reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing vendor assessment criteria, tiered risk reviews, and contracting processes to mitigate cybersecurity risks from service providers, making TP the clear category. All language is generic ERM vocabulary (identify, assess, mitigate, initial assessment, contracting process) that any business professional could write without cybersecurity domain expertise; no domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Let me classify this paragraph.

Content: About third-party service provider risk management - assessing and mitigating risks from third-party providers, including cybersecurity risks, initial assessments, contracting processes.

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

Specificity: Let me scan for facts.
- "third-party risk management process" - general
- "identify, assess, and mitigate risks" - generic ERM language
- "initial assessment," "additional risk assessment," "contracting process" - generic process descriptions
- "access to our network, data, and information systems" - generic

- No domain terminology, firm-specific facts, or QV details present - just standard process language anyone in ERM would use.

Level 1.


content_category: Risk Management Process

fact: attack vectors

fact: reported vulnerabilities

fact: IT Steering Committee

category_confidence: high

specificity_confidence: high

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' — describing risk identification, ERM integration, continuous monitoring, and quarterly threat/vulnerability reviews. Person-removal test: removing the IT Steering Committee and executive references leaves a substantive program description intact, confirming RMP over MR. The IT Steering Committee is a named non-generic committee elevating to Level 3; 'attack vectors' and 'reported vulnerabilities' are domain terms but the committee is the highest-level fact.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content Category: The paragraph describes what the cybersecurity program does - risk identification, monitoring, mitigation, ERM integration, and monitoring activities. It mentions the IT Steering Committee and third-party vendor, but the primary content is about program activities.

Person-removal test: Remove "IT Steering Committee" and "key executives and employees" - the paragraph still describes a cybersecurity program with risk assessment, ERM integration, continuous monitoring, quarterly updates, vulnerability reports, threat analysis. Substantive program description remains → RMP.

The third-party vendor is mentioned as serving the company's program → RMP, not TP.

Now I'm checking the specificity of the language used. "IT Steering Committee" is clearly firm-specific, but most other terms like "continuous monitoring," "risk mitigation," and "trend analysis" are fairly generic ERM language. The cybersecurity-specific terminology like "attack vectors" and "reported vulnerabilities" are domain terms that wouldn't typically appear in general ERM discussions.

There are no quantifiable facts here—no specific numbers, dates, or named external entities—so this doesn't qualify for QV eligibility. The reference to a "third-party cybersecurity vendor" is unnamed, and "quarterly updates" is just a generic cadence. The main specificity driver is the named committee, which puts this at Level 3.


fact: information security and data privacy training (security awareness training)

fact: phishing simulation program — mimics potentially harmful phishing attempts

reasoning: The paragraph describes cybersecurity program activities — employee security awareness training and a phishing simulation program — answering 'what does the program do?' (RMP). The third-party vendor is unnamed and serves the company's own program (Rule 3 → RMP not TP). Domain terms (security awareness training, phishing simulations) elevate to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes employee training and phishing simulation program. This is about what the cybersecurity program does - activities and processes.

Category: RMP - answers "What does the cybersecurity program do?" It describes security awareness training and phishing simulations.

Specificity: Let me scan for facts.
- "information security and data privacy training" - security awareness training is domain terminology
- "phishing attempt" / "phishing security test" - phishing simulations is domain terminology
- "each month" - generic cadence, not QV
- "third-party vendor" - unnamed, not firm-specific

- The domain terms here are phishing simulations and security awareness training, which puts this at Level 2 with no firm-specific or quantifiable facts.


content_category: Management Role

fact: Information Security Officer

fact: Chief Information Officer

reasoning: The paragraph identifies two specific roles (ISO and CIO) and their responsibility for mandatory training, answering 'how is management organized to handle cybersecurity?' Person-removal test: removing the roles leaves only a generic training obligation, confirming MR. The cybersecurity-specific leadership titles (Information Security Officer, CIO) elevate to Level 3, but no verifiable claims (numbers, dates, named external entities, certifications) are present to reach Level 4.

thinking:
Classify this paragraph.

Category: This describes management roles and their training responsibilities. The primary question answered is "How is management organized to handle cybersecurity?" - specifically about who (ISO and CIO) is responsible for what (mandatory training). Person-removal test: remove "Information Security Officer and Chief Information Officer" → "completing additional mandatory training to understand the processes, procedures, and technical requirements for securing information assets across the Company" — this describes a training requirement but without the people, it's about a generic training obligation. The paragraph is primarily about the roles and their responsibilities → MR.

Both the ISO and CIO are firm-specific cybersecurity leadership positions, with no quantifiable facts or specialized domain terminology present, placing this at Level 3 specificity.


fact: June 2024 — specific date of cybersecurity incident

fact: CDK — named third-party provider involved in incident

category_confidence: medium

reasoning: The paragraph is framed around validating the company's incident response plan — it opens by describing the plan's procedures, drills, and training, then uses the CDK incident as a case study demonstrating the plan worked as intended, and closes with lessons learned for plan refinement. While the CDK incident (ID) and materiality conclusion (SI) are substantial, the dominant frame answers 'what does the program do?' with the incident serving as supporting evidence. Specificity reaches Level 4 via 'June 2024' (specific date tied to a real event) and 'CDK' (named external entity), both independently verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes their incident response plan, mentions a real incident (CDK incident in June 2024), and states it didn't materially impact them.

Category: This is tricky. It covers:
1. RMP - incident response plan description
2. ID - actual CDK incident
3. SI - materiality assessment

The paragraph starts with RMP (incident response plan), then transitions to describing a real incident (CDK, June 2024), then gives a materiality conclusion. Let me assess which dominates by text volume.

- RMP content: "well-defined and frequently updated information security incident response plan...

The paragraph is roughly split between RMP and ID. The first ~3 sentences establish their incident response plan with its key components like identification, categorization, escalation, and reporting. Then the June 2024 CDK incident takes over as the main example, showing how that plan was actually triggered and executed. The materiality statement at the end wraps it up, but the real substance is demonstrating that their response procedures worked effectively when tested by an actual incident. I'm wrestling with whether the incident itself or the response plan is the main focus. The CDK incident gets substantial coverage with specific details—the date, what happened, the impact—which points toward incident description. But the whole thing is framed as a validation of their response procedures, opening and closing with the plan. By sheer text volume the incident edges ahead, but the structural framing keeps pulling back to RMP. I'll lean toward RMP with moderate confidence, since the incident serves as evidence for how well their procedures work. incident serves the narrative of "our plan works."

I'll go with RMP given the framing, but with moderate confidence.

Actually, let me reconsider one more time. The question test:
- "What does the cybersecurity program do?" - Yes, describes IRP
- "What happened in a cybersecurity incident?" - Yes, describes CDK incident

The CDK incident portion is roughly half the paragraph. Given it's genuinely split, I need to decide which question the paragraph MOST DIRECTLY answers. The paragraph uses the incident to validate the program. I'll go RMP.

For specificity, I'm looking at the concrete details: June 2024 is a specific date tied to the event, and CDK is a named third-party. The incident response plan itself is generic terminology, and the process steps are standard language. The materiality statement is self-assertion rather than verifiable fact. So I'm counting two QV facts and landing on Level 4.


content_category: Strategy Integration

reasoning: This is a materiality assessment — the company states a backward-looking conclusion that no cybersecurity incidents materially affected or are reasonably likely to materially affect the business, squarely triggering SI. Specificity remains Level 1: 'December 31, 2023' is a generic reporting period, and the negative assertion about absence of material incidents is not independently verifiable.

thinking:
Materiality assessment - backward-looking conclusion about whether cybersecurity affected business outcomes.

Category: Strategy Integration (SI) - states a conclusion about materiality.

Specificity: The paragraph says "no cybersecurity incidents that materially affected or are reasonably likely to materially affect" - this is a negative self-assertion. "December 31, 2023" is a reporting period date, not a cybersecurity-specific date. The negative assertion is not externally verifiable. No domain terms, no firm-specific facts.

This is a Level 1 assessment - the lowest specificity tier.


content_category: None/Other

reasoning: This paragraph describes hypothetical cybersecurity threats and speculative impacts ('could expose,' 'could materially and adversely affect') without disclosing any substantive cybersecurity measures, governance, or assessments. Per Rule 5, 'could have a material adverse effect' is speculation found in every 10-K and is not a materiality assessment (SI), and per Rule 6, pure speculation without actual measures is N/O. N/O always receives Specificity 1.

thinking:
This paragraph discusses general cyber risks and potential impacts. Let me classify it.

Content: General risk language about cybersecurity threats, potential impacts. "Could materially and adversely affect our business" is speculation, not an assessment. No substantive disclosure of what the company does.

Category: This is generic risk language. No actual cybersecurity measures described. "Could materially and adversely affect" is speculation per Rule 5. This is N/O.

Wait - let me reconsider. It mentions "mining operations" and "Newmont proprietary data" but these are just describing potential impacts, not actual measures. No program description, no governance, no management roles.

This is pure risk factor language with no substantive content—just speculation about what could happen. That makes it N/O, which means Level 1 specificity.


reasoning: The first sentence states a backward-looking materiality conclusion ('not aware of any risks from cybersecurity threats that have materially affected the Company, including our business strategy, results of operations or financial condition'), which is an SI assessment per Rule 5. The remaining text is generic speculation and a cross-reference to Item 1A. No domain terminology, firm-specific facts, or verifiable claims are present; the negative materiality assertion is a self-reported claim about absence and is not externally verifiable.

thinking:
Classify this paragraph.

"As of the date of this report, we are not aware of any risks from cybersecurity threats that have materially affected the Company, including our business strategy, results of operations or financial condition." — This is a backward-looking materiality assessment → SI.

"However, we cannot provide assurance that these threats will not result in such an impact in the future." — Generic speculation.

"For more information regarding risks relating to information technology and cybersecurity, see Item 1A. Risk Factors." — Cross-reference.

The first sentence is the key: it states a conclusion about materiality (backward-looking negative assertion). Per Rule 5, this is SI.

The materiality statement is a negative self-assertion—"not aware of any risks that have materially affected"—which lacks external verifiability. There are no domain-specific terms, firm-specific facts, or quantifiable metrics here, making this a Level 1 specificity claim.


fact: malware detection

fact: phishing simulations

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing a security awareness program with training, simulations, and preparedness testing — squarely RMP. 'Malware detection' and 'phishing simulations' are cybersecurity domain terms that pass the ERM test, elevating to Level 2, but there are no firm-specific or verifiable facts to go higher.

thinking:
Classify this paragraph.

Category: "What does the cybersecurity program do?" → RMP. Describes program activities.

Specificity: Domain terms: "malware detection", "phishing simulations" → Level 2 at minimum. No firm-specific facts (no named roles, committees). No QV facts.

Level 2.


reasoning: This is a SPAC with no business operations and no cybersecurity program — the codebook explicitly directs SPACs with no real program to N/O. The absence of a program is not a disclosure; mentions of board oversight and no incidents are incidental. No domain terminology, firm-specific facts, or verifiable claims are present.

thinking: SPAC with no operations, no cybersecurity program.


fact: phishing tests

fact: penetration tests

fact: Vice President of Information Technology

reasoning: The paragraph primarily describes what the cybersecurity program does — centralized risk management, third-party phishing and penetration testing, and implementation of improvements from test results. Person-removal test: removing the Corporate Controller and VP of IT titles leaves a substantive program description intact, confirming RMP over MR. Specificity reaches Level 3 via the VP of Information Technology (a VP-level IT role qualifying as firm-specific); phishing and penetration testing are domain terms (Level 2 floor). The year references ('2023', '2024') are not month+year or exact dates, so they don't reach QV.

thinking:
Let me analyze this paragraph.

Content: Describes centralized IT/risk management, mentions Corporate Controller and VP of IT involved in risk activities, third-party phishing/penetration tests in 2023, implementing new processes from test results.

Category: This is primarily about what the cybersecurity program does - risk management activities, testing, implementing improvements. The mention of Corporate Controller and VP of IT is attribution. Person-removal test: remove titles/roles → "risk management function is highly centralized... consistent input throughout risk management activities... engaged a third party who conducted phishing and penetration tests in 2023... implementing new processes, procedures, and tools as a result..." - still describes program activities. → RMP

Now I'm checking the specificity of each element. "Phishing" and "penetration tests" are domain-specific terms, while "Corporate Controller" is a generic finance role that wouldn't be firm-specific. The VP of IT is a firm-specific role, and "2023" is just a year without the month, so it doesn't meet the threshold for a qualified vulnerability. "Third party" is unnamed and doesn't qualify either.


reasoning: This is a SPAC with no business operations that explicitly states it has not adopted any cybersecurity risk management program. Per the codebook, SPACs and no-operations companies with no real program receive N/O regardless of incidental mentions of board oversight. The absence of a program is not a disclosure. No domain terminology, firm-specific facts, or verifiable claims are present.


content_category: Board Governance

reasoning: The paragraph answers 'How does the board oversee cybersecurity?' by describing the audit committee's oversight role, periodic updates, and information flow to the full board — classic BG. Specificity is Level 1: 'audit committee' and 'CFO' are generic governance structures present at every public company (both on the NOT firm-specific list), 'periodic updates' is a generic cadence, and no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me classify this paragraph.

Category: This describes how the board oversees cybersecurity through the audit committee. It answers "How does the board oversee cybersecurity?" → Board Governance.

The mention of CFO is subordinate to the oversight structure description.

Specificity: Let me scan for facts.
- "audit committee" — every public company has one, NOT firm-specific
- "Chief Financial Officer" — generic role, NOT firm-specific (CFO is explicitly listed as NOT firm-specific)
- "periodic updates" — generic cadence
- No domain terminology beyond general risk management language

- No QV facts either, so this is entirely generic business language. Level 1.


content_category: Third-Party Risk

specificity_confidence: medium

reasoning: This paragraph answers 'how are third-party cyber risks managed?' — it describes due diligence on service providers and contractual cybersecurity requirements imposed on them, making TP the clear category. Despite mentioning 'cybersecurity measures' and 'cybersecurity practices,' the language describes generic vendor oversight activities (due diligence, evaluating practices, contractual commitments) that any ERM professional would use — no domain-specific terminology passes the ERM test.


reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' by listing who is responsible (Senior Director of IT, CEO, General Counsel, CFO) and detailing their responsibilities (hiring, budgets, incident escalation). Person-removal test leaves only generic responsibility descriptions. For specificity, 'Senior Director of Information Technology' is a Director-level IT title without a security qualifier (not firm-specific per codebook), CEO/CFO/General Counsel are generic governance roles, Audit Committee exists at every company, and no cybersecurity domain terminology or verifiable facts appear — all language is general business/risk management vocabulary.

thinking:
Let me analyze this paragraph.

Category: This describes management's organizational role - who is responsible, how responsibilities are divided. The paragraph lists specific people (Senior Director of IT, CEO, General Counsel, CFO) and their responsibilities. Person-removal test: remove all person-specific content → "cybersecurity risk assessment and management processes are implemented and maintained... integrating cybersecurity risk considerations into the Company's overall risk management strategy, and communicating key priorities to relevant personnel... approving budgets, helping to prepare for cybersecurity incidents, approving cybersecurity processes, and reviewing security assessments and other security-related reports...

The remaining substance covers determining materiality of incidents and escalating them to the Audit Committee or investors. So this is fundamentally about role allocation and who handles what responsibilities → MR

Specificity: "Senior Director of Information Technology" is a director-level title without a security qualifier, which doesn't meet the firm-specific threshold. CEO, General Counsel, and CFO are all generic roles, and the Audit Committee isn't firm-specific either.

Looking at domain terminology, I see "cybersecurity risk assessment," "security assessments," and "cybersecurity incidents" — but these are general business language, not specialized domain terms like SIEM or penetration testing. Even "securing networks and application systems" is too generic; any IT professional would use that phrasing.

This paragraph doesn't pass the ERM test. It's all generic management and risk language with no firm-specific cybersecurity titles or domain-specific terminology, so it's Level 1.


category_confidence: low

reasoning: This fragment describes generic responsibilities related to cybersecurity policies/procedures and corporate commitment. It lacks context about who performs these duties (likely a continuation of a prior paragraph about a committee or role). The content describes program implementation oversight and culture promotion, which are general program activities rather than board oversight or management qualifications. However, the text is extremely generic with no domain terminology, firm-specific facts, or verifiable claims, yielding Level 1.


reasoning: This paragraph states a backward-looking materiality conclusion ('have not...materially affected us, including our operations, business strategy, results of operations, or financial condition'), making it SI per the materiality assessment rule. No domain terminology, firm-specific facts, or verifiable claims are present — the negative self-assertion about no material impact is not externally verifiable.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — describing delegation from the Board to the ARC, which reviews risks, controls, mitigation plans, and incident response capabilities. The 'Audit Review Committee' is functionally the audit committee (present at every public company) and is not firm-specific; the remaining language ('cybersecurity risks, controls and procedures,' 'internal controls over financial reporting') is general business/governance vocabulary that fails the ERM test, keeping this at Level 1.

thinking:
Let me classify this paragraph.

Content: Describes board oversight structure - Board delegates to ARC (Audit Review Committee), which reviews cybersecurity risks, controls, procedures, mitigation plans, and incident response capability. Information flows through management reviews.

Category: This answers "How does the board oversee cybersecurity?" → Board Governance. The entire paragraph is about the oversight structure from Board → ARC → management.

Specificity: Let me scan for facts.
- "Audit Review Committee of the Board of Directors (the 'ARC')" - This is a named committee. But is it firm-specific? The codebook says "Audit Committee" is NOT firm-specific since every company has one.

"Audit Review Committee" is just a slight variation on the standard audit committee name, so it's not firm-specific either. The language throughout is purely generic governance terminology—nothing about cybersecurity risks, controls, procedures, or incident response distinguishes this company from any other. No QV facts present. This is Level 1 material.


fact: zero-day vulnerability

fact: material cybersecurity incident in the third quarter of fiscal year 2023

fact: personal information accessed by unauthorized third-party exploiting vulnerability in third-party vendor's file transfer application

reasoning: The paragraph's primary purpose is assessing how cybersecurity incidents have affected the business: it states a material incident occurred, expenses were recorded, and no other incidents have had material effect — these are materiality conclusions (SI per Rule 5). While incident details are present, they serve the business-impact framing in this 10-K context. Specificity reaches Level 4 because 'third quarter of fiscal year 2023' is a specific time period tied to a verifiable, publicly known cybersecurity event (the MOVEit breach), and 'zero-day vulnerability' is domain terminology.

thinking:
Let me analyze this paragraph.

Content: Describes past cybersecurity incidents (material incident in Q3 FY2023 involving zero-day vulnerability in third-party file transfer app), expenses recorded, and forward-looking risk language.

Category: This is mixed. It describes an actual incident (ID) but also discusses business/financial impact (SI). The paragraph starts with incident details, mentions expenses, then transitions to materiality assessment and forward-looking risk language. The incident is described but the framing is about its business impact - "material cybersecurity incident", "recorded expenses", "not aware of any other cybersecurity incidents that have had a material effect on our business." This feels like it's primarily answering "how does cybersecurity affect the business?" with the incident as context.

The paragraph does contain substantial incident detail—what happened, the unauthorized access, the zero-day vulnerability in the third-party vendor's file transfer app—but these specifics are really serving the materiality and business impact assessment. The backward-looking statement about not being aware of other material incidents, combined with the financial consequences mentioned, points toward SI as the dominant category. Per Rule 4, when there's a mixed framing with financial and business impact as the primary lens, that's SI. I keep going back and forth on this. The paragraph definitely has incident details—the zero-day, unauthorized access, the vendor app—but it's all framed within a materiality assessment. Since this is in a 10-K Item 1C focused on business risks, the real purpose is explaining the financial and operational impact to shareholders, not just documenting what happened. The incident serves as the evidence, but the materiality conclusion is what matters. I'm settling on SI. I'm settling on SI with Level 4 specificity. The third quarter of fiscal year 2023 is a verifiable timeframe tied to a real, publicly documented incident, and "zero-day vulnerability" is a domain-specific term that adds precision to the threat type.


fact: Security Operations Center (SOC)

fact: Security Information and Event Management (SIEM)

fact: 24x7 Security Operations Center

reasoning: The paragraph describes specific cybersecurity program activities (SOC and SIEM for monitoring and threat response), answering 'what does the program do?' → RMP. Domain terms SOC and SIEM elevate to Level 2, and '24x7 Security Operations Center' is a firm-specific organizational claim (implies specific investment beyond generic monitoring) elevating to Level 3.


reasoning: The first sentence states a materiality conclusion ('not reasonably likely to materially affect us or our business strategy, results of operations or financial condition'), making this SI per the materiality assessment rule. The second sentence is a cross-reference to Item 1A, but the assessment in the first sentence is the primary content. No domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

First sentence: "We do not believe that there are currently any known risks from cybersecurity threats that are reasonably likely to materially affect us..." - This is a materiality assessment (backward/forward-looking conclusion about whether cybersecurity affects business). → SI

Second sentence: Cross-reference to Item 1A risk factors. Per the codebook: "risks that may materially affect us, see Item 1A" → N/O. But here the first sentence IS an assessment, and the cross-reference is subordinate.

Per the codebook: "'Risks have not materially affected us.

See Item 1A' → SI (the first sentence IS an assessment; the cross-reference is subordinate)."

So this is SI.

Specificity: The paragraph is generic boilerplate materiality language. No domain terms, no firm-specific facts, no QV facts. Level 1.


reasoning: This paragraph is a cross-reference to Item 1A Risk Factors with no substantive cybersecurity disclosure — it merely acknowledges cybersecurity risks exist and points elsewhere. N/O always receives Specificity 1.


reasoning: Despite the heading 'Management's Role Managing Risk,' the paragraph primarily answers how the board oversees cybersecurity: the Director of Internal Audit and CFO brief the Board, the Board participates in strategic decisions, and the Board conducts annual reviews — all describing information flow to and oversight by the Board (Rule 1: management reporting TO the board → BG). No domain terminology passes the ERM test (topics listed are generic), and no firm-specific facts survive validation: CFO and Director of Information Technology are explicitly excluded, Director of Internal Audit is not a cybersecurity-specific VP+ title, and 'once per year'/'annual' are generic cadences.

thinking:
Let me analyze this paragraph.

Content Category: The heading says "Management's Role Managing Risk" but the content is primarily about how information flows to the Board and how the Board oversees cybersecurity. The Director of Internal Audit and CFO brief the Board, the Board participates in strategic decisions, the Board conducts annual reviews. This is answering "How does the board oversee cybersecurity?" → Board Governance.

The management roles (Director of Internal Audit, CFO) are mentioned but in the context of their reporting TO the board - this is the oversight flow, which per Rule 1 defaults to BG.

Now I'm checking the specificity of the roles and details mentioned. The Director of Internal Audit and CFO aren't cybersecurity-specific titles, and the Director of Information Technology without a security qualifier doesn't count as firm-specific either. The cadences and topics referenced—annual reviews, cybersecurity landscape, emerging threats—are all generic business language, so this doesn't meet the specificity threshold.


fact: Chief Information Security Officer (CISO)

fact: Chief Information Officer (CIO)

fact: over 30 years of experience in cybersecurity and intelligence

type: quantified

fact: Department of Defense

fact: CIO Program Certificate from the College of Information and Cyberspace, National Defense University

fact: CISSP designation

fact: CIPP designation

reasoning: The paragraph primarily answers 'how is management organized?' — it describes the CISO's reporting lines (to CIO, works with CLO), qualifications, and credentials. Person-removal test: removing titles, experience, and credentials leaves only a generic team description, confirming MR. Specificity is Level 4 due to multiple independently verifiable facts: 'over 30 years' (lower-bound number), CISSP and CIPP certifications (verifiable via issuing bodies), and named external entities (Department of Defense, National Defense University).

thinking:
Let me classify this paragraph.

Content Category: This paragraph describes the CISO, their reporting lines, qualifications, credentials, and experience. Person-removal test: remove all person-specific content → "We have a team of information security professionals who lead our enterprise-wide cybersecurity strategy, risk management, cyber defense, software security, security monitoring and other related functions." That's still somewhat substantive but the bulk of the paragraph is about the CISO's qualifications. The primary question answered is "How is management organized to handle cybersecurity?" → MR.

Specificity: Let me scan for facts:
- CISO (firm-specific role)

- CIO and Chief Legal Officer (firm-specific roles)
- "over 30 years of experience" (lower bound, verifiable)
- Department of Defense and National Defense University's College of Information and Cyberspace (named external entities)
- CIO Program Certificate, CISSP, and CIPP (verifiable credentials)

Multiple verifiable facts across roles and credentials → Level 4.


reasoning: This paragraph describes general reliance on technology infrastructure and enumerates potential cybersecurity threats (hacker attacks, ransomware, AI-driven threats) but does not describe any actual cybersecurity measure, process, program, oversight structure, or materiality assessment. It is speculative risk-factor language ('may be susceptible,' 'potential cybersecurity threats') without substantive disclosure, placing it in N/O. None/Other paragraphs always receive Specificity 1.

thinking:
Let me analyze this paragraph.

Content: Describes reliance on technology infrastructure, mentions cybersecurity threats generally, lists threat types. No actual cybersecurity measures described. This is general risk language about potential threats.

Category: This reads like general risk factor language. It doesn't describe what the program does (RMP), doesn't describe board oversight (BG), doesn't describe management (MR), doesn't describe an incident (ID), doesn't make a materiality assessment (SI). It's describing potential risks without any substantive cybersecurity disclosure.

Wait - it does mention "ransomware" which is a specific threat type (domain terminology).

But the paragraph itself is about general IT infrastructure risk. No actual cybersecurity measures are described. The mention of ransomware and malicious viruses is domain-specific language, yet the paragraph is still pure risk speculation without describing any actual cybersecurity program, measures, or assessments. This falls under the N/O threshold for generic risk language lacking substantive cybersecurity content.


fact: CIO

fact: management committee on cybersecurity

reasoning: The paragraph primarily answers how the board oversees cybersecurity — describing quarterly briefings to the Audit and Finance Committee and annual board reviews, with cybersecurity-focused briefings from management. Although management roles are mentioned, they serve as attribution within the oversight-flow description, making this BG. Specificity reaches Level 3 via firm-specific cybersecurity roles (Senior Director, Information Protection & Compliance; CIO) and a named cybersecurity management committee, but no QV-eligible facts (cadences like 'quarterly' and 'annual' are generic).

thinking:
Let me analyze this paragraph.

Category: This describes how information flows to the board - quarterly briefings, annual reviews, cybersecurity-focused briefings to the Audit and Finance Committee and Board. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

Even though management roles are mentioned (Senior Director, CIO, management committee), the purpose is describing the oversight/reporting structure to the board.

Specificity:
- "Senior Director, Information Protection & Compliance" - firm-specific cybersecurity role (Director-level with security qualifier)

- "CIO" is a standard executive title, not firm-specific
- "management committee on cybersecurity" is a named committee but generic in nature
- "Audit and Finance Committee" is essentially equivalent to a standard Audit Committee, so not firm-specific

No QV facts present - "quarterly" and "annual" are generic reporting cadences with no specific dates, numbers, or external certifications mentioned.

This falls into Level 2 based on generic roles and committees.


fact: SOC (System and Organizational Control) type reports

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' — describing deployed software, internal audits, and vendor SOC report requirements. While the last sentence touches on third-party oversight, the majority of text describes the company's own program activities, so RMP wins. The mention of SOC reports is domain terminology (a security professional would recognize this as a specific assurance mechanism), elevating specificity to Level 2, but nothing is firm-specific or quantified-verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity program built on industry standards, deployed software, internal audits, and requires service providers to provide SOC reports.

Category: This touches both RMP and TP. The first two sentences describe the company's own program (RMP). The last sentence is about requirements imposed on service providers (TP). Most text is about the program itself, so RMP wins.

Wait - let me reconsider. The paragraph has three sentences: (1) program built on standards with software, (2) internal audits, (3) requiring SOC reports from service providers. Two sentences are RMP, one is TP. RMP dominates.

Looking at the specificity here, "SOC type reports" is actual domain terminology that appears in the domain list, so that's Level 2 specificity. The other details like industry standards, internal audits, and sophisticated software are all generic. There's nothing firm-specific or QV-related in this paragraph.


fact: over 20 years of experience managing and securing global enterprises (both CIO and CISO)

reasoning: The paragraph describes a governance chain (Board → Audit Committee → CISO/CIO → program → ERM integration), which defaults to BG under Rule 1, even though it also contains MR-relevant content (management roles and qualifications) and RMP-relevant content (ERM integration). The BG frame of oversight delegation and information flow to the board is the structural backbone. Specificity reaches Level 4 because 'over 20 years of experience' is a lower-bound quantified claim that is independently verifiable against resumes or professional records.

thinking:
Let me analyze this paragraph carefully.

**Content Category:**
This paragraph covers multiple topics:
1. Management roles (CIO, CISO, experience) - MR
2. Board oversight (Audit Committee, delegates oversight, receives updates) - BG
3. ERM integration (quarterly business reviews, annual budget planning, ERM process) - RMP

The paragraph answers multiple questions. Let me assess which dominates by text volume:
- Sentence 1: Management roles and qualifications → MR
- Sentence 2: Board delegation and oversight → BG
- Sentence 3: Integration into risk management → RMP

This is genuinely split.

The governance chain is clearly there—Board delegates to Audit Committee, which oversees the CISO and CIO—but the paragraph doesn't really center on any single question. Looking at what actually takes up the most space: it opens with the management structure and qualifications, moves into how the Board delegates oversight, then describes how cybersecurity feeds into the broader risk management process. If I strip away the organizational roles and reporting lines, what's left is essentially about board delegation and ERM integration, which suggests this might be more about governance and risk management processes than about the management structure itself.

The tension is real though—the first sentence is clearly about management organization, the second about board oversight, the third about risk integration. But the dominant frame seems to be the governance chain and oversight structure rather than what the management team actually does. Given that the paragraph is anchored in who oversees what and how it connects to the board's risk framework, I'm leaning toward this being primarily a governance and board structure question, especially since the management qualifications feel more like supporting detail than the main point.

Now I'm looking at what makes something firm-specific versus generic. The CIO and CISO are named roles that matter here, and the "over 20 years" is a verifiable lower bound. But the Audit Committee is standard across companies, and ERM is just general business terminology. The quarterly reviews are also pretty generic. So there's a mix of firm-specific details and boilerplate language.

The experience threshold is what pushes this to Level 4 — it's a concrete, measurable fact. And the whole thing still fits under BG since it's describing the governance structure.


reasoning: The paragraph describes general IT infrastructure (accounting software, CRM, POS, mobile app) and routine data collection practices — it does not answer any of the six substantive cybersecurity questions. No cybersecurity measures, processes, or assessments are described. As N/O, specificity is Level 1.

thinking:
Classify this paragraph.

This describes general IT systems and data collection - no cybersecurity-specific content. It's about business operations infrastructure, not answering any of the six cybersecurity questions.

Category: None/Other - no substantive cybersecurity disclosure
Specificity: Level 1 - no domain terminology, no firm-specific cybersecurity facts, no QV facts


fact: penetration testing

fact: cyber threat actors

reasoning: The paragraph covers multiple topics — pen testing/vulnerability remediation (RMP), third-party vendor oversight (TP), and cybersecurity insurance (SI) — but the overall framing describes what the company's cybersecurity program does, with third-party oversight and insurance as components; RMP wins by slight text dominance and framing. Specificity is Level 2: 'penetration testing' and 'cyber threat actors' are domain terms passing the ERM test, but there are no firm-specific facts (no named roles, committees, or unique organizational claims) and no QV-eligible facts (no specific numbers, dates, named firms, or certifications held).

thinking:
Let me analyze this paragraph.

Content: Describes penetration testing, vulnerability remediation, third-party risk management policies, and cybersecurity insurance.

Category: Multiple topics here - penetration testing (RMP), third-party oversight (TP), and insurance (SI). The paragraph covers: (1) third-party pen testing of own systems → RMP, (2) third-party service provider oversight policies → TP, (3) cybersecurity insurance → SI.

Which dominates? Roughly equal split. The pen testing is about 1-2 sentences, third-party oversight is about 2-3 sentences, insurance is 1 sentence.

Looking at the breakdown more carefully, third-party service provider oversight takes up the most space with details on onboarding assessments, contractual requirements, and ongoing monitoring, while the pen testing and vulnerability remediation sections are also substantial. The insurance component is minimal by comparison.

This is genuinely a mixed paragraph without a single dominant theme. I'm leaning toward RMP as the primary category since the pen testing and vulnerability remediation form the core program activities, and the third-party oversight functions as a supporting component within that broader framework. The insurance mention is just a minor addition.

Looking at specificity now—there are domain terms like "penetration testing" and "cyber threat actors" that signal Level 2, but no named firms, specific numbers, certifications, named roles, or organizational claims that would push this higher. This lands at Level 2 based on the domain terminology alone.


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


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' by describing vendor oversight with additional scrutiny for vendors handling PII or trade secrets, making it TP. No cybersecurity domain terminology (the language is general vendor risk management any ERM professional would use), no firm-specific facts, and no verifiable claims — remains Level 1.

thinking:
Classify this paragraph.

Content: About third-party vendor management for cybersecurity risks, with additional scrutiny for vendors handling PII or trade secrets.

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

Specificity: Let me check for facts.
- "personally identifiable information" / "trade secrets" - these are data classification terms, not cybersecurity domain terms per se
- "risk-based approach" - generic
- "third-party vendor management program" - generic
- No named roles, no numbers, no domain terminology that passes the ERM test

This is describing vendor oversight but in very generic terms.

There's no specialized cybersecurity terminology, no company-specific details, and no quantifiable vendor facts here either. That puts it at Level 1.


reasoning: This is a blank check/SPAC company with no operations and no cybersecurity program, which per the codebook receives N/O. No substantive cybersecurity disclosure exists, so specificity is Level 1.


fact: Information Technology Committee

reasoning: The paragraph primarily answers how the board oversees cybersecurity—Board involvement, monthly updates, and board approval of risk assessments and policies—making it BG. The Information Technology Committee is a named non-generic committee (firm-specific), but 'monthly updates' is a generic cadence and no QV-eligible facts are present, placing this at Level 3.

thinking:
Let me analyze this paragraph.

Category: The paragraph answers "How does the board oversee cybersecurity?" - Board oversight, committee involvement, monthly updates to board, board reviews and approves assessments. This is BG.

There's mention of "Information Technology Committee" which is described as "comprised of key members of senior management" - this is a management-level committee, but the paragraph's purpose is describing the oversight structure (Board + committee providing oversight). The governance-chain default applies → BG.

Specificity:
- "Information Technology Committee" - named non-generic committee → firm-specific (Level 3)

- The rest of the details—monthly cadence, key monitoring metrics, and general oversight language—don't contain specific quantitative facts or domain-specific terminology that would elevate the specificity level.

Level 3.


reasoning: The paragraph's framing sentence explicitly addresses oversight of third-party vendors and third-party technology/systems, and two of three listed measures (vendor security assessments, insurance company risk assessments) involve external parties, making TP the primary question answered. No domain terminology passes the ERM test — 'security assessments,' 'risk assessments,' and 'security solution' are all general business language any ERM professional would use — and there are no firm-specific or verifiable facts (vendors and insurance company are unnamed).

thinking:
Let me classify this paragraph.

Content: About third-party vendor security oversight processes - security solution for customer data, security assessments of major vendors, risk assessments by insurance company.

Category: This answers "How are third-party cyber risks managed?" - it's about oversight of third-party vendors and the processes to manage third-party risk. The central topic is third-party risk management. → Third-Party Risk

Wait, let me reconsider. The paragraph mentions three things: (1) security solution for customer data, (2) security assessments of major vendors, (3) risk assessments by insurance company. Items 2 and 3 are about third-party oversight.

Looking more closely at the framing: the security assessments of vendors clearly point to third-party risk, while the insurance company's risk assessments could fall under risk management per the rules. The security solution for customer data is less clear, but the overall context emphasizes third-party vendor oversight, so the dominant category here is third-party risk.

On specificity, I'm not finding much to work with. The language is generic throughout—"security assessments," "major vendors," "insurance company," "security solution"—without any specialized terminology or firm-specific details. Even "security assessments" feels like general business language rather than domain-specific jargon that would fail the ERM test. No domain terms, no firm-specific facts, no quantitative details, so this stays at Level 1.


fact: Vendor Management Program (named internal program)

fact: CCDC (named non-generic committee involved in vendor oversight)

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing vendor onboarding due diligence, cybersecurity requirements imposed on vendors, and ongoing monitoring/assessment, making it Third-Party Risk. Specificity reaches Level 3 via the named 'Vendor Management Program' (distinguishing identifier) and 'CCDC' (a named non-generic committee), but no quantified-verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes a Vendor Management Program for overseeing cybersecurity risks related to vendors/suppliers. Includes onboarding due diligence, requirements for vendors, ongoing monitoring, and CCDC involvement.

Category: This is clearly about third-party cyber risk management - "How are third-party cyber risks managed?" The central topic is vendor oversight, requirements imposed on vendors, and supply chain risk management. → **Third-Party Risk**

Specificity:
- "Vendor Management Program" - named internal program with distinguishing identifier → firm-specific
- "CCDC" - named non-generic committee → firm-specific

- The language here is mostly generic risk management terminology without specialized domain vocabulary, and there aren't any quantifiable facts like metrics, dates, or external certifications mentioned, so this lands at Level 3 - Firm-Specific.


reasoning: This is a SPAC with no business operations and no cybersecurity program — the codebook explicitly directs SPACs and no-operations companies to N/O regardless of incidental mentions of board oversight or risk acknowledgment. The absence of a program is not a disclosure. No domain terminology, firm-specific facts, or verifiable claims are present.

thinking: SPAC with no operations, no cybersecurity program.


reasoning: The opening sentence states a backward-looking materiality conclusion ('have not experienced a cybersecurity incident that has resulted in a material effect on our business strategy, results of operations or financial condition'), which is an SI assessment per the codebook. The remaining text is speculation ('may materially affect') and a cross-reference to Item 1A, both subordinate. No domain terminology, firm-specific facts, or verifiable claims are present—the negative assertion about no material incidents is not externally verifiable—so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

The paragraph starts with "we have not experienced a cybersecurity incident that has resulted in a material effect" - this is a backward-looking materiality assessment → SI.

Then it has speculation ("cannot guarantee," "may materially affect") and a cross-reference to Item 1A.

The first sentence is the key - it's stating a conclusion about materiality (negative assertion). Per the codebook, "Have not experienced any material cybersecurity incidents" → SI.

The rest is speculation and cross-reference, which are subordinate.

Specificity: "have not experienced a cybersecurity incident that has resulted in a material effect on our business strategy, results of operations or financial condition" - this is a negative self-assertion. Per the codebook, negative self-assertions are NOT externally verifiable.

This is a Level 1 classification - no domain-specific terminology, no company-specific facts, and no quantifiable metrics involved.


reasoning: The paragraph's central topic is managing third-party IT service provider risks — dependency on vendors, obtaining reports from vendors on cybersecurity efficacy, and vendor management as risk mitigation. This answers 'how are third-party cyber risks managed?' No cybersecurity domain terminology is present (no specific security practices, tools, or frameworks); the language ('vendor management process,' 'reports from vendors,' 'efficacy and efficiency') is general business/ERM vocabulary any non-security professional could write, keeping specificity at Level 1.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party IT service providers, vendor management, obtaining reports from vendors about cybersecurity efficacy, and catastrophic event risks.

Category: The central topic is managing third-party/vendor cyber risks - they discuss dependency on IT service providers, vendor management process, obtaining reports from vendors on cybersecurity issues. This is Third-Party Risk.

Specificity: Let me scan for facts.
- "hosted architecture" - generic IT term
- "third-party service providers" - generic
- "vendor management process" - generic business term

- "obtain reports from our vendors handling sensitive data as to their efficacy and efficiency in managing cybersecurity issues" - describes their vendor oversight approach but lacks domain-specific terminology or firm-specific details
- No ERM terminology present, no firm-specific facts, no QV facts

This reads as standard vendor management language without cybersecurity domain expertise evident. I'm settling on Level 1 for this one.

Actually, reconsidering the category here - the core focus is third-party vendor oversight and their cybersecurity risk management, which points to TP rather than a broader category. The language about catastrophic events and IT dependency is secondary to the main emphasis on vendor management of cyber risks. So this is TP, Specificity 1.


reasoning: The paragraph states a materiality conclusion — both backward-looking ('have not materially affected') and forward-looking ('are not reasonably likely to materially affect') — making it SI per Rule 5. The cross-reference to Item 1A is subordinate to the assessment. No domain terminology, firm-specific facts, or verifiable claims are present; the materiality language is standard boilerplate found in countless filings.

thinking:
Let me analyze this paragraph.

Two sentences:
1. Cross-reference to Risk Factors
2. Materiality assessment - "have not materially affected and are not reasonably likely to materially affect"

The second sentence is a clear materiality assessment (both backward and forward-looking), which is SI per Rule 5. The cross-reference is subordinate.

Specificity: No domain terms, no firm-specific facts, no QV facts. The materiality language is standard boilerplate. Level 1.


reasoning: The paragraph's central topic is oversight of vendors' cybersecurity posture — tiering, due diligence questionnaires, assessments of vendors' security practices, and vendor incident response procedures — all squarely answering 'how are third-party cyber risks managed?' For specificity, the vocabulary is general risk management language (assessments, tiers, due diligence questionnaires, incident response procedures) applied to a cybersecurity context; swapping 'cybersecurity' for another risk domain leaves the paragraph structurally intact. No domain-specific tools, frameworks, architectural concepts, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: This is about third-party/vendor risk management. It describes how the company manages vendor cybersecurity risks through assessments, tiering, questionnaires, and incident response procedures.

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

Specificity: Let me scan for facts.
- "third-party assessments of vendor's information security practices" - this is about assessing vendors, general language
- "categorized into tiers" - tiering approach, but generic
- "Vendor due diligence questionnaires" - general practice

- "cybersecurity breaches" - specific threat type reference
- "cyber and information security control environment" - domain-adjacent language
- "intrusion to their systems" - implies unauthorized access, somewhat domain-specific

Most of this language is fairly accessible to a general ERM professional, though there's some security-specific terminology mixed in. The core concepts—vendor assessment, tiering, questionnaires—are standard risk management practices, but the execution details lean toward cybersecurity domain knowledge.

Looking at the codebook more carefully, "breach" and "intrusion" are general threat descriptors, not the specialized terms like ransomware or phishing. "Information security practices and protocols" and "incident response procedures" are broad enough that they don't require deep domain expertise. I'm leaning toward Level 1 here—the language is fundamentally about vendor risk management with cybersecurity applied as the context, not deeply technical security terminology.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' by describing due diligence and monitoring of business partners' cybersecurity practices, making TP the clear category. All language is generic business terminology ('comprehensive due diligence process,' 'continuous monitoring,' 'stringent standards') that any ERM professional could write — no domain terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: "We use a comprehensive due diligence process to manage third-party risks, emphasizing continuous monitoring and to ensure our business partners' cybersecurity practices meet our stringent standards."

Category: This answers "How are third-party cyber risks managed?" - it's about managing third-party risks, business partners' cybersecurity practices. → Third-Party Risk

Specificity: Let me scan for facts.
- "comprehensive due diligence process" - generic

- "continuous monitoring" - generic ERM language
- "third-party risks" - generic
- "business partners' cybersecurity practices" - generic
- "stringent standards" - generic

No domain terminology, no firm-specific facts, no QV facts. → Level 1


fact: IT Lead role implementing cybersecurity processes

fact: 5 years of experience in cybersecurity risk management oversight

fact: external agency with about 15 years of expertise in cybersecurity

reasoning: The paragraph answers 'how is management organized to handle cybersecurity?' — describing who implements the program (IT Lead), their qualifications (5 years experience), and support structure (external agency). Person-removal test leaves only 'processes are implemented and maintained by certain Company management,' which collapses. The '5 years of experience' is a hard number verifiable against a resume, elevating to Level 4. Note: 'about 15 years' for the external agency is a soft/approximate number (similar to 'approximately 20 departments' in the codebook), but the IT Lead's '5 years' is a specific, unhedged quantity sufficient for QV. 'IT Lead' is borderline as a firm-specific role — it's a general IT title below VP level, but the cybersecurity oversight context and organizational specificity give it at least Level 3 status.

thinking:
Let me analyze this paragraph.

Content: Describes who implements cybersecurity risk management - the IT Lead, their experience, and an external agency assisting them.

Category: This is about management's organizational role - who handles cybersecurity, their qualifications, reporting. Person-removal test: remove "IT Lead, 5 years experience, external agency with 15 years" → left with "Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management." That collapses to near-nothing. → MR.

Specificity:
- "IT Lead" - this is below VP level, not a cybersecurity-specific title.

Now I'm checking whether these details count as firm-specific. "Head of IT" and "IT Manager" are standard titles that don't qualify, so "IT Lead" falls into that same category. The IT Lead's 5 years of experience is a concrete number I can verify, so that's quantifiable. For the external agency, "about 15 years" uses hedging language that makes it approximate rather than precise - similar to how "approximately 20 departments" wouldn't count as quantifiable. The IT Lead's tenure is the only hard number here.


fact: forensic analysis

fact: NIST framework

type: framework

fact: Global Corporate Continuity Program

reasoning: While the paragraph opens with after-action evaluation and third-party firms conducting pen testing on the company (RMP per Rule 3), the majority of text addresses how FRI identifies, oversees, and mitigates cybersecurity risks from vendors, service providers, and counterparties — squarely answering 'how are third-party cyber risks managed?' TP wins by text volume. Specificity reaches Level 3 via the named 'Global Corporate Continuity Program,' a distinguishing internal program identifier; domain terms (penetration testing, forensic analysis, NIST framework) establish at least Level 2.

thinking:
Let me analyze this paragraph.

Content: Mixed content - after-action evaluation, third-party firms for assessment/pen testing, third-party risk management, NIST framework, diligence on third parties.

Category: The paragraph starts with after-action evaluation (RMP), then mentions third-party firms assessing the company's own security (RMP per Rule 3), then shifts to managing third-party risks (TP). The bulk of the text is about third-party risk oversight - vendors, service providers, diligence on third parties. TP dominates.

Wait, let me re-read Rule 3: "Third parties hired to serve the company (assessors, pen testers) → RMP." But "Requirements imposed ON vendors → TP" and "Vendor oversight as central topic → TP."

The opening mentions pen testing services, which would be RMP, but the rest of the paragraph is really about how the company oversees and manages its vendors and service providers. That's clearly TP territory, and it takes up most of the space.

Looking at the specificity markers: I see domain terminology like penetration testing, forensic analysis, and NIST framework. There's a named internal program - Global Corporate Continuity Program - that has a specific identifier. FRI appears throughout but that's just self-reference. No actual QV facts here - no specific numbers, dates, or external firm names. That puts this at Level 3 because of the named program with a distinguishing identifier.


fact: CFO has been responsible for oversight function for three years

fact: CFO has worked in financial services for more than 30 years

fact: CCO has been responsible for oversight functions for three years

fact: Current CCO has been serving since April 2025

fact: CCO has worked in financial services for more than 35 years

reasoning: The paragraph answers 'how is management organized to handle cybersecurity?' by describing the CFO and CCO's responsibilities, oversight structure, reliance on IT staff, and their qualifications — person-removal leaves very little substantive content, confirming MR. Multiple quantified facts (specific years of experience as lower bounds, specific date of April 2025 for CCO appointment) elevate specificity to Level 4.

thinking:
Let me analyze this paragraph.

Content Category: The paragraph is titled "Management's Role in Cybersecurity Risk Management" and describes who is responsible (CFO, CCO), their oversight function, reliance on IT staff, and their qualifications/experience. Person-removal test: remove CFO, CCO, their years of experience, reporting lines → very little remains besides "oversee the Company's oversight function" and "rely on Information Technology staff of, and consultants to, the Adviser to manage the assessment and management of material risks from cybersecurity threats." That's fairly thin. This is primarily about Management Role.

Now I'm checking the specificity of the details. The CFO and CCO are generic corporate titles rather than cybersecurity-specific roles, but there are several quantified facts here—specific years of experience (three years, more than 30 years, more than 35 years) and a concrete date in April 2025—that push this toward Level 4. No specialized domain terminology appears in the text.


reasoning: This paragraph acknowledges cybersecurity as important and notes generic risks but does not answer any of the six substantive questions — it describes no program, no governance, no management structure, no incidents, and no materiality assessment. The 'could impact' language is pure speculation. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing due diligence for new providers, continuous monitoring of existing managed service providers and CIO firms, communication/incident response protocols aligned with provider operations, and scheduled meetings. This is oversight imposed ON external parties, making it TP. Specificity remains Level 1: 'incident response,' 'due diligence,' 'continuous monitoring,' and 'industry best practice' are all general business/ERM language; 'managed service provider' and 'CIO firms' are unnamed entities (not firm-specific); no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: About third-party service provider oversight - due diligence, monitoring of managed service provider and CIO firms, protocols for communication and incident response aligned with MSP operations, scheduled meetings with third-party providers.

Category: This is centrally about how third-party cyber risks are managed → Third-Party Risk (TP)

Specificity:
- "managed service provider" - this is a general IT term
- "CIO firms" - interesting, suggests outsourced CIO
- "due diligence checks" - general business
- "incident response" - general (Level 1 per codebook)

- "protocols for communication" - general

Looking through the language here, there's no domain-specific terminology that would meet the ERM threshold. No firm-specific identifiers like named roles, committees, or entities. No QV facts either. The paragraph is describing vendor management processes, but the terms used—managed service providers, outsourced CIO services, due diligence, incident response—are all standard business concepts without cybersecurity-specific domain language.

Even "managed service provider" and "CIO firms," while they might suggest the company outsources IT functions, are unnamed generic references rather than firm-specific facts. This falls into Level 1.


reasoning: This paragraph defines the term 'cybersecurity threat' using generic regulatory language — it answers none of the six substantive questions. No domain terminology beyond the topic itself, no firm-specific or verifiable facts.


reasoning: The paragraph describes the Audit Committee's oversight of cybersecurity — periodic discussions with management and annual program review — directly answering 'how does the board oversee cybersecurity?' No domain terminology passes the ERM test ('identify and detect threats,' 'response or recovery' are general risk language), 'Audit Committee' is not firm-specific (every public company has one), and no verifiable facts are present, leaving this at Level 1.

thinking:
Let me classify this paragraph.

Content: The Audit Committee has periodic discussions with management regarding cybersecurity risks, performs annual review of cybersecurity program including discussion of management's actions to identify/detect threats and planned response/recovery actions.

Category: This answers "How does the board oversee cybersecurity?" - The Audit Committee (board-level) oversight activities. → Board Governance

Specificity: Let me scan for facts:
- "Audit Committee" - NOT firm-specific (every public company has one)
- "periodic discussions" - generic cadence
- "annual review" - generic cadence

- "identify and detect threats" - generic language
- "response or recovery situation" - generic language

No domain terminology that passes the ERM test. No firm-specific facts. No QV facts. This is just standard boilerplate language about what audit committees typically do.

→ Level 1: Generic Boilerplate


reasoning: This is a blank check company (SPAC) explicitly stating it has no operations and no cybersecurity personnel or processes of its own. Per the codebook, SPACs with no real program receive N/O regardless of incidental mentions of risk or third-party reliance. No domain terminology, firm-specific facts, or verifiable claims are present.

thinking: SPAC/blank check company with no operations and no cybersecurity program.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — it describes obtaining reports to assess vendors' security and ongoing monitoring of third-party providers for compliance, which are requirements/assessments imposed ON external parties (TP, not RMP). All language is generic business risk vocabulary ('obtain reports,' 'ongoing monitoring,' 'compliance with our standards') that any ERM professional could write without cybersecurity domain knowledge; no domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Let me classify this paragraph.

Content: About monitoring third parties and obtaining reports to assess their security. This is about oversight of external parties' cybersecurity → Third-Party Risk.

Specificity: Let me check for domain terms, firm-specific facts, or QV facts.
- "obtain reports to assess the security of their systems and processes" — generic
- "ongoing monitoring of all third-party providers" — generic
- "compliance with our cybersecurity standards" — generic

No domain terminology (no SOC 2, no specific assessment types), no firm-specific facts, no QV facts.

This lands at Level 1 — it's generic third-party risk language without specialized terminology or concrete details.


reasoning: This paragraph describes general IT infrastructure and data handling without any cybersecurity-specific disclosure — it answers none of the six substantive questions. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: This paragraph describes general business data handling ('collect and store customer information, sensitive company information') without any substantive cybersecurity disclosure — no measures, processes, or assessments are described. It is generic business language that could appear in any company's filing, warranting N/O at Level 1.


fact: SOC reports

reasoning: The paragraph primarily answers how third-party cyber risks are managed — security assessments before engagement, ongoing monitoring, and review of providers' SOC reports. The final materiality sentence is SI-eligible but subordinate to the dominant TP content. 'SOC reports' is domain terminology (specific security attestation evidence a non-security ERM professional wouldn't naturally reference), elevating to Level 2. Other language ('security assessments,' 'ongoing monitoring,' 'compliance with our cybersecurity standards') is generic ERM vocabulary.

thinking:
Let me analyze this paragraph.

Content Category: The paragraph primarily answers "How are third-party cyber risks managed?" - it's about vendor oversight, security assessments of third-party providers, monitoring compliance, SOC reports. The last sentence is a materiality assessment (SI), but the bulk is about third-party risk management.

The last sentence "We have not encountered cybersecurity challenges that have materially impaired our operations or financial standing" is a materiality assessment (SI), but the majority of text is about third-party risk management.

Category: Third-Party Risk

Specificity: Domain-Adapted (Level 2)

The language here uses some domain-specific terminology like SOC reports and complementary controls, but most of it stays fairly general—security assessments, annual cadences, vendor oversight. The final sentence is just a negative assertion without real substance. Overall, this lands at Level 2 specificity.


reasoning: The final sentence states a materiality conclusion using SEC Item 106(b)(2) language ('materially affected or are reasonably likely to materially affect... business strategy, results of operations, or financial condition'), making SI the primary category. The preceding text about confidentiality frameworks and agreements uses only general business language with no domain terminology, firm-specific facts, or verifiable claims, keeping specificity at Level 1.

thinking:
Let me analyze this paragraph.

Content: Plans to establish confidentiality framework, confidentiality agreements, and a materiality assessment statement.

Category: The last sentence is a materiality assessment - "not aware of any material risks from cybersecurity threats, that have materially affected or are reasonably likely to materially affect the Company, including our business strategy, results of operations, or financial condition." This is the SEC's Item 106(b)(2) language - a backward and forward-looking materiality assessment → SI.

The first parts about confidentiality framework and agreements are generic measures, but the materiality conclusion is the most substantive disclosure here.

Looking at the specifics, the confidentiality framework and agreements are just generic boilerplate without any company-specific details, and the materiality statement is a negative self-assertion using standard SEC language rather than something externally verifiable or grounded in actual facts. There's no domain terminology, firm-specific information, or quantifiable evidence here—this is Level 1 generic boilerplate.


reasoning: The paragraph primarily answers 'How are third-party cyber risks managed?' with its focus on vendors, service providers, and external users — making TP the central topic. Despite mentioning 'CROs' (Contract Research Organizations, an industry term but not cybersecurity domain terminology), the language is entirely generic business/risk management vocabulary ('comprehensive, risk-based approach to identifying and overseeing') with no cybersecurity domain terms, firm-specific facts, or verifiable claims.


reasoning: The paragraph states a backward-looking materiality conclusion ('business strategy, results of operations, and financial condition have not…been affected') and a negative incident assertion ('have not experienced any material cyber incidents'), both mapping to SI under the materiality assessment rule. No domain terminology, firm-specific facts, or verifiable claims are present — negative self-assertions about absence of incidents are not externally verifiable — so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: States that business hasn't been affected by cybersecurity risks, no material incidents experienced. This is a materiality assessment - stating a conclusion about whether cybersecurity has affected business outcomes.

Category: Strategy Integration - "Have not materially affected our business strategy, results of operations, or financial condition" maps directly to SI. Also "have not experienced any material cyber incidents" is a negative assertion with materiality framing.

Specificity: Let me check for facts.
- "business strategy, results of operations, and financial condition have not...been affected" - this is a materiality assessment, boilerplate SI language

- The claim about not experiencing material incidents is unverifiable self-reporting with no supporting details or domain-specific information

This is generic boilerplate SI language. Level 1.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing processes to identify, assess, and manage cybersecurity risks, making it RMP. However, the language is entirely generic ERM vocabulary ('processes designed to identify, assess and manage material risks,' listing asset types and data categories) with no cybersecurity domain terminology, no firm-specific facts, and no verifiable claims — Level 1.

thinking:
Classify this paragraph.

Category: This describes processes to identify, assess, and manage risks. It's about what the cybersecurity program does → RMP.

Specificity: Let me scan for facts.
- "processes designed to identify, assess and manage material risks" → generic ERM language, Level 1
- "cybersecurity threats" → topic, not domain terminology
- "computer networks, third party hosted services, communications systems, hardware and software" → general IT infrastructure terms
- "intellectual property, strategic or competitive in nature, and proprietary or confidential information, including clinical trial data, personal and financial information" → data types, general business language

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


reasoning: The paragraph describes third-party consultants and external service providers hired to serve the company's own security program (risk assessment, security controls, incident response coordination), which per Rule 3 is RMP rather than TP. All language is generic business terminology — 'risk assessment process,' 'security controls,' 'external service providers' — with no domain-specific terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Classify this paragraph.

Content: describes third-party security expert consultant overseeing risk assessment, security controls, incident response coordination; engagement with external service providers to evaluate/enhance security measures.

Category: This describes third parties hired to serve the company's own security program. Per Rule 3, "Third parties hired to serve the company (assessors, consultants, pen testers) → RMP." The central topic is how the company uses external parties as part of its own program, not requirements imposed on vendors. → RMP

Specificity: Let me scan for facts.
- "third-party security expert consultant" — unnamed entity, not firm-specific

- "risk assessment process" — general ERM language, Level 1
- "security controls" — general term
- "cybersecurity incidents" — general
- "external service providers" — unnamed

No domain terminology that passes the ERM test. No firm-specific facts. No QV facts. → Level 1.


reasoning: The paragraph's central topic is oversight of third-party service providers' cybersecurity risks, directly answering 'how are third-party cyber risks managed?' — requirements imposed on vendors and ongoing monitoring of their compliance. All language ('security assessments,' 'ongoing monitoring,' 'data breaches,' 'cybersecurity standards') is generic business/ERM vocabulary that any non-security professional could write; no domain-specific tools, frameworks, or practices are mentioned, and no firm-specific or verifiable facts appear.

thinking:
Third-party risk management is the central topic. Let me check specificity.

No domain terminology that passes the ERM test - "security assessments," "data breaches," "security incidents" - let me think. "Data breaches" is a specific threat type... actually "data breaches" is pretty general business language now. "Security assessments" - would an ERM professional use this? Yes, they do security assessments for non-cyber risks too... actually "security assessments of third-party providers" is pretty generic.

Let me scan: "security assessments," "ongoing monitoring," "cybersecurity standards," "data breaches," "security incidents" - these are all fairly generic.

"Data breaches" has become mainstream business language, so it doesn't really qualify as domain-specific terminology. This is just generic language about third-party oversight with no firm-specific facts or QV details. Level 1.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing ERM integration, risk assessments, security controls, and use of external service providers — all program activities → RMP. Every term used ('risk assessment processes,' 'security controls,' 'external service providers,' 'enterprise risk management') is standard ERM language that fails the domain-terminology test; there are no cybersecurity-specific practices, no firm-specific facts, and no verifiable claims, leaving this at Level 1.

thinking:
Let me classify this paragraph.

Content: Describes cybersecurity risk management program integrated into ERM, includes assessments, team responsibilities, use of external service providers.

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

Specificity: Let me scan for facts.
- "enterprise risk management program" - generic
- "assessments designed to help identify material cybersecurity risks" - generic process language
- "security controls" - generic
- "external service providers" - unnamed, generic
- "critical systems" - generic
- "cybersecurity risk assessment processes" - generic ERM language

- Everything here is generic business/risk language with no domain-specific terminology, firm-specific facts, or quantifiable details. This is Level 1 - Generic Boilerplate.


fact: February and April 2025 — specific dates of Microsoft notifications about unauthorized activity

fact: Microsoft — named external entity that notified the company

fact: Azure environment — named cloud platform where unauthorized activity occurred

fact: nation-state threat actor — specific threat type

fact: enhanced rotation of credentials — domain-specific security practice

fact: security monitoring — domain-specific practice

reasoning: The paragraph's primary frame is a materiality assessment ('not aware of any risks...that have materially affected or are reasonably likely to materially affect'), making it SI under the materiality assessment rule. The actual incident (Microsoft/Azure nation-state activity) is introduced with 'For example' — explicitly subordinated to the materiality conclusion as supporting evidence. Category confidence is moderate because the incident detail is substantial enough to argue for ID. Specificity is Level 4 due to multiple QV facts: specific dates (February and April 2025), named external entity (Microsoft), and named platform (Azure).

thinking:
Let me analyze this paragraph carefully.

This is a complex paragraph that touches multiple categories. Let me break it down:

1. Opening: generic cyber resilience language
2. Materiality assessment: "not aware of any risks from cybersecurity threats... that have materially affected or are reasonably likely to materially affect" → SI
3. Speculation: "could adversely impact" → generic
4. Incident disclosure: "in February and April 2025, Microsoft notified the Company about unauthorized activity within our Azure environment by a suspected nation-state threat actor" → ID

5. Response actions: "activated its incident response plan, issued security advisories, and implemented several advanced security measures" → ID continuation

This paragraph layers a materiality assessment with an actual incident disclosure. The incident itself is detailed—specific dates, Microsoft notification, Azure environment, nation-state actor—which clearly falls under ID. The materiality statement at the beginning says no material impact, but then provides this incident as an example, creating a tension between the SI framing and the substantive ID content. The incident description with response actions is the core disclosure here. The incident has concrete details and takes up substantial space, but it's framed as evidence supporting the materiality assessment rather than the main point. Rule 4 suggests that when financial analysis dominates the framing, SI wins even with detailed incident content. The "For example" construction explicitly subordinates the incident to the broader business impact question, so I'm categorizing this as SI with moderate-high confidence.

Now looking at the specificity level: there are multiple V-eligible facts here—the specific dates in February and April 2025, Microsoft and Azure as named entities, and the nation-state threat actor designation. Combined with domain-specific terminology around credential rotation and security monitoring, this clearly reaches Level 4.


fact: Chief Information Officer (CIO) conducts regular assessments of third-party providers

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing security assessments of vendors before engagement, ongoing monitoring for compliance, and mitigation of vendor-originated risks, making TP the clear category. The CIO reference is a firm-specific cybersecurity leadership role (VP-level+), elevating to Level 3, but the remaining language ('security assessments,' 'ongoing monitoring,' 'compliance with our cybersecurity standards') is generic process description that fails the ERM test, so no domain terminology pushes higher.

thinking:
Let me classify this paragraph.

Content Category: The paragraph primarily answers "How are third-party cyber risks managed?" - it's about vendor oversight processes. This is Third-Party Risk (TP).

Wait, let me check Rule 3. The paragraph describes processes the company uses to oversee third-party providers - security assessments of vendors, monitoring vendors for compliance. This is TP since vendor oversight is the central topic.

Specificity: Let me scan for facts.
- "Chief Information Officer" - CIO is a cybersecurity-specific title at VP level or above → firm-specific (Level 3)
- "security assessments" - generic process language, not domain terminology

- "data breaches" and "third-party providers" are general terms, and "ongoing monitoring" is standard language too

The codebook confirms CIO as firm-specific, so this lands at Level 3.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing the Board → Audit Committee → CFO oversight chain, making it BG. All entities mentioned (Board of Directors, Audit Committee, CFO) exist at every public company and are not firm-specific; the language ('identify, prioritize, assess, manage, and mitigate') is generic ERM terminology with no cybersecurity domain terms, yielding Level 1.

thinking:
Let me classify this paragraph.

Content: Board oversees ERM, Audit Committee oversees cybersecurity risks, receives updates from CFO.

Category: "How does the board oversee cybersecurity?" → Board Governance. The paragraph describes Board → Audit Committee → CFO oversight chain.

Specificity: Let me scan for facts.
- "Board of Directors" — not firm-specific (every company has one)
- "Audit Committee" — not firm-specific (every company has one)
- "CFO" — not a cybersecurity-specific role, NOT firm-specific

- The language around risk identification, prioritization, assessment, management, and mitigation is standard ERM boilerplate with no domain-specific details or firm-specific facts.

This is Level 1 — generic governance language without any substantive cybersecurity content.


reasoning: The paragraph states a conclusion about materiality — that no incidents have materially affected or are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition — making it SI under Rule 5. For specificity, 'fiscal year 2025' is generic reporting context, and the negative assertion ('did not experience any material cybersecurity incidents') is not externally verifiable. No domain terms, firm-specific facts, or QV-eligible facts remain.


reasoning: The paragraph states a conclusion about materiality ('have not experienced any cybersecurity incidents that have been determined to affect us materially, our business strategy, results of operations, or financial condition'), which is a backward-looking materiality assessment → SI per Rule 5. The cross-reference to Item 1A and mention of Business Continuity/Incident Response programs are subordinate. No domain terminology (incident response plan and business continuity are general business terms), no firm-specific facts, and the negative assertion about no material incidents is not externally verifiable → Level 1.

thinking:
Let me analyze this paragraph.

Content: States no material incidents, mentions business continuity and incident response programs, cross-references Item 1A.

Category: The key sentence is "we have not experienced any cybersecurity incidents that have been determined to affect us materially, our business strategy, results of operations, or financial condition." This is a materiality assessment (backward-looking negative assertion) → SI per Rule 5.

Specificity: "have not experienced any material cybersecurity incidents" — negative self-assertion, NOT externally verifiable. "Business Continuity and Incident Response programs" — general business terms, not domain terminology.

The cross-reference to Item 1A doesn't add substantive content here, and without domain-specific language or company-particular facts, this disclosure stays at the most general level.


reasoning: AA Mission Acquisition Corp. is a SPAC with no operations — the paragraph explicitly states 'we have no personnel or processes of our own' for cybersecurity. Per the codebook, SPACs with no real cybersecurity program receive N/O regardless of incidental board oversight or risk mentions. The board review of risk factors before SEC filings is generic governance, not a substantive cybersecurity disclosure. N/O always receives Specificity 1.

thinking:
SPAC with no operations/program of its own. They explicitly state "we have no personnel or processes of our own for this purpose." This is a SPAC/no-operations company.

Per the codebook: "SPACs and no-operations companies: Companies with no cybersecurity program receive N/O regardless of incidental mentions of board oversight or risk acknowledgment."

N/O, Specificity 1.


reasoning: This paragraph is a generic statement of intent about cybersecurity importance without describing any actual measures, processes, oversight, or organizational details. It answers none of the six substantive questions — it merely acknowledges cybersecurity matters. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: This paragraph is pure speculation about potential cybersecurity risks ('may be unable to,' 'could expose,' 'could have a material adverse effect') without describing any actual cybersecurity measures, processes, or assessments. It reads as generic risk factor language found in any 10-K. The 'could have a material adverse effect' language is speculation, not a materiality assessment, so it fails the SI test. No domain terminology, firm-specific facts, or verifiable claims are present.


fact: privileged access policies

fact: multi-factor authentication

reasoning: The paragraph primarily describes security measures implemented (privileged access policies, enhanced MFA) — answering 'what does the program do?' The incident is referenced as context ('following the incident') but the content focuses on remediation measures, not the incident itself. The forward-looking risk language ('cannot provide assurance... will not be materially affected') is speculation, not a materiality conclusion, so it does not qualify as SI. The cross-reference to Item 1A is subordinate. MFA and privileged access policies are cybersecurity domain terms that pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes additional security measures after an incident (stronger privileged access policies, enhanced MFA), then discusses ongoing risks and materiality, then cross-references Item 1A.

Category analysis:
- First part describes security measures implemented after an incident - this is post-incident remediation, which relates to both ID and RMP
- "following the incident" references a real event → ID-adjacent
- But the primary content is about what measures were implemented (RMP)
- Second sentence is forward-looking risk speculation ("cannot provide assurance... will not be materially affected") - this is speculation, not a materiality assessment

- Third sentence is a cross-reference → N/O

The core issue is whether this is primarily about incident response (ID) or the security measures themselves (RMP). The paragraph focuses on what remediation steps were taken—stronger access controls and MFA—rather than describing the incident itself. The "cannot provide assurance" language is speculative risk language, not a concrete materiality claim. So this leans RMP with some ID context, plus a cross-reference.

For specificity, "privileged access policies" and "multi-factor authentication" are established cybersecurity domain terms that meet the ERM threshold. There's no firm-specific implementation detail or quantifiable fact beyond the terminology itself.

This is Level 2 - Domain-Adapted.


fact: threat intelligence analysis

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' — employee training, leveraging MSPs for scans and threat intelligence, and imposing contractual requirements on third parties. Two of three sentences describe the company's own program activities (training, system scans via MSPs), with the third-party contractual requirement as a subordinate element rather than the central topic. 'Threat intelligence analysis' is a cybersecurity domain term that passes the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Two main topics - employee training program, use of third-party providers (both as service to company AND requirements imposed on vendors).

Category analysis:
- Employee education/training program → RMP
- Managed service providers performing scans and threat intelligence → RMP (third parties serving the company)
- Requiring third-party providers to adhere to contractual requirements → TP

The paragraph has three sentences. First is about training (RMP). Second is about leveraging MSPs for the company's program (RMP). Third is about imposing requirements on third parties (TP).

Most of the content focuses on the company's own program with third-party requirements as a supporting element, so this leans RMP overall. Looking at the specificity, most terms are fairly generic—"employee education and training program," "cybersecurity threats," and "managed service providers" lack detail. The more domain-specific language appears in "threat intelligence analysis" and "system scans," though the latter is borderline in this context.

There are no firm-specific facts like named roles or committees, and nothing that qualifies as QV material. The presence of domain terminology like threat intelligence pushes this toward Level 2.


content_category: Incident Disclosure

fact: May 2025 - specific date of incident detection

fact: DNS configurations - domain-specific cybersecurity terminology

fact: data exfiltration - specific threat type terminology

reasoning: This paragraph describes an actual cybersecurity incident — unauthorized changes detected in May 2025 from a former employee's retained credentials, with timeline, scope, and remediation details — directly answering 'what happened?' → Incident Disclosure. 'May 2025' is a specific date tied to a real cybersecurity event, making it QV-eligible. Domain terms like DNS and data exfiltration also appear.


reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' by describing the CEO, MIS consultant, and MIS supervisor's respective responsibilities and reporting lines — role allocation is the core content. No domain terminology passes the ERM test ('prevention, detection, mitigation, and remediation' is standard risk language), and no titles qualify as firm-specific: CEO is generic, and 'MIS consultant' and 'MIS supervisor' are general IT titles below VP level without a security qualifier.

thinking:
Let me analyze this paragraph.

Content: Describes CEO, MIS consultant, and MIS supervisor roles in managing cybersecurity. MIS supervisor monitors prevention/detection/mitigation/remediation, updates CEO regularly.

Category: This is about how management is organized to handle cybersecurity. Person-removal test: remove "CEO and MIS consultant" and "MIS supervisor" — what remains? "prevention, detection, mitigation, and remediation of cybersecurity risks" and "regular cybersecurity updates." That's fairly generic but there is some substance. However, the primary content is about WHO does WHAT — role allocation and reporting lines. → MR

The roles mentioned here lack specificity — CEO and MIS titles are generic across companies, MIS isn't even a cybersecurity-specific designation, and the risk management language used is standard boilerplate without any domain expertise or firm-specific details.


reasoning: The company explicitly states it does not have formal cybersecurity or risk assessment policies and merely expresses intent to develop them in the future — analogous to SPACs/no-operations companies with no real program. The vague reference to having 'invested in measures' lacks any substantive description of actual cybersecurity activities, and the remainder is forward-looking intent, a cross-reference to Risk Factors, and SEC transition guidance. N/O always receives Generic Boilerplate.

thinking:
Let me analyze this paragraph from Charging Robotics Inc. (CHEV).

This is a company that recently went through an acquisition, reshaped its board, and notably does NOT have formal cybersecurity policies yet. They're essentially a early-stage/post-acquisition company with no real cybersecurity program.

Category: This is tricky. The paragraph says they don't have formal cybersecurity policies, mentions the board is addressing implementation, and they intend to develop a program. There's also a cross-reference and transition guidance mention.

The key question: what does this primarily answer? It's mostly about the ABSENCE of a program.

The vague mention of investing in risk-reduction measures doesn't change the fundamental picture—the company explicitly lacks formal policies and is still in planning stages. This looks like a N/O situation, similar to how SPACs or early-stage companies with minimal operations would be classified. The bulk of the disclosure is about what they don't have and what they plan to do, not what they've actually implemented.