2024" appointed → specific date → QV

- "28 years of experience" → specific number → QV
- Reports to CFO → not firm-specific (CFO is generic)
- "Director of Information Technology at Puget Sound Energy in Bellevue, Washington from 2016 to September 2024" → named external entity, specific dates → QV
- "Cybersecurity management team" → named team? It's somewhat generic but has a specific name.

Level 4 easily.


fact: Chief technology officer responsible for information security

fact: Information security team

fact: Over a decade of industry experience

reasoning: The paragraph's primary subject is the CTO's role, team composition, qualifications, and reporting responsibilities — answering 'how is management organized?' The reporting-to-board content describes management's duties rather than framing board oversight. Person-removal test: removing CTO, team, experience, and reporting lines leaves almost nothing substantive. 'Over a decade of industry experience' is a verifiable lower bound (≥10 years), elevating to Level 4.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes the CTO's role, responsibilities, team composition, reporting lines, and experience. Let me apply the person-removal test: remove CTO, team details, reporting lines → very little remains. The primary question answered is "How is management organized to handle cybersecurity?" But there's also significant reporting-to-board content.

The paragraph covers: CTO responsibility, team composition, experience, reporting to senior management and audit committee, incident escalation to board. The governance-chain aspect (reporting to audit committee and board) is present but the primary content is about how management is organized - the CTO's role, qualifications, team structure, and reporting lines.

Actually, I'm seeing this as genuinely mixed content. The first part focuses on the CTO's role, qualifications, and team structure—clearly management-related. But the last sentences shift to describing how information security reports up through the audit committee and board, which leans toward governance. The text is roughly split between these two aspects, with the CTO and security team as the consistent subject throughout.

Given that the paragraph opens with "Our chief technology officer is responsible for..." and frames everything through management's organizational role, I'm leaning toward classifying this as management-related overall. The reporting structure is presented as part of describing management's responsibilities rather than as a standalone governance mechanism.

On specificity, I notice the CTO is described as a VP+ level cybersecurity leadership role with over a decade of industry experience. That "over a decade" phrasing sets a verifiable threshold—more than 10 years—so it qualifies as quantitatively verifiable. I'm checking whether "information security team" qualifies as firm-specific or if it's just a generic descriptor—it seems like a named team with a security qualifier, which could push it toward firm-specific classification. Given the CTO role and the verifiable lower bound of over a decade, this candidate lands at Level 4.


reasoning: The paragraph's central topic is how the company coordinates cybersecurity with its third-party vendors, answering 'how are third-party cyber risks managed?' — making it TP rather than RMP. The language is entirely generic: no domain terminology, no firm-specific details (unnamed vendors, generic 'IT department,' generic cadences like 'semi-annual or annual'), and no verifiable facts, leaving it at Level 1.

thinking:
Let me analyze this paragraph.

Content: Describes IT department working with third-party vendors on cybersecurity coordination.

Category: This is about how third-party cyber risks are managed - vendor collaboration on cybersecurity. But let me think more carefully. The paragraph describes coordination with vendors on cybersecurity approach. This could be TP (vendor oversight) or RMP (part of internal program).

The central topic is collaboration WITH vendors on cybersecurity. It's about how they work with vendors - this feels like TP. But it's quite vague - "coordinate a mutually beneficial approach" isn't really imposing requirements ON vendors, it's collaborative.

Looking at the specificity here, there's nothing concrete - just generic references to an IT department, unnamed third-party vendors, and vague cadences like semi-annual or annual meetings. No actual security practices, tools, or frameworks mentioned, and nothing that's firm-specific or tied to any quantifiable facts. This reads as general business language without substantive detail.


fact: GISO (Global Information Security Officer) role

fact: Chief Information Security Officer (CISO)

fact: cybersecurity maturity assessments

reasoning: The paragraph describes third parties hired to serve the company's own cybersecurity program — vendors providing network protection and experts performing assessments of the company's controls — which per Rule 3 is RMP, not TP. The reporting line to the Audit Committee is subordinate. Specificity reaches Level 3 via the GISO and CISO cybersecurity-specific leadership titles, but no named external firms, numbers, or verifiable credentials push it to Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes third-party engagement for cybersecurity. The GISO partners with vendors for protection and engages experts for assessments. The CISO reports results to executive team and Audit Committee.

Category: This is about third-party engagement but the third parties are hired to SERVE the company (vendors providing protection, experts performing assessments on the company's own program). Per Rule 3: "Third parties hired to serve the company (assessors, consultants, pen testers) → RMP." The central topic is using third parties as part of the company's own cybersecurity program, not imposing requirements ON vendors.

The paragraph focuses on how the company leverages third-party vendors and experts to strengthen its own cybersecurity program through protection services and assessments, which falls under RMP rather than vendor management. The reporting to the Audit Committee is secondary to the main substance about program activities. I'm also noting the firm-specific terminology like GISO and CISO as Level 3 specificity indicators.


fact: third-party security scoring system to evaluate security posture

reasoning: The paragraph's central topic is oversight of vendors and third parties' cybersecurity, including requirements imposed on them and evaluation of their security posture, making it clearly TP. The mention of a 'third-party security scoring system' to evaluate 'security posture' reflects cybersecurity domain knowledge (an ERM professional would say 'vendor risk assessment' not 'security scoring system'), but there are no firm-specific facts (no named tools, roles, or committees) or verifiable claims, keeping it at Level 2.

thinking:
Let me analyze this paragraph.

Content: About managing third-party risk - vendors, service providers. Processes to oversee and manage these risks, minimum security standards, third-party security scoring system, ongoing monitoring.

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

Specificity:
- "third-party security scoring system" - this is a domain term (security scoring/rating of vendors is cybersecurity-specific)
- "security posture" - domain term
- "minimum security and control standards" - somewhat generic
- "continuous compliance with its cybersecurity standards" - generic

- The reference to a third-party security scoring system signals domain expertise—that's not something an ERM generalist would typically mention, so this points to Level 2 knowledge. There are no firm-specific details like named roles or committees, and no quantifiable facts like numbers or dates, which keeps it at Level 2 overall.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' by describing vendor assessments and risk-calibrated oversight — requirements/evaluations imposed on vendors, not third parties serving the company's own program. No domain terminology (vendor assessments described in generic ERM language like 'data security, availability, and confidentiality'), no firm-specific facts, and no verifiable claims, so specificity remains Level 1.


fact: CISO

reasoning: The paragraph describes how cybersecurity information flows upward from the CISO through channels to the Audit Committee and Board, answering 'how does the board oversee cybersecurity?' — this is a governance-chain paragraph describing oversight structure, defaulting to BG. The CISO role is firm-specific (Level 3), but 'Audit Committee,' 'Board,' and 'quarterly' are generic governance terms that don't qualify.


fact: more than 20 years' experience in financial services

fact: Certified Information Systems Security Professional (CISSP) from ISC2 Organization

fact: degree from the University of California, Santa Barbara

reasoning: The paragraph is entirely about a management figure's qualifications, credentials, career experience, and responsibilities — person-removal leaves almost nothing, confirming MR. Specificity is Level 4 due to multiple verifiable facts: 'more than 20 years' is a verifiable lower bound, CISSP is verifiable via (ISC)² registry, and University of California, Santa Barbara is a named university in credential context.

thinking:
Let me classify this paragraph.

Content: Describes the Director of IT's experience, qualifications, certifications, and responsibilities. This is about who manages cybersecurity and what qualifies them.

Person-removal test: Remove all person-specific content → almost nothing remains. This is MR.

Specificity: Let me scan for facts.
- "Director of Information Technology" — this is a Director-level IT title WITHOUT a security qualifier. Per the codebook: "Director of IT" is NOT firm-specific.
- "more than 20 years' experience" — lower bound, quantified, verifiable → QV
- "CISSP from ISC2 Organization" — verifiable certification → QV

- "University of California, Santa Barbara" — named university in credential context → QV

The domain language around information security and cybersecurity risk management appears general, but the CISSP certification combined with the quantified experience and named university credential pushes this to Level 4.


fact: application vulnerability assessments

fact: NIST

type: framework

fact: ISO

fact: HIPAA

fact: Payment Card Industry standards (PCI)

fact: public internet presence monitoring

reasoning: The paragraph's central topic is requirements imposed ON suppliers — contractual security obligations, periodic audits, and remediation tracking — squarely answering 'how are third-party cyber risks managed?' (TP). Specificity reaches Level 2 via multiple domain terms (application vulnerability assessments, public internet presence monitoring) and named frameworks (NIST, ISO, HIPAA, PCI), but no firm-specific organizational details or QV-eligible facts push it higher.

thinking:
Let me analyze this paragraph.

Content: This is about how Cigna manages third-party/supplier cybersecurity risks. Contractual requirements on suppliers, security audits of suppliers, vendor assessments.

Category: Third-Party Risk (TP) - clearly about requirements imposed ON vendors/suppliers.

Specificity: Let me scan for facts.

Domain terms: security questionnaires, application vulnerability assessments, NIST, ISO, HIPAA, PCI standards, right to audit - these are domain terms that pass the ERM test.

Named standards: NIST, ISO, HIPAA, PCI DSS - these are domain terms (Level 2).

The standards are cited as benchmarks for alignment rather than as certifications Cigna actually holds. Company references like "The Cigna Group" and "Security Policies and Standards" are too generic to qualify. Without specific metrics, dates, external vendors, or actual certifications, this lands at Level 2 - Domain-Adapted based on the security terminology alone.


reasoning: The first sentence states a backward-looking materiality conclusion ('have not experienced any material cybersecurity incidents' and 'expenses were immaterial'), making this SI; the cross-reference to Item 1A is subordinate. Specificity is Level 1: the negative assertion about no material incidents is not externally verifiable, 'December 31, 2023' is reporting period context, and no domain terminology, firm-specific facts, or QV-eligible facts are present.

thinking:
Let me analyze this paragraph.

Content: Two parts - (1) a statement that no material incidents occurred in three years and expenses were immaterial, (2) a cross-reference to Item 1A for materiality assessment.

Category: The first sentence states a conclusion about materiality - "have not experienced any material cybersecurity incidents" and "expenses incurred from cybersecurity incidents were immaterial." This is a backward-looking materiality assessment → SI.

The second sentence is a cross-reference to Item 1A. Per the rules, "risks that may materially affect... see Item 1A" → N/O. But here, the first sentence IS an assessment, and the cross-reference is subordinate.

Per the codebook, this pattern of "Risks have not materially affected us. See Item 1A" is classified as Strategy Integration since the first sentence contains the actual assessment and the cross-reference is just supporting it. Looking at the specificity, the company's claim that they "have not experienced any material cybersecurity incidents" during the three-year period ending December 31, 2023 is a negative self-assertion that can't be externally verified, and the same goes for their statement about immaterial expenses from incidents.

This doesn't qualify because it uses only generic domain terminology without any firm-specific or quantifiable facts—that's Level 1.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — the Audit Committee receives reports from management on cybersecurity risks and incidents, describing the oversight flow. No domain terminology, no firm-specific facts (Audit Committee exists at every public company), and no verifiable claims, so specificity remains Level 1.


reasoning: The paragraph's central topic is managing cybersecurity risks posed by third-party vendors—risk assessments of vendors and breach notification requirements imposed on them—directly answering 'how are third-party cyber risks managed?' For specificity, the language ('risk assessments,' 'processes to identify risks,' 'notify us of any actual or suspected breach') is general business language that any ERM professional could write; no domain terminology, firm-specific facts, or verifiable claims are present.

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

Category: This is about how third-party cyber risks are managed - vendor assessments, identifying risks from third-party systems, and requiring breach notification. Central topic is oversight of external parties. → Third-Party Risk

Specificity: Let me scan for facts:
- "cybersecurity risk assessments" - general risk management language
- "third-party vendors" - general
- "processes to identify cybersecurity risks" - generic
- "promptly notify us of any actual or suspected breach" - "breach" is a domain term? Let me think... "breach" in context of data breach notification is fairly standard business language.

The language here is all standard business terminology - nothing that would be unique to security professionals. "Risk assessments of third-party vendors" is exactly what a general ERM person would say, and "breach" has become common enough in business contexts that it's not a specialized term. No firm-specific details or technical facts either. → Level 1.


reasoning: The paragraph describes who is responsible for the information security program (a Director), their qualifications ('extensive experience'), and how responsibilities are shared with the CFO for risk review — all answering 'how is management organized?' Person-removal test: removing the Director and CFO references leaves only generic program language ('development, operation, and maintenance of our information security program' and 'review potential risks and measures'), confirming MR. For specificity, 'Director' without a visible security qualifier in the full title is not clearly firm-specific per the codebook, CFO is explicitly excluded as a generic governance role, and terms like 'information security program,' 'identify and mitigate cyber security risks,' and 'regularly review potential risks' are general business language that fails the ERM test — no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph from Lifeway Foods' 10-K Item 1C filing.

This appears to be a truncated paragraph (starts with "is responsible for...") describing someone (likely a Director-level role) and their responsibilities regarding the information security program.

**Content Category Analysis:**
The paragraph describes:
1. A role responsible for development, operation, and maintenance of the information security program
2. That person's experience/qualifications
3. The Director and CFO regularly reviewing risks and mitigation measures

This is primarily about management's organizational role - who is responsible, their qualifications, and how responsibilities are divided between the Director and CFO.

When I strip away the person-specific details—the Director's experience and the specific roles of the Director and CFO—what remains is just generic language about developing and maintaining an information security program and reviewing cyber risks. The real substance here is about organizational structure and who holds responsibility, not about the actual security program itself. This falls squarely into **Management Role** disclosure rather than a substantive description of the company's security practices.

Looking at the specificity, the "Director" title is truncated and ambiguous—I can't tell if it's "Director of IT Security" or just "Director of IT," and without that security qualifier, it doesn't meet the firm-specific threshold. The CFO reference is clearly generic governance. Everything else—the program description, the experience qualifications, the risk review language—is boilerplate. Since the paragraph is cut off and I only see "Director" without the full title, and given that a plain "Director of IT" isn't considered firm-specific per the codebook, this doesn't qualify as firm-specific disclosure. I'm settling on Level 1 - Generic Boilerplate, since the language throughout is standard business terminology without any security-specific jargon or firm-particular details.


fact: security threat intelligence system

fact: vulnerability management tools

fact: patch management standard

fact: Security Operations Center

fact: event correlation

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing threat intelligence collection, vulnerability management, patch management practices, and SOC capabilities — all program activities → RMP. Multiple domain terms (threat intelligence, vulnerability management, patch management, SOC, event correlation) elevate to Level 2, but no firm-specific facts (no named roles, committees, or unique organizational details) or verifiable claims (no numbers, dates, named external entities, or certifications) push it higher.

thinking:
Let me classify this paragraph.

Content: Describes cybersecurity program activities - threat intelligence, vulnerability management, patch management, SOC capabilities.

Category: RMP - "What does the cybersecurity program do?"

Specificity: Let me scan for facts.
- "security threat intelligence system" - domain term (threat intelligence)
- "vulnerability management tools" - domain term
- "patch management" - domain term
- "Security Operations Center" / SOC - domain term

No named roles, no specific numbers, no named external entities. Domain terms → Level 2.

Wait - "Security Operations Center" could be firm-specific as "24/7 security operations" is listed as firm-specific.

But here it just says "a Security Operations Center" without the "24/7" qualifier, so it's a standard domain term per the codebook, not firm-specific. Level 2.


reasoning: The paragraph states a backward-looking materiality conclusion ('have not been materially affected'), which is an SI assessment per Rule 5. The cross-reference to Item 1A is subordinate. Specificity is Level 1: 'last three fiscal years' is a soft timeframe, the negative materiality assertion is not externally verifiable, and there are no domain terms, firm-specific facts, or QV-eligible claims.


reasoning: The first sentence states a backward-looking and forward-looking materiality conclusion ('have not materially affected or are reasonably likely to materially affect'), which is the SEC's Item 106(b)(2) language — making this SI per the materiality assessment rule. The subsequent speculation ('no assurance') and cross-reference to Risk Factors are subordinate. No domain terminology, firm-specific facts, or verifiable claims are present — all language is generic boilerplate that could appear in any filing.

thinking: Materiality assessment paragraph with cross-reference.


fact: DPT (named internal team playing critical role in incident response)

fact: Incident Response Team (IRT) - named committee of IT members

fact: Chief Information Officer (CIO)

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing the Incident Response Plan's processes for containment, review, escalation, recovery, and remediation. Person-removal test: removing CIO and IRT membership details leaves a substantive description of IRP processes, confirming RMP over MR. The governance elements (escalation to Audit Committee, senior leadership) are subordinate to the process description. Specificity reaches Level 3 via firm-specific facts: the CIO (VP-level cybersecurity-adjacent role), the named DPT team, and the named IRT committee. No QV-eligible facts (no specific numbers, dates, named external entities, or certifications).

thinking:
Let me analyze this paragraph.

Content: Describes the Incident Response Plan (IRP), the role of DPT and IRT in incident response, escalation processes, and how incidents flow from identification to review to escalation.

Category: This describes what the cybersecurity program does regarding incident response - processes for containment, review, escalation, recovery, remediation. The person-removal test: remove CIO, IRT committee membership - the IRP processes remain substantive. This is RMP.

Wait, but there's significant organizational structure here - the IRT committee, the DPT, escalation to senior leadership and Audit Committee. Let me reconsider.

Actually, applying the person-removal test more carefully: if I strip out the CIO and IRT membership details, the core substance remains—the IRP still establishes processes for containment, review, escalation, recovery, and remediation. Incidents are still promptly reviewed and material ones escalated. The organizational roles are just the mechanism for executing these processes, not the substance itself. So this is definitely RMP, not organizational structure.

Now I'm checking whether these elements qualify as firm-specific. "IRP" is generic terminology, but "DPT" appears to be a named committee referenced earlier in the document. The CIO is a firm-specific cybersecurity role at the executive level. "IRT" is a named committee as well. The domain terms like containment and remediation are standard cybersecurity vocabulary, not firm-specific identifiers.

So this document hits Level 3 at minimum due to the CIO reference and the named internal teams, with no quantifiable or external entity references pushing it higher.


fact: Security Incident Response Plan ("SIRP") — named internal program with distinguishing identifier

fact: encryption protocols

fact: multi-factor authentication

fact: data loss prevention controls

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing incident response planning, vendor coordination during incidents, data protection measures, and business continuity — all program activities (RMP). The named 'Security Incident Response Plan (SIRP)' with its distinguishing acronym elevates to Level 3 as a firm-specific program identifier, supported by multiple domain terms (encryption, MFA, DLP).

thinking:
Let me analyze this paragraph.

Content: Describes their Security Incident Response Plan (SIRP), partnerships with insurance/regulatory/law enforcement, vendor engagement during incidents, data protection measures (encryption, MFA, DLP), and business continuity/disaster recovery plans.

Category: "What does the cybersecurity program do?" → RMP. This describes program activities and processes.

Specificity: Let me scan for facts:
- "Security Incident Response Plan ("SIRP")" — named internal program with distinguishing identifier → firm-specific (Level 3)
- "encryption protocols" — domain term

- "multi-factor authentication" and "data loss prevention controls" — standard domain terminology

The key question is whether SIRP qualifies as firm-specific. Looking at the codebook pattern, named internal programs with distinguishing acronyms like CIRP are Level 3. SIRP follows the same structure—it's their specific acronym for their incident response plan, not a generic reference. That makes it Level 3.

No quantifiable facts present, so this stays at Level 3.


fact: technology committee of our board of directors

reasoning: The paragraph primarily answers 'how does the board oversee cybersecurity?' — it describes board-level oversight via the Audit Committee and technology committee, then outlines management's responsibilities as part of that governance chain. The management sentence describes delegation from the board, not management's organizational structure. The 'technology committee' is a named non-generic board committee (unlike 'Audit Committee' which every company has), elevating specificity to Level 3. The remaining language is generic ERM vocabulary ('identify, assess, and manage,' 'policies and procedures').

thinking:
Let me analyze this paragraph.

Content: Board oversees cybersecurity, Audit Committee and technology committee oversee processes, management responsibilities described.

Category: This is primarily about how the board oversees cybersecurity - BG. The management sentence describes responsibilities but in the context of the oversight structure flowing from board to management.

Specificity: Let me scan for facts:
- "Audit Committee" - not firm-specific (every company has one)
- "technology committee" - this is a named non-generic committee → firm-specific
- No domain terminology beyond generic risk management language
- No QV facts

- The "technology committee" reference pushes this to Level 3.


fact: complementary user entity controls

reasoning: The paragraph splits between general security measures (RMP) and third-party risk management, but the most substantive and detailed content describes how the company manages third-party cyber risks—reviewing attest reports, implementing complementary user entity controls, contractual safeguards—making TP the primary category. 'Attest reports covering cyber-related controls' and 'complementary user entity controls' are SOC-report-specific audit terminology that fails the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes general IT security measures, then focuses on third-party risk management in the latter portion.

Category analysis:
- First part: general security measures (RMP-ish but very generic)
- Second part: "Where third parties house financially significant or sensitive data, the Company obtains and reviews attest reports covering cyber-related controls at these third parties, designs and implements complementary user entity controls, maintains open lines of communication for cyber incident notifications, and has contractual safeguards in place"

This is a mixed paragraph. The latter portion specifically addresses how third-party cyber risks are managed - reviewing attest reports, complementary user entity controls, contractual safeguards. But the first portion talks about general security measures.

The paragraph splits roughly evenly between generic security language and substantive third-party risk management practices. The real substance lies in the second half—attest report reviews, complementary controls, and contractual protections—while the opening just mentions standard security protocols without specifics. cyber risks.

I'd say Third-Party Risk edges out since it's the most substantive and specific portion, but it's close to RMP. Actually, the paragraph covers both RMP and TP. The TP content is more detailed and specific. I'll go with TP.

Wait, let me reconsider. Rule 3: "Vendor oversight as central topic → TP." Is vendor oversight the central topic? The paragraph starts broad then narrows to third-party. The most actionable content is about third parties. I'll go TP.

Hmm, but actually the paragraph is roughly evenly split. Let me re-read once more...

Sentences:
1. We rely on information systems... (general intro)
2. We have implemented security protocols... (RMP)
3. Some of these systems are managed by third parties... (transition to TP)
4. Third party cybersecurity incidents could affect... (TP risk framing)
5. We have implemented measures... (RMP, generic)
6. Where third parties house... obtains and reviews attest reports... (TP, detailed)

The most substantive sentence is #6 which is TP. But there's a lot of general/RMP content too. I think TP wins because the detailed, specific content is about third-party management, while the RMP content is very generic.

Actually, I'm overthinking this. The paragraph has substantial content about both. The third-party management section is the most detailed part. I'll call it TP.

Looking at the specificity here—terms like "attest reports covering cyber-related controls" and "complementary user entity controls" show real domain knowledge about SOC 2 audit terminology and the assurance process, which goes beyond generic risk management language.


reasoning: The first sentence states a backward-looking materiality conclusion ('not aware of any cybersecurity incidents or threats that have materially impacted us or our business, financial condition, and results of operations'), which is an SI assessment per the materiality rule. The remaining sentences are speculation ('could adversely affect') and a cross-reference to Risk Factors, both subordinate. No domain terminology, firm-specific facts, or verifiable claims are present — the negative materiality assertion is a self-reported claim about absence, not externally verifiable.

thinking:
Let me analyze this paragraph.

Content: "We are currently not aware of any cybersecurity incidents or threats that have materially impacted us..." - This is a materiality assessment (backward-looking negative assertion). Then speculation about future risks, then a cross-reference to Risk Factors.

Category: The first sentence states a conclusion about materiality → SI. The second sentence is speculation ("could adversely affect") → not SI. The third is a cross-reference → N/O. The primary substance is the materiality assessment in the first sentence → SI.

The language here is quite generic—"materially impacted us or our business, financial condition, and results of operations" uses standard materiality phrasing but lacks specificity. References to "cybersecurity incidents or threats" and "third-party providers" are vague with no domain terminology or company-specific details. The negative assertion itself isn't externally verifiable according to the codebook standards, so this rates as Level 1 specificity.


reasoning: This is a generic disclaimer with a cross-reference to Risk Factors, containing no substantive cybersecurity disclosure. Pure speculation ('cannot guarantee') and a pointer elsewhere → N/O, Level 1.


reasoning: The first sentence states a materiality conclusion using SEC Item 106(b)(2) language ('have not materially affected... are reasonably likely to materially affect'), making this SI. The remaining text is hedging speculation and a cross-reference. Specificity is Level 1: 'In 2023' is reporting-period context not a specific cybersecurity fact, the negative materiality assertion is not externally verifiable, and no domain terminology or firm-specific facts are present.

thinking:
Let me analyze this paragraph.

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

Category: The first sentence is a materiality assessment - "have not materially affected or are reasonably likely to materially affect" - this is the SEC's Item 106(b)(2) language. This is a backward-looking + forward-looking materiality conclusion → Strategy Integration. The second sentence is hedging/speculation, and the third is a cross-reference. But the primary purpose is stating a materiality conclusion.

Specificity:
- "In 2023" - reporting period context, not a specific cybersecurity fact tied to a date

- The materiality language is a negative self-assertion without external verification, no domain terminology or firm-specific facts, and the cross-reference and hedging are entirely generic. This is boilerplate materiality language.


fact: extended detection and response

fact: vulnerability scanning

fact: security awareness and privacy training

fact: phishing simulations

fact: penetration tests

reasoning: The paragraph answers 'what does the cybersecurity program do?' by listing program components including monitoring, EDR, vulnerability scanning, training, and phishing simulations; third-party engagements for audits and pen tests serve the company's own program (Rule 3 → RMP). Multiple domain terms (EDR, vulnerability scanning, phishing simulations, penetration tests) elevate to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me classify this paragraph.

Content: Describes components of a cybersecurity program - security monitoring, EDR, vulnerability scanning, training, phishing simulations, incident response team, and third-party engagements for audits and pen tests.

Category: "What does the cybersecurity program do?" → RMP. The third-party mention is about firms hired to serve the company (assessors, pen testers) → still RMP per Rule 3.

Specificity: Let me scan for facts:
- "security event monitoring and detection" - generic
- "extended detection and response" (XDR/EDR) - domain term ✓

- "vulnerability scanning" - domain term ✓
- "security awareness and privacy training" - close but "security awareness training" is domain term ✓
- "phishing simulations" - domain term ✓
- "penetration tests" - domain term ✓

No firm-specific facts (no named roles, committees, etc.). No QV facts (no numbers, dates, named firms, certifications).

Level 2 - Domain-Adapted.


fact: encryption of data

reasoning: The paragraph answers 'what does the cybersecurity program do?' by listing measures, processes, and policies designed to manage cybersecurity risks — this is RMP. Most of the listed items (incident response plans, policies and procedures, vulnerability management policy, disaster recovery plans) are generic ERM language that stays at Level 1. However, 'encryption of data' as a specific security control passes the ERM test — a non-security ERM professional wouldn't naturally list encryption as a measure — elevating to Level 2.


fact: Critical Threat Committee

reasoning: The paragraph primarily describes how cybersecurity incident information flows to the Board—materiality evaluation triggers briefings to the Board, and non-material incidents follow a notification path through the Chairman to the Audit Committee. This is a governance-chain paragraph answering 'how does the board oversee cybersecurity?' The 'Critical Threat Committee' is a named non-generic committee unique to this company, elevating specificity to Level 3; 'Audit Committee' and 'Board of Directors' are generic and do not qualify.

thinking:
Let me analyze this paragraph.

Content: Describes the Critical Threat Committee's responsibilities for evaluating materiality of cybersecurity incidents, determining disclosure obligations, briefing the Board, and the notification process for material vs non-material incidents.

Category: This is about how information flows to the board regarding cybersecurity incidents and materiality determinations. The Critical Threat Committee evaluates materiality and then briefs/notifies the Board. This is a governance-chain paragraph describing oversight structure - how the board gets informed about incidents and materiality. The primary question answered is "How does the board oversee cybersecurity?" - specifically the escalation and notification process to the board. BG.

I'm reconsidering whether the Critical Threat Committee operates at the management level rather than the board level. The paragraph shows a two-step process: the committee first makes materiality and disclosure determinations, then escalates material incidents to the Board while notifying the Chairman for non-material ones. This is fundamentally about the governance flow and oversight structure. The Critical Threat Committee name is firm-specific, while the Board and Chairman references are generic.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing policies, processes, incident response planning, and use of third-party assessors to evaluate the company's own program (Rule 3: assessors serving the company → RMP, not TP). All language is generic ERM boilerplate — 'processes for assessing, identifying, and managing material risk,' 'incident response plan,' unnamed 'third-party' assessors and experts — none of which passes the ERM test or qualifies as domain terminology, firm-specific, or verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity measures, policies, processes for managing risk, third-party assessors, incident response plan. The primary question answered is "What does the cybersecurity program do?" → RMP

Third-party mentions: assessors hired to serve the company's own program → RMP (Rule 3)

Specificity: Let me scan for facts.
- "cybersecurity measures" - generic
- "policies and processes for assessing, identifying, and managing material risk" - generic ERM language
- "cyber incident response plan" - "incident response plan" is listed as NOT domain terminology.

Adding "cyber" as a qualifier doesn't elevate this to domain terminology—it's just narrowing the scope. The CIA triad concept appears here as general business language rather than specialized terminology. Everything else—unnamed assessors, generic third-party providers, the security principles—reads as standard business language without firm-specific details or quantifiable facts. This lands at Level 1.


fact: Pension Benefit Information, LLC (PBI) — named third-party vendor

fact: Progress Software Corporation — named software company

fact: MOVEit Transfer software — named product involved in breach

fact: approximately 850,000 customers' PII compromised

fact: quarter ended June 30, 2023 — specific date of prior disclosure

fact: cybersecurity breach

reasoning: The paragraph describes an actual cybersecurity incident — the MOVEit breach at PBI that compromised Jackson customer data — answering 'what happened?' which maps to Incident Disclosure. Specificity is Level 4 due to multiple verifiable facts: named external entities (PBI, Progress Software Corporation), a named product (MOVEit Transfer), a specific impacted count (~850,000 customers), and a specific timeframe (Q2 2023).

thinking: Incident disclosure about the MOVEit breach via PBI vendor.


fact: Information Security Program ("ISP") — named internal program with distinguishing identifier

fact: Information Technology Board Committee ("ITBC") — named non-generic board-level committee

fact: IT Steering Committee ("ITSC") — named non-generic management-level committee

reasoning: The paragraph describes the oversight structure of the company's cybersecurity program through two named committees, with the ITBC being a board-level committee — this governance-chain description defaults to BG per Rule 1. Three named, non-generic organizational elements (ISP, ITBC, ITSC) elevate specificity to Level 3, but no quantified or externally verifiable facts are present to reach Level 4.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes two committees (ITBC and ITSC) and their role in overseeing the ISP. The question is whether this is BG, MR, or RMP.

The ITBC sounds like a Board-level committee ("Board Committee"), while ITSC sounds like a management-level committee ("Steering Committee"). The paragraph describes oversight structure - what these committees do (managing technology and cyber risks, ensuring compliance, fostering controlled risk environment). The primary focus is on the oversight structure of the ISP through these committees.

Since ITBC is a board-level committee, and the paragraph describes oversight structure, this leans BG. But it also mentions ITSC which is management-level.

The governance structure here centers on the ISP with board-level oversight through ITBC, so I'm categorizing this as BG. Looking at specificity, the ISP is a named internal program with a distinguishing identifier, and both ITBC and ITSC are named non-generic committees rather than generic governance roles, making these firm-specific references. There are no QV facts present, so this is Level 3.


reasoning: This paragraph is a disclaimer about limitations of the cybersecurity program followed by a cross-reference to Risk Factors. It provides no substantive cybersecurity disclosure — it's pure speculation ('there can be no assurance') and a pointer to another section, making it N/O. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' by describing vendor due diligence, access assessment, controls, and contractual requirements imposed on service providers. Despite being substantive in describing vendor oversight processes, the language is entirely general business/ERM vocabulary ('due diligence,' 'contractual rights and obligations,' 'controls,' 'stakeholders') with no cybersecurity domain terminology, no firm-specific facts, and no verifiable claims — remaining at Level 1.

thinking:
Let me classify this paragraph.

Content: Describes how the company manages third-party vendors who provide critical services or process sensitive information. Includes due diligence, access assessment, controls, and contractual requirements.

Category: This is clearly about Third-Party Risk - it answers "How are third-party cyber risks managed?" The central topic is vendor oversight with due diligence, access controls, and contractual requirements imposed on vendors.

Specificity: Let me scan for facts.
- "third party vendor review processes" - generic
- "multiple levels of due diligence" - generic business language

- "stakeholders throughout the company" - generic
- "contractual rights and obligations" - generic
- "user data or confidential information" - generic
- "controls should be implemented around such access" - generic

No domain terminology (no specific security terms like SOC 2, encryption, etc.), no firm-specific facts, no QV facts. This is all general business language about vendor management that any ERM professional could write.

Level 1 - Generic Boilerplate.


fact: Security Committee oversees cybersecurity risk management

fact: Chief Security Officer (CSO)

fact: Cyber Risk Advisory Committee oversees IT strategy and cybersecurity governance

reasoning: This is a governance-chain paragraph describing how the board, its committees, and the CSO collectively oversee cybersecurity risk — the primary question answered is 'how does the board oversee cybersecurity?' with management details subordinate to the oversight structure. Specificity reaches Level 3 via named non-generic committees (Security Committee, Cyber Risk Advisory Committee) and the CSO role, but no QV-eligible facts (no specific numbers, dates, named external firms, or certifications).

thinking:
Let me analyze this paragraph carefully.

**Content Category:**
This paragraph covers multiple topics - board oversight, management roles, and committee structures. Let me apply the "what question" test:

- "board of directors...has responsibility for oversight of risk management" → BG
- "Security Committee oversees management of risks from cybersecurity threats" → BG (board-level committee)
- "full board reviews our major risk exposures" → BG
- "CSO is responsible for developing, implementing, and maintaining..." → MR
- "CSO provides regular cybersecurity updates to the Chairman of the Board" → BG (information flow to board)

- "Cyber Risk Advisory Committee oversees matters regarding IT strategy..." → Could be MR or BG depending on whether it's board-level or management-level

This is fundamentally a governance-chain paragraph describing how oversight flows from the board through committees down to the CSO and back up through reporting. The core question is "How does the board oversee cybersecurity?" with management details supporting that structure, so BG seems most appropriate.

Looking at the specificity now: the Security Committee, Chief Security Officer, and Cyber Risk Advisory Committee are all named, non-generic governance bodies specific to this firm, putting them at Level 3. The Chairman reference is generic governance language. There are no QV-eligible facts—no specific numbers, dates, named external entities, or certifications mentioned. So this lands at Level 3 overall.


fact: Cybersecurity Leadership Team

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — describing the Board's ultimate oversight, delegation to the Audit Committee, and the reporting structure from management to the Board. The named 'Cybersecurity Leadership Team' is a firm-specific organizational detail that elevates specificity to Level 3; all other elements (Board, Audit Committee, generic reporting cadences) are standard governance language.

thinking:
Classify this paragraph.

Category: This is about board oversight of cybersecurity. The Board delegates to Audit Committee, receives reports, etc. → Board Governance.

Specificity: Let me scan for facts.
- "Cybersecurity Leadership Team" — named non-generic team → firm-specific (Level 3)
- "Audit Committee" — every company has one, NOT firm-specific
- "Board of Directors" — generic

No QV facts. The "Cybersecurity Leadership Team" is a named non-generic team → Level 3.