reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected us, including our business strategy, results of operations or financial condition'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. The brief mention of past threats/breaches is subordinate to the materiality conclusion. No firm-specific facts from the IS list are present — the risk factor title and third-party references are generic cross-reference language.

thinking:
Let me analyze this paragraph.

Content: Contains a materiality assessment ("have not materially affected us, including our business strategy, results of operations or financial condition"), mentions past threats/breaches briefly, and has a cross-reference to Risk Factors.

Category: The materiality assessment is the substantive content here. Per Rule 6, any paragraph with an explicit materiality conclusion is Strategy Integration, even with a cross-reference appended.

Specificity: The materiality language is boilerplate. No named frameworks, no specific dates, no firm-specific facts from the IS list. The cross-reference names specific risk factor language but that's just a cross-reference.

Since the materiality language is generic and lacks any firm-specific details or frameworks, this falls into Generic Boilerplate.


content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: The paragraph opens with an explicit materiality assessment ('risks from cyber threats have not materially affected the Fund's business strategy, results of operations or financial condition'), which per Rule 6 is Strategy Integration regardless of the appended cross-reference to Risk Factors. The specific date 'December 31, 2023' is one firm-specific fact, reaching Firm-Specific but not Quantified-Verifiable (only one hard verifiable fact).

provider: anthropic

generationId: agent-sdk

stage: benchmark

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

Specific facts: "December 31, 2023" is a specific date. That's one hard fact. No other QV-eligible facts.

Specificity: One specific date → Firm-Specific.

fact: as of December 31, 2023


content_category: Risk Management Process

reasoning: The paragraph describes the company's internal incident response plan, team composition, escalation process, and integration with business continuity plans — all internal cybersecurity processes. The Board and Audit Committee are mentioned only in the context of the escalation process, not as primary actors. The detailed departmental composition of the IR team (10 named departments) is a firm-specific fact, but there are no QV-eligible hard facts (no dates, dollar amounts, named third-party firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: Describes the company's incident response plan, team composition, escalation process, and integration with business continuity. This is about internal processes.

Category: Risk Management Process - describes IR plan, team, escalation process, integration with BCP. Board/Audit Committee mentioned briefly in escalation context, not as primary actors.

Specificity: Let me check for specific facts.
- Team composition: "information security, legal, compliance, risk management, communications, facilities, operations, marketing and distribution, finance, and human resources" - this is a specific departmental composition → IS list item
- "external, nationally recognized legal and forensics resources" - unnamed, generic

- References to Audit Committee, Board of Directors, tabletop training, incident response plan, and business continuity plans are all generic program elements without firm-specific details. The only concrete fact here is the departmental composition itself, which qualifies as firm-specific information.

No quantifiable facts like dates, financial figures, headcounts, or named external resources.

fact: Incident response team includes representatives from information security, legal, compliance, risk management, communications, facilities, operations, marketing and distribution, finance, and human resources


content_category: Management Role

reasoning: The paragraph is primarily about the people filling cybersecurity leadership roles — CTO, CSO, and CIO — describing their experience, qualifications, how they coordinate, and their respective responsibilities. While some process elements are mentioned (GRC, cyber business continuity planning), these are subordinate to the management structure and personnel descriptions. Two QV-eligible quantified facts: 'two decades' of CIO experience and 'two public companies' where the CIO previously served.

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

The paragraph discusses multiple management roles: CTO (who is a Board member), CSO, and CIO. It describes their responsibilities, experience, and how they work together. The primary content is about the people and their roles/qualifications.

Content Category: This is about management roles - CTO, CSO, CIO - their experience, responsibilities, reporting structure, and how they coordinate. The person-vs-function test: the paragraph tells us about who these people are (experience, background) and how they relate to each other. While there are some process elements (cybersecurity program initiatives, GRC), the dominant content is about the management structure and qualifications.

I'm identifying the specific quantifiable facts here: the CTO serves on the Board, the CSO leads a named office, and the CIO brings roughly two decades of experience plus prior roles at public companies. The CIO's team also oversees GRC functions. These details about experience duration and specific organizational positions are all eligible for quantitative verification.

fact: CTO (cybersecurity-specific leadership role, also a Board member)

fact: CSO (Chief Security Officer)

fact: CIO (Chief Information Officer)

fact: CSO Office established at JFrog

fact: Over the past two decades of CIO experience

type: quantified

fact: CIO served in two public companies


reasoning: The paragraph describes the company's own internal continuous monitoring program — security metrics, control assessments, analysis reporting, and attack detection — all of which are standard cybersecurity processes. No named frameworks, tools, roles, dates, or firm-specific facts are present; 'executive team' is generic and the listed activities are common practices that could apply to any company.

thinking:
Classify this paragraph.

This describes the company's internal cybersecurity monitoring program - processes, activities. No person is the focus, no board oversight, no third-party, no incident, no materiality assessment.

Category: Risk Management Process

Specificity: No named frameworks, no named roles (CISO etc.), no dates, no numbers, no named tools. "Executive team" is generic. The bullet points describe common practices (monitoring, assessments, reporting). Nothing firm-specific.

Generic Boilerplate.


content_category: Incident Disclosure

reasoning: The paragraph describes the scope and aftermath of an actual ransomware incident—potential exfiltration of personal information and notification actions taken—placing it squarely in Incident Disclosure. No specific dates, named firms, named tools, headcounts, or other facts from the IS list are present; language like 'ransomware actors,' 'personal information,' and 'notifications to individuals and regulators' is standard incident language, yielding Generic Boilerplate.

thinking:
Classifying this paragraph about MKS Inc's cybersecurity disclosure.

This describes aftermath of a ransomware incident - exfiltration of personal information, notifications to individuals and regulators. This is about what happened in an incident.

Content category: Incident Disclosure - describes scope (personal information exfiltration) and response actions (notifications).

Specificity: No specific dates, no named firms, no dollar amounts, no named tools. "ransomware actors" is standard incident language. No specific facts from the IS list.

This looks like generic boilerplate language rather than substantive disclosure.


category_confidence: medium

reasoning: The opening sentences frame cybersecurity as influencing business strategy, but the dominant content describes internal training processes — monthly phishing/vishing/smishing simulations, quarterly IT training, incident response tabletop exercises, and employee awareness programs. By the dominant-category rule, this is Risk Management Process. The specific year '2023' is a firm-specific fact from the IS list, but it is the only QV-eligible fact (cadences like 'monthly' and 'quarterly' are on the NOT list), so specificity is Firm-Specific rather than Quantified-Verifiable.

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

Content: The paragraph discusses how cybersecurity risks influence business strategy and operations, then goes into detail about training programs (monthly phishing simulations, quarterly IT training, tabletop exercises). It starts with strategy integration language but the bulk is about internal processes/training.

Category: The opening sentences touch on Strategy Integration ("factor into many facets... have a direct influence on business strategy"). But the majority of the paragraph describes internal training and awareness programs - monthly simulations, quarterly IT training, tabletop exercises, incident response exercises. The dominant content is Risk Management Process.

Now I'm reconsidering the categorization. The framing emphasizes strategy, but the substance is really about the specific training cadences and processes they've implemented. That makes Risk Management Process the dominant category by volume. Looking at the specificity, "2023" appears as a concrete date reference, and the training activities have defined frequencies - monthly phishing simulations with particular attack vectors, quarterly IT training sessions. Those are the concrete facts worth capturing.

Checking against the QV-eligible criteria: "2023" qualifies as a specific date, but "monthly" and "quarterly" are just cadences, not dates themselves. So there's really just one QV-eligible fact here. That puts this squarely in Firm-Specific territory.


reasoning: The paragraph describes generic incident response process steps — containment, implementing solutions, and recovery — which are internal cybersecurity processes. All language is boilerplate with no named frameworks, tools, roles, dates, or firm-specific details.

thinking:
Classifying this paragraph from TTM Technologies' 10-K Item 1C filing.

This describes incident response process steps: containment, implementing solutions, recovery. These are generic IR planning activities - no named tools, frameworks, dates, roles, or firm-specific details.

Category: Risk Management Process - describes internal IR processes
Specificity: Generic Boilerplate - all generic practices, no named standards or firm-specific facts


reasoning: The paragraph primarily describes a real cybersecurity incident — the February 2022 targeted cyber-attack, its operational impact (three-week shutdown), and immediate response actions. While it also touches on materiality ('do not expect further material adverse impact') and post-incident investments (CSRM program, adding a CISO), the incident narrative dominates. Multiple IS-list facts are present (specific date, CISO role, named CSRM program), but only one hard QV-eligible fact (February 2022 date) — 'approximately three weeks' is an approximation, not a hard verifiable number — so specificity is Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content: Describes a February 2022 cyber-attack, its operational impact (three weeks shutdown), response actions, materiality assessment, and post-incident investments including adding a CISO.

Category analysis:
- Incident Disclosure: describes what happened (targeted cyber-attack, shut down systems, limited operations for ~3 weeks)
- Strategy Integration: materiality assessment ("do not expect further material adverse impact"), accelerated investments
- Management Role: added a CISO
- Risk Management Process: strengthened security, enhanced monitoring

The dominant content is the incident narrative - what happened, when, scope, response.

The materiality statement and post-incident improvements are secondary to the core incident description. Looking at the specificity, I've got one clearly verifiable fact in the February 2022 date, while "three weeks" is approximate and the CISO addition is more of an internal role designation than a hard verifiable detail. The CSRM program is named but not externally verifiable in the same way.

With just one QV-eligible fact and the rest being internal-specific details, this lands at Firm-Specific level 3.

fact: February 2022 (specific date of cyber-attack)

fact: CISO added to IS leadership

fact: CSRM program (named internal program)

fact: approximately three weeks of limited operations


reasoning: The paragraph opens by naming the CFO as responsible but then spends the vast majority of its text describing the company's internal cybersecurity processes: safeguards, third-party assessments, ISO 27001 alignment, incident response plan, external consultant for ISMS, and security awareness training. Applying the person-vs-function test, removing the CFO attribution leaves a fully coherent process description, making this Risk Management Process. For specificity, ISO 27001 is a named standard (Sector-Adapted), but CFO is on the NOT list (generic C-suite), no third-party firms are named, no specific dates or headcounts appear, and no firm-specific facts from the IS list are present beyond the framework reference.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics: management responsibility (CFO), risk management processes, third-party engagement, and framework alignment. Let me determine the dominant category.

Content analysis:
- Opens with "Disclosure of Management's Responsibility" and names the CFO as responsible
- But then most of the paragraph describes what the program does: protocols, policies, tools, safeguards, third-party assessments, ISO 27001 alignment, incident response plan, external consultant, training

Person-vs-function test: The CFO is mentioned as attribution, then the paragraph describes processes. Remove the CFO mention and the paragraph still makes complete sense as a process description. → Risk Management Process

Now checking the specificity level. The CFO is a generic C-suite title that doesn't count toward specificity, and while ISO 27001 is named, it's only mentioned as an alignment target rather than a certification. The third-party assessments and external consultant are both unnamed and generic, with no specific dates, firm names, tools, or headcounts provided. I'm not finding any unique identifiers in the text, so this falls into the Sector-Adapted category based on the ISO 27001 reference alone.

fact: ISO 27001 alignment mentioned

type: framework


content_category: Third-Party Risk

reasoning: The paragraph's primary sentence describes systems and processes to oversee and reduce cybersecurity risk at third-party vendors, service providers, and customers, making third-party oversight the dominant topic. The second sentence mentions cybersecurity insurance (Strategy Integration) but is subordinate. All language is generic — no named vendors, standards, tools, roles, or specific facts from the IS list.

thinking:
Let me analyze this paragraph.

Two sentences: (1) systems/processes for third-party vendor oversight, (2) cybersecurity insurance.

Category: First sentence is about third-party risk oversight. Second sentence is about cyber insurance (Strategy Integration). Which is dominant? Both are roughly equal length. The first sentence is about overseeing third-party vendors - Third-Party Risk. The second is about insurance - Strategy Integration. I'd say it's split, but the first sentence is slightly longer and sets the topic. However, let me think about dominant purpose.

Actually, the first sentence describes processes to manage third-party risk. The second sentence is about insurance. These are two different categories.

The opening sentence about vendor oversight processes is longer and establishes the main focus, so Third-Party Risk is the dominant category here. The insurance component is secondary, even though it represents a distinct Strategy Integration element.

Looking at the specificity, there are no named standards, roles, or concrete facts from the IS list—just generic language like "systems and processes" and "third-party vendors." This reads as Generic Boilerplate.


content_category: None/Other

reasoning: This is a cross-reference to Risk Factors with no materiality conclusion. It does not state whether cybersecurity risks have or have not materially affected the company — it merely directs the reader elsewhere. Pure cross-reference → None/Other.


reasoning: The paragraph's central topic is oversight of external parties' cybersecurity — evaluating vendor risk before selection, periodic reassessment, and incident-triggered reviews of third parties. This is vendor oversight as the primary focus, not a component of an internal process description. No named standards, firm-specific facts, or verifiable details are present; the practices described (pre-engagement evaluation, periodic assessment, incident-triggered review) are generic.

thinking:
Classify this paragraph.

The paragraph is about third-party risk management - evaluating vendors, periodic assessments, and responding to third-party incidents. Vendor oversight is the central topic.

Specificity: No named frameworks, no named roles, no specific dates, no named firms/tools. "service providers that deal with sensitive employee, business, or customer data" is somewhat specific but not really a firm-specific fact. The practices described (risk evaluation before choosing vendors, periodic assessment, assessment after incidents) are general practices.

No IS-list facts. No named standards.

This looks like generic boilerplate - standard vendor management guidance without any organization-specific details or frameworks.


reasoning: The paragraph describes the company's own internal encryption and data protection practices, which are core risk management process activities. It contains no named frameworks, tools, roles, dates, or any firm-specific details — the description is entirely generic and could apply to virtually any company.

thinking:
Classify this paragraph.

This describes encryption practices - internal security processes. No frameworks named, no specific facts, no named tools/roles.

Category: Risk Management Process - describes internal data protection practices
Specificity: Generic Boilerplate - no named standards, no firm-specific facts, completely generic


reasoning: The paragraph describes the company's internal cybersecurity risk management processes — ERM integration, risk register, continuous monitoring, prioritization, and periodic reporting. While it mentions executive management and the audit committee, these are subordinate to the process description. No named frameworks, cybersecurity-specific roles, dates, tools, or other facts from the IS list are present; 'monthly,' 'periodic,' 'cybersecurity team,' 'audit committee,' and 'risk register' are all generic per the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes integration of cybersecurity into ERM, risk register, monitoring, prioritization, and reporting chain. The primary topic is the company's internal risk management processes.

Category: Risk Management Process - describes internal processes (ERM integration, risk register, monitoring, prioritization). The mention of executive management reporting to audit committee is subordinate to the process description.

Specificity: Let me check for specific facts.
- "enterprise risk management program" - generic program name
- "risk register" - generic

- "cybersecurity team" - generic
- "security management" - generic
- "executive management" - generic
- "audit committee" - generic (on the NOT list)
- "monthly basis" - generic cadence
- "periodic basis" - generic cadence
- No named frameworks, no named roles from the IS list, no specific dates, no named tools

This is Generic Boilerplate.


reasoning: The paragraph describes what the cybersecurity team does — publishing policies, promoting compliance, risk mitigation measures (network segmentation, detection and response, recovery), and periodic assessments. The CIO/Security Officer is mentioned as attribution for who leads the team, but the substantive content is about the program's functions and activities. Removing the role title, the paragraph still reads as a process description. One IS-list fact (CIO as a cybersecurity-specific title) elevates to Firm-Specific, but no second QV-eligible hard fact exists to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes a dedicated team led by CIO/Security Officer, their responsibilities (publishing policies, compliance, risk mitigation), and specific measures (network segmentation, cyber protection, detection/response, recovery).

Category: The paragraph mentions the CIO but is primarily about what the team DOES - publishing policies, compliance, risk mitigation, assessments, network segmentation, etc. Applying the person-vs-function test: remove "led by our CIO, Security Officer" and the paragraph still describes the team's functions. → Risk Management Process.

Specificity: The CIO is a cybersecurity-specific role on the IS list, making this Firm-Specific. While "Security Officer" is a named role and the paragraph covers common practices like network segmentation and detection/response, there are no named frameworks, dates, dollar amounts, or external firms mentioned. With just one IS-list fact, this rates as Firm-Specific (3).

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


reasoning: The paragraph primarily describes the company's internal cybersecurity program — risk assessment, security monitoring, vulnerability assessments, penetration testing, and tabletop exercises — all of which are internal processes. The opening risk statement is subordinate to the process description. No named frameworks, tools, roles, dates, or other specific facts appear; all practices listed (pen testing, vulnerability assessments, tabletop exercises, endpoint monitoring) are common/generic and on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity risks faced, then describes the company's cybersecurity program including security monitoring, risk assessment, and various tools/services (network monitoring, vulnerability assessments, penetration testing, etc.).

Category: This is about the company's internal cybersecurity processes - risk assessment, monitoring, tools. The opening risk statement is generic, but the bulk describes their program. → Risk Management Process

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

- No named tools/products
- No dates, dollar amounts, headcounts
- Practices mentioned are all generic: "network and endpoint monitoring, vulnerability assessments, penetration testing, threat monitoring and tabletop exercises"
- "comprehensive cybersecurity program" is generic
- ERM integration mentioned generically ("alongside other company risks as part of our overall risk assessment process")

This is generic boilerplate with no concrete details or named standards to anchor it.


reasoning: The grammatical subject is 'management team' but the paragraph's substantive content describes cybersecurity processes — prevention, detection, mitigation, remediation via briefings, threat intelligence, and security tools. Applying the person-vs-function test, removing the management attribution leaves a complete process description. No named frameworks, tools, roles, firms, dates, or quantified facts appear — all entities are generic ('internal security personnel,' 'external consultants,' 'security tools').

thinking:
Let me analyze this paragraph.

Content: Describes what the management team does regarding cybersecurity - prevent, detect, mitigate, remediate through various means including briefings, threat intelligence, alerts from security tools.

Category: The subject is "Our management team" but the content is about processes/activities (prevent, detect, mitigate, remediate). Applying the person-vs-function test: if I remove "Our management team supervises," the paragraph describes processes - briefings, threat intelligence, alerts, security tools. This is about the function, not the person. → Risk Management Process

Specificity: No named frameworks, no named tools, no named roles (CISO etc.), no dates, no numbers.

Looking at the language used throughout - "management team," "external consultants," "security tools" - everything stays at a high level of abstraction without concrete details. This reads like generic boilerplate.


reasoning: The paragraph describes what happened in a cybersecurity incident: systems affected, data exfiltrated and posted on the dark web, types of data compromised (PII, bank account info), regulatory cooperation, and notice/remediation actions. The specific date reference ('fourth quarter of 2023') is the only IS-list fact; other details like 'three state regulators' are vague quantifiers and 'dark web' is descriptive but not a named entity, so this reaches Firm-Specific but not Quantified-Verifiable.

thinking: Incident description with specific details.

fact: fourth quarter of 2023


reasoning: The paragraph describes an actual cybersecurity incident: when it was detected (early April 2023), how it was discovered (routine monitoring), and response actions taken (investigation, law enforcement, security enhancements). This is clearly Incident Disclosure. The specific date is the only fact on the IS list; all other details ('leading cybersecurity experts', 'law enforcement', 'additional safeguards') are generic/unnamed, yielding one hard fact → Firm-Specific.

thinking:
Classify this paragraph.

Content: Describes an actual cybersecurity incident - detection, timing, response actions.

Category: Incident Disclosure - describes what happened, when, and response actions.

Specificity: "In early April 2023" is a specific date (month+year). Other details are generic ("leading cybersecurity experts" = unnamed, "law enforcement" = standard). Only one hard fact (the date). So Firm-Specific.

fact: early April 2023


reasoning: The paragraph describes the company's approach to designing and assessing its cybersecurity program using named frameworks (ISO 27001, CIS 18, NIST CSF), which is squarely risk assessment methodology. It names three recognized standards, triggering Sector-Adapted, but the explicit disclaimer ('does not imply that we meet any particular technical standards') negates any certification claim, and no firm-specific facts (named roles, dates, tools, headcounts) are present, keeping it at Level 2.

thinking:
Classify this paragraph.

Content: Describes framework adoption (ISO 27001, CIS 18, NIST) for their cybersecurity program design and assessment. This is about internal processes/methodology.

Category: Risk Management Process - describes framework adoption and risk assessment methodology.

Specificity: Names three frameworks (ISO 27001, CIS 18, NIST) but explicitly disclaims certification or unique implementation. Nothing firm-specific beyond naming standards. The disclaimer actually reinforces that this is generic usage. → Sector-Adapted.

Wait - does "CIS 18" count as a named standard? Yes, CIS is on the recognized standards list.

All three are recognized standards, but there's no firm-specific information here, so this stays at Sector-Adapted level.

fact: CIS 18

fact: NIST Cybersecurity Framework


reasoning: The paragraph names a specific cybersecurity leadership role (Senior Principal Security and Infrastructure Architect) and describes their experience (over 20 years). Applying the person-vs-function test: removing the role and credentials leaves only a shell sentence about processes being 'implemented and maintained by certain Company management,' so the substantive content is about the person. Specificity is Firm-Specific: the named cybersecurity-specific role is an IS-list fact, and the 20 years of experience is one QV-eligible fact, but only one QV-eligible fact does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes who implements cybersecurity risk assessment processes - mentions a specific role (Senior Principal Security and Infrastructure Architect) with experience (over 20 years).

Category: This is about the person's role and qualifications. The paragraph names a specific cybersecurity leadership title and describes their experience. But it also starts with "risk assessment and management processes are implemented and maintained by..." - so is it about the process or the person?

Person-vs-function test: If I remove the role and credentials, what's left? "Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management." That's essentially empty.

The substantive content here is really just the person's role and their experience level. I've got two specific facts: the named role title and over 20 years of experience. But the named role itself doesn't count as a QV-eligible fact - only the years of experience does. That gives me just one QV-eligible fact, which means this falls into the Firm-Specific category.

fact: over 20 years managing large scale enterprise security systems


content_category: Board Governance

reasoning: The paragraph's primary communicative purpose is describing how the Audit and Finance Committee receives cybersecurity oversight through regular CTO reports — the committee appears three times and is the entity being informed. While the CTO is the grammatical subject of the opening sentence (which could push toward Management Role), the paragraph contains nothing about the CTO as a person and is structured entirely around the governance reporting mechanism. Firm-Specific due to the CTO role, the named Audit and Finance Committee (distinct from generic 'Audit Committee'), and the uniquely named Digital QBR program, but no two QV-eligible hard facts (no dates, dollar amounts, named third-party firms, or named tools).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the CTO providing reports to the Audit and Finance Committee and leadership teams. Let me determine category and specificity.

Category analysis:
- The CTO is the grammatical subject providing reports
- But the content is about what the reports contain and the reporting process
- The person-vs-function test: if I remove "Our CTO", the paragraph still describes reporting processes, report contents, review cadences
- However, the CTO is the primary actor here, and the paragraph is about reporting lines and briefing cadence
- Actually, this is about the reporting/oversight structure. The CTO reports TO the Audit and Finance Committee - this is about the oversight mechanism

- The board committee is receiving reports, which is Board Governance territory
- But Rule 2 says "Management role reports TO the board → Management Role" - so the CTO as the primary actor reporting to the board would fall under Management Role
- Wait, let me reconsider the person-vs-function test more carefully. The paragraph isn't really about the CTO as an individual - it's about the reporting cadence and what gets communicated. If I replace "Our CTO" with "the Company," the substance remains the same: "The Company provides relevant cybersecurity reports to the Audit and Finance Committee..."
- This suggests the focus is on the function and process rather than the person, which points toward Board Governance rather than Management Role. The CTO is the grammatical subject, which points toward Management Role under Rule 2, but the paragraph's focus is really on the oversight structure and what information flows to the board committee rather than on the CTO's qualifications or role. Since the Audit and Finance Committee is the primary recipient and the dominant purpose is describing how they receive cybersecurity oversight, I'm categorizing this as Board Governance. I'm working through the decision tree: the CTO is the grammatical subject, so this falls under Management Role rather than Board Governance. The person-versus-function test distinguishes between Management Role and Risk Management Process, and since this is about the CTO's reporting structure and responsibilities rather than risk assessment methodology or vulnerability management, Management Role is the right classification. The reporting structure itself is explicitly a Management Role topic, so that classification makes sense. But I'm noticing the paragraph really emphasizes the oversight mechanism—the Audit and Finance Committee appears multiple times, and the focus is on how reports flow to governance bodies and when they're reviewed. This feels more like Board Governance, which covers how the board and committees oversee cybersecurity. Let me look at what's actually being described: the cadence of reporting, which committees receive what information, and how the security roadmap gets reviewed at the governance level. That's the governance structure, not just the CTO's position. I'm going back and forth on whether this is about the board's oversight role or the management reporting structure. The CTO is technically the grammatical subject, which would suggest Management Role, but the paragraph really centers on how the Audit and Finance Committee receives and stays informed about cybersecurity—that's the core governance function being described. I think the primary purpose here is showing the board committee's oversight mechanism, so Board Governance makes more sense than focusing on the CTO as a management role.

Now I'm checking what qualifies as firm-specific information. The CTO title itself is standard, but the Audit and Finance Committee is this company's particular committee structure, not a generic audit committee. The Digital QBR is their named internal program, and the Digital Leadership team is their specific team. These are all firm-specific details, which puts this at Level 3, though none of them trigger the quantitative value threshold.

fact: CTO

fact: Audit and Finance Committee

fact: Digital Quarterly Business Review ("Digital QBR")

fact: Digital Leadership team


reasoning: The board of directors is the grammatical subject throughout, describing its oversight of cybersecurity risk and delegation through the audit committee. All entities mentioned (board of directors, audit committee, executive officers, senior management) are on the NOT list as generic governance terms, with no firm-specific facts present.

thinking:
Let me analyze this paragraph.

Content: Board oversight of cybersecurity risk, delegation through audit committee. Board is the grammatical subject throughout.

Category: Board Governance - clear, board is the subject performing oversight.

Specificity: Let me check facts:
- "board of directors" - generic, NOT list
- "audit committee" - generic, NOT list
- "executive officers and other members of senior management" - generic
- No named frameworks, no specific facts from the IS list

This is Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes — threat identification, risk assessment, monitoring methods, and security controls. The CFO is mentioned as part of the cybersecurity function, but the paragraph is about what the function does (processes, tools, methods), not the person's qualifications, so the person-vs-function test points to Risk Management Process. No named frameworks, no firm-specific facts survive the NOT list: CFO is generic C-suite, MSSP is unnamed, and all practices listed (audits, threat assessments, monitoring, incident detection) are common/generic.

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

Content: Describes the cybersecurity function's activities - identifying, assessing, managing threats using various methods (monitoring, audits, tools, threat assessments, etc.) and maintaining security measures.

Category: The paragraph mentions CFO and MSSP but the bulk is about what the cybersecurity function DOES - processes, methods, tools. The person-vs-function test: remove the CFO mention and the paragraph still describes processes. → Risk Management Process

But wait - CFO is on the "IS NOT" list (generic C-suite). The MSSP is unnamed ("managed security services provider").

Now I'm checking what specific facts are actually present. The CFO is generic C-suite, the MSSP is unnamed, and all the third-party service providers lack names. There are no named frameworks, dates, tools, or specific numbers - just generic practices like monitoring, audits, and threat assessments. With no IS-list facts remaining and no named standards, this falls into Generic Boilerplate.


reasoning: The paragraph identifies the specific team composition (Information Security, Compliance, Legal, Internal Auditing) overseeing cybersecurity and describes their collective experience (~20 years average). The primary content is about who these people are and their qualifications, making it Management Role. While the third sentence touches on their functions, it is subordinate to the personnel description. Specificity is Firm-Specific: the named departmental composition and quantified experience are IS-list facts, but only one QV-eligible fact (20 years) prevents reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes UHS' cybersecurity leadership team - their composition (Information Security, Compliance, Legal, Internal Auditing), their experience (average over 20 years), and what they do (monitor prevention, mitigation, detection, remediation through management of cybersecurity processes).

Category: This is about the people who oversee cybersecurity - their team composition and experience. But let me apply the person-vs-function test. The paragraph tells us about who these people are (their backgrounds, experience levels, team composition) rather than detailing specific processes. The first two sentences are about the people.

The third sentence describes what they do but in general terms. Looking at the grammatical subjects - "leaders from Information Security, Compliance, Legal and Internal Auditing teams" and "Such individuals" and "These individuals" - this is clearly about management personnel, their qualifications and experience, not about specific processes or frameworks. So this falls under Management Role.

For specificity, I've got two concrete facts here: the specific team composition across those four departments, and the quantified experience level of over 20 years on average. These are both eligible as IS list items.

Now checking the QV threshold - "over 20 years" is definitely a specific number that counts as QV-eligible. But the team composition, while firm-specific, doesn't qualify as QV per the rules since team compositions don't count toward that metric. That gives me only one QV-eligible fact when I need two, so this lands at Firm-Specific level.

fact: Leaders from Information Security, Compliance, Legal and Internal Auditing teams

fact: Average of over 20 years of prior work experience


reasoning: The paragraph makes an explicit materiality assessment ('have materially affected us' and 'reasonably likely to materially affect us'), which per Rule 6 is Strategy Integration regardless of the appended cross-reference to Risk Factors. No firm-specific facts are present — 'December 31, 2023' is a standard fiscal year-end, and the cross-reference heading is not a cybersecurity-specific fact.

thinking: Materiality assessment paragraph with cross-reference.


specificity_confidence: medium

reasoning: The paragraph describes the incident escalation and reporting process: cybersecurity status → senior management → Incident Response Team → BCC → CLO → Audit Committee → Board. While multiple roles and reporting lines are named, the person-vs-function test indicates this is about the escalation process itself rather than any individual's credentials or background. The Business Continuity Coordinator ('BCC') designation with its unique abbreviation qualifies as a firm-specific fact, but no QV-eligible hard facts (dates, dollar amounts, named third-party firms, named tools) are present.

thinking:
Let me analyze this paragraph.

Content: Describes reporting chain for cybersecurity status - senior management, incident reports, Incident Response Team, Business Continuity Coordinator (BCC), business continuity plan, compliance reports, then BCC reports to CLO who reports to Audit Committee and board.

Category: This is about the reporting structure and incident escalation process. The primary content is about how information flows - from cybersecurity status → senior management → Incident Response Team → BCC → CLO → Audit Committee/Board.

The paragraph describes processes (incident reporting, escalation, compliance reports) and reporting lines.

Now I'm trying to determine whether this is primarily about management roles or risk management processes. The BCC's function here is more about the escalation pathway than the person in the role itself. Looking at the grammatical structure, the subjects are the cybersecurity status, incidents, and the IRT - all flowing through a chain that ultimately reaches the board. The dominant pattern is the escalation process, though the structural reporting lines from BCC up through CLO to the board suggest governance elements as well. I'm seeing the tension here—the paragraph lists multiple process steps like incident reporting, escalation to the incident response team, and compliance reporting, but it also heavily emphasizes the reporting structure itself: BCC reports to CLO, who reports to the Audit Committee and board. The reporting lines feel like the core organizational content rather than just supporting details for the process. I think Management Role is the right fit because the paragraph is fundamentally defining who holds responsibility and how authority flows through the organization.

Now I'm evaluating whether specific roles should be flagged as list items. BCC is clearly a firm-specific title with its own abbreviation, which suggests it belongs on the list. CLO is just a standard C-suite position, so that doesn't qualify. The Incident Response Team and business continuity plan are too generic. BCC stands out as the only named internal role with a unique identifier that isn't a standard cybersecurity title.

Actually, I need to reconsider the main category here. The paragraph describes an escalation process, but the core content is really about the reporting structure and who holds what responsibility. That points toward Management Role rather than Risk Management Process. The roles themselves—BCC and CLO—are the focus, not the abstract process.

So my final categorization: Management Role with Firm-Specific designation, since BCC is the only element that qualifies as a named internal program with a unique identifier. No QV facts are present.

fact: Business Continuity Coordinator ('BCC') — named role with unique abbreviation leading the Incident Response Team


reasoning: The paragraph describes management's responsibilities for cybersecurity, making management the grammatical subject throughout. However, applying the person-vs-function test, this is borderline — it describes what management does (functions/responsibilities) rather than who the people are. Still, the primary framing is about management's role and responsibilities rather than specific processes or tools, so Management Role is the best fit. No specific facts are present — 'management team' is generic, no named roles, no frameworks, no dates.


reasoning: This paragraph is a cross-reference directing the reader to Item 1A Risk Factors for cybersecurity risk descriptions. While it uses the phrase 'may materially affect us,' it does not itself make a materiality assessment or conclusion — it merely points elsewhere for the substance. Per the codebook, a pure cross-reference with no standalone materiality conclusion is None/Other.

thinking:
This is a cross-reference paragraph pointing to Risk Factors. But it does say "risks from cybersecurity threats that may materially affect us and how they may do so" — does this constitute a materiality assessment?

Looking at the codebook: "Only a pure cross-reference with no materiality conclusion is None/Other." And "does the paragraph make a substantive claim about cybersecurity's impact on the business? If yes → Strategy Integration. If it only points elsewhere → None/Other."

This paragraph says "For a description of the risks... that may materially affect us... see our risk factors." It's pointing the reader elsewhere for the description.

The key distinction is that it doesn't actually conclude whether cybersecurity risks have or haven't materially affected the business — it just uses "materially" as a descriptor while directing readers to the Risk Factors section. That makes this a pure cross-reference, so it's None/Other.


reasoning: The Audit Committee is the grammatical subject throughout — appointed by the Board to oversee cybersecurity, receiving CISO briefings, reviewing third-party reports, and receiving internal audit observations. This is Board Governance. QV-eligible hard facts include the headcount ('Two Company Directors'), the named institution (Carnegie Mellon CERT program), and the named certification (CERT designation), meeting the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content Category: The Board's Audit Committee is the primary subject - appointed to oversee cybersecurity, board member expertise, receiving reports. The grammatical subject throughout is the Audit Committee (a board committee). → Board Governance

Specific facts:
- NACD/Carnegie Mellon CERT cyber-risk oversight program - named program
- CERT designation - named certification
- Two directors completed the program - quantified
- CISO provides quarterly updates - CISO is a cybersecurity-specific role
- NIST framework - named framework
- Key performance indicators, phishing campaigns, tabletop exercises - generic practices

- Two Company Directors completed the program (headcount), Carnegie Mellon CERT (named institution and program), and CERT designation (named certification) - these are all QV-eligible facts. That gives me at least two hard verifiable elements, so this qualifies as Quantified-Verifiable.

fact: Two Company Directors completed the NACD/Carnegie Mellon CERT cyber-risk oversight program

fact: CERT designation earned by two directors

fact: CISO provides quarterly updates to the Audit Committee

fact: NIST framework

fact: National Association of Corporate Directors/Carnegie Mellon CERT program


reasoning: The paragraph's primary frame is the Audit Committee and Board of Directors' oversight of cybersecurity risk, including how they receive briefings and CIO reports. While the CIO's experience is mentioned in the final sentence (Management Role content), the dominant communicative purpose is how the board-level entities oversee cyber risk — the CIO reporting is subordinate to the Audit Committee's oversight function. Specificity is Firm-Specific: CIO is a cybersecurity-specific title (IS list), and 'over 20 years' is a specific number, but only 'over 20 years' is QV-eligible (named roles don't count toward QV), so only one QV fact prevents reaching Quantified-Verifiable.

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

The paragraph covers multiple topics:
1. Executive team + Audit Committee considers cyber risk as part of business strategy/financial planning
2. Board/Audit Committee briefed on cybersecurity risks annually
3. CIO reports to Audit Committee - describes what the report covers
4. CIO's experience - "over 20 years"

Dominant category: This is tricky. Let me apply the rules.

The paragraph has:
- Strategy integration element (first sentence about business strategy, financial planning, capital allocation)
- Board governance element (Audit Committee/Board briefed annually)

- Management Role element (CIO reports, CIO's 20 years experience)
- Risk Management Process element (the topics covered in the report)

The grammatical subjects shift: "executive team + Audit Committee" → "Audit Committee and Board" → "CIO" → "CIO"

The bulk of the paragraph is about the CIO's reporting to the Audit Committee and the CIO's background. But the reporting content describes processes. Let me think about dominant category.

The first sentence is about strategy integration (cybersecurity as part of business strategy/financial planning/capital allocation). The second sentence is board governance. The third sentence describes the CIO reporting to the Audit Committee - this is a mix of board governance (receiving reports) and management role (CIO is the subject). The fourth sentence is management role (CIO's background).

So I'm looking at a paragraph that weaves together strategy integration, board governance, and management role elements. The CIO's reporting and experience dominate the latter half, but the opening establishes cybersecurity as a strategic priority. I'd say this leans toward board governance with strong management role components, since the Audit Committee is receiving regular briefings and reports from the CIO. I'm settling on Board Governance as the primary category since the paragraph's structure centers on how the Audit Committee oversees cybersecurity, with the CIO's reporting role being secondary to that oversight function. For the specificity assessment, the CIO title and "over 20 years" are the QV-eligible facts here, though the named role itself doesn't count toward the threshold.

fact: Chief Information Officer

fact: over 20 years of experience in senior IT/information security roles


reasoning: The paragraph primarily describes the company's internal process of integrating cybersecurity into its enterprise risk management program, with annual review. The Board mention is subordinate (results are presented to the Board) rather than the Board being the primary actor. No named frameworks, specific roles, dates, or other firm-specific facts are present — all language is generic boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes integrating cybersecurity into ERM program, annual review, results presented to Board. The primary content is about the company's internal risk management processes. The Board mention is subordinate - it's where results go, not the primary actor.

Category: Risk Management Process - describes ERM integration, annual review cycle.

Specificity: No named frameworks, no named roles (just "the Board" which is generic), no specific dates, no named tools. "annually" is generic cadence. This is Generic Boilerplate.


reasoning: The paragraph describes the TRCC, a management-level governance committee (not a board committee), its composition (CISO + senior stakeholders), its chair appointment process, and its reporting relationship to the ERC. The primary communicative purpose is to describe the management governance structure for cybersecurity oversight — who sits on the committee, how it is constituted, and its mandate. While it touches on what the committee does, the dominant content is organizational structure and management role definition. Multiple named non-generic committees (TRCC, ERC) and the CISO role make this Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, headcounts, named third-party firms, named tools) are present.

thinking:
Let me analyze this paragraph.

Content: Describes TRCC (a management risk governance committee), its composition, chair appointment, members including CISO, and responsibilities for overseeing technology/cybersecurity risk management.

Category: This is about a management committee (TRCC) that oversees cybersecurity risk. The TRCC is a management-level committee (sub-committee of ERC), not a board committee. It describes the committee's composition and responsibilities. This is Management Role - it's about the organizational structure of management oversight, including reporting lines and committee composition. Actually, let me reconsider.

The paragraph focuses on what the TRCC actually does—overseeing risk management practices, maintaining tolerances, handling escalations and remediation—rather than just listing who sits on it. This is fundamentally about the committee's function and governance role within the organization, so it fits Management Role.

I'm also checking whether these are facts: TRCC and ERC are named non-generic committees, the CISO is a cybersecurity-specific title, and the head of Enterprise Risk Management is a named role. That gives me multiple IS facts to work with.

fact: TRCC (Technology and Cybersecurity Risk Committee) — dedicated management risk governance committee

fact: ERC (Enterprise Risk Committee) — firmwide committee that TRCC reports into

fact: CISO is a member of the TRCC

fact: Chair of TRCC is appointed by the head of Enterprise Risk Management


reasoning: The paragraph describes the company's internal process for identifying, assessing, and managing cybersecurity threats, with the third-party firm retained to serve the company's own risk management needs (not vendor oversight). Per Rule 3, an external firm hired to help the company is Risk Management Process. No cybersecurity-specific titles (CFO is generic C-suite per the NOT list), no named frameworks, no named firms or tools, and no specific dates or numbers — all references are generic ('third-party technology solutions firm,' 'IT Lead,' 'various methods and tools').

thinking:
Let me analyze this paragraph carefully.

Content: Describes how the company retains a third-party IT firm to manage cybersecurity, the reporting structure (IT Firm → IT Lead in finance/operations → management team/CFO), and what the IT Firm does (monitor, evaluate threat environment).

Category: This is about the company's risk management process - how they identify, assess, and manage cybersecurity threats. The third-party firm is a component of their internal process (they retained the firm to serve the company), not about vendor oversight. The reporting structure is incidental. Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." This is Risk Management Process.

I'm second-guessing myself on whether this could be Third-Party Risk, but the distinction is clear - the firm is engaged to help the company manage its own risks, not to oversee the vendor itself. The specifics here are sparse: the IT Firm is unnamed, the IT Lead is a generic title without cybersecurity focus, and the CFO is standard C-suite. The only concrete organizational detail is that the IT Lead sits within finance and operations, which is a structural element worth noting.

Looking at what's actually present - no named frameworks, no specific tools, no dates - this reads as Generic Boilerplate.


reasoning: The entire paragraph is about overseeing third-party service providers' cybersecurity risks — vendor risk assessments, security questionnaires, contractual obligations, and vendor selection policies. This is squarely Third-Party Risk. Despite being detailed in describing the vendor management process, it names no specific frameworks (NIST, ISO, SOC 2), no specific vendors, no dates, no numbers, and no cybersecurity-specific roles. The vendor types listed (application providers, hosting companies, CROs, CMOs) are generic. The assessment activities described (security questionnaires, vulnerability scans, contractual obligations) are common practices. Everything here could apply to any company with a vendor management program.

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


reasoning: The paragraph describes the company's internal risk assessment process — how cybersecurity threats are identified and assessed alongside other enterprise risks. The named 'Cybersecurity GRC' team with its distinguishing abbreviation is a firm-specific fact, but there is only one such fact, keeping it at Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the company's internal risk assessment process - GRC team, enterprise risk professionals, collaboration with subject matter specialists, identifying and assessing cybersecurity risks as part of overall risk assessment.

Category: Risk Management Process - describes internal processes for risk assessment, ERM integration.

Specific facts:
- "Cybersecurity Governance, Risk and Compliance ("GRC") team" - this is a named internal program/team with a unique identifier (GRC). This qualifies as a specific fact.

No named frameworks, no dates, no dollar amounts, no named third-party firms, no named tools.

The GRC team's specific name and identifier makes this a firm-specific fact, so it rates as a 3 on the specificity scale.


reasoning: This kitchen-sink paragraph spans multiple categories (board oversight, management credentials, incident response processes, materiality statement, insurance), but the dominant content describes the company's internal risk management approach: incident response strategy, roles/responsibilities, communication protocols, detection/response/recovery priorities, and monitoring processes. Management roles (CIO, Senior Director) and the board committee appear as attribution rather than primary content. Multiple firm-specific facts exist (CIO, Senior Director of Information Security, Cybersecurity Infrastructure Committee, 15 years of experience), but only one QV-eligible hard fact (15 years), so specificity is Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

This is a dense, multi-topic paragraph. Let me identify what's covered:

1. Audit and Risk Committee oversight - Board Governance
2. CIO, Senior Director of Information Security roles - Management Role
3. CIO's 15 years experience and degree - Management Role
4. Cybersecurity Infrastructure Committee meets monthly - could be Management Role or Risk Management Process
5. Incident response strategy - Risk Management Process
6. Past adverse IT events, no material impact - Strategy Integration
7. Cybersecurity insurance - Strategy Integration
8. Monitoring, testing, response processes - Risk Management Process

9. CIO reports to Audit and Risk Committee - Board Governance or Management Role

This paragraph is really a mix of governance structure, management qualifications, and operational processes. The CIO's reporting line to the Audit and Risk Committee ties back to the board oversight mentioned at the start, while the committee meetings, incident response strategy, and monitoring activities form the core of the risk management framework. The company's track record and insurance coverage round out the overall approach.

Looking at what actually dominates the text, Risk Management Process takes up the most space—the incident response plan, monitoring and testing protocols, detection and recovery procedures. But the management roles are woven throughout as the people executing those processes. The CIO's 15 years of experience and the specific committee structure ground this in concrete organizational details rather than generic descriptions.

Counting what qualifies as QV-eligible: the 15 years is a specific number, but the degree without a named university doesn't count, and the named roles and committee are firm-specific rather than QV-eligible. That leaves just one QV-eligible fact, so this lands as Firm-Specific (3).

The paragraph centers on the company's cybersecurity risk management approach with management attribution, though there's also a materiality statement and insurance mention that are secondary. Risk Management Process is the dominant category here.

fact: Chief Information Officer (CIO)

fact: Senior Director of Information Security

fact: Cybersecurity Infrastructure Committee that meets monthly

fact: CIO has 15 years of experience in cybersecurity

fact: degree in management information systems


reasoning: This paragraph describes a general trend of state-level cybersecurity regulation and the company's intent to monitor it. It names no specific regulations, describes no company processes or programs, and makes no materiality assessment. Per the codebook's Case 9 guidance, generic regulatory compliance language that doesn't describe what the company does to comply is None/Other.

thinking:
Classify this paragraph.

This is generic regulatory compliance language about state regulators implementing privacy/cybersecurity standards. No specific processes, no materiality assessment, no named regulations, no firm-specific details.

Per Case 9 in the codebook: "This acknowledges that regulations exist... It does not describe any process, program, or framework the company uses to comply. It does not make a materiality assessment. It names no specific regulation. → None/Other, Specificity 1."


reasoning: The paragraph describes the company's internal risk assessment methodology — annual assessments, risk register updates, identification and evaluation of threats, and review of existing safeguards. This is squarely Risk Management Process. No named frameworks, specific roles, dates, tools, or any facts from the IS list appear; the language is generic enough to apply to any company.

thinking:
Classify this paragraph.

Content: Describes risk assessment process - annual risk assessments, risk register updates, identification of risks, likelihood assessment, sufficiency of policies. This is about internal processes.

Category: Risk Management Process - describes the company's own internal risk assessment methodology.

Specificity: No named frameworks, no named roles, no specific dates, no named tools. "Annual risk assessments" and "risk register" are common practices. Nothing firm-specific from the IS list. → Generic Boilerplate.


reasoning: Management Role because the paragraph's primary content is the VP Head of Technology's qualifications (20+ years experience, CISM credential) and responsibilities. Quantified-Verifiable because two QV-eligible hard facts are present: a specific duration ('over 20 years') and a named individual certification ('CISM').

thinking:
Let me analyze this paragraph.

The paragraph is about the Vice President, Head of Technology - their experience, credentials, and what they do. Let me apply the person-vs-function test.

Content: Describes the VP Head of Technology's 20 years of experience, CISM certification, and responsibilities. The paragraph is primarily about WHO this person is and their qualifications. While the last sentence mentions monitoring/prevention/detection activities, these are described in the context of what the person does, and the bulk is about credentials.

Category: Management Role - the paragraph is about the person's qualifications, experience, and credentials.

Specificity:

The title itself is firm-specific, and I'm finding two concrete verifiable facts here: the "over 20 years" duration and the "CISM" certification, which gives me two hard data points that qualify as Quantified-Verifiable.

fact: Vice President, Head of Technology

fact: over 20 years of experience

fact: Certified Information Security Manager (CISM)


reasoning: The paragraph describes the company's internal cybersecurity risk management activities — monitoring, automated tools, audits, threat assessments, vulnerability assessments, tabletop exercises — making it squarely Risk Management Process. Despite the lengthy enumeration of practices, none are named products/tools (just generic categories like 'intrusion detection,' 'DDoS protection'), no frameworks are named, no firm-specific roles beyond generic 'officers' and unnamed 'IT vendors' appear, and no dates or numbers are provided. Everything listed is common practice language that could apply to any company.

thinking:
Let me analyze this paragraph.

Content: Describes how the company manages, identifies, and assesses cybersecurity risks - monitoring, tools, audits, assessments, etc. The "officers and IT vendors" is brief attribution. The bulk is about internal processes.

Category: Risk Management Process - this is clearly about internal cybersecurity processes, tools, and methodologies.

Specificity: Let me check for specific facts:
- No named frameworks (NIST, ISO, etc.)
- No named roles (just "officers" and "IT vendors" - both generic)
- No named tools/products - just generic categories (monitoring, geolocation, remote wiping, etc.)

- No dates, dollar amounts, headcounts, or named firms
- Mentions machine learning but only in generic terms
- Lists standard practices like audits, threat assessments, vulnerability assessments, and tabletop exercises

This is all boilerplate language with no concrete details or named standards.


reasoning: This paragraph is introductory business language acknowledging the importance of cybersecurity and IT dependence. It contains no substantive disclosure — no processes, frameworks, governance structures, roles, incidents, or materiality assessments are described. Statements like 'we recognize the importance of' and 'our business depends on' are generic preamble that could apply to any company, with no actual cybersecurity program content disclosed.

thinking:
Let me analyze this paragraph from LSB Industries' 10-K filing.

The paragraph is general language about recognizing the importance of cybersecurity and dependence on IT systems. It doesn't describe any specific processes, frameworks, roles, or incidents. It's generic business language about cybersecurity importance.

This is essentially introductory/contextual language. No specific facts, no frameworks, no roles, no incidents. It mentions "third parties" and "Board" but only incidentally.

Category: None/Other - This is general business language about the importance of cybersecurity. It doesn't describe any program, process, governance structure, or make a materiality assessment. It's introductory boilerplate.

I'm reconsidering whether this could fit Risk Management Process since it mentions "developing, implementing, and maintaining robust cybersecurity measures," but it's really just acknowledging the importance without describing what they actually do. The language is too vague and lacks substantive disclosure content, so None/Other is the right call.

Specificity: Generic Boilerplate (1) - no specific facts whatsoever.


reasoning: The paragraph describes how the Audit Committee receives cybersecurity updates and quarterly reports covering program assessments, developments, and mitigation strategies — this is board-level oversight via briefing cadence and content. Although 'our cybersecurity team' is the grammatical subject, the communicative purpose is to describe the board's oversight mechanism. No firm-specific facts survive the NOT-list filter: 'Audit Committee' is generic governance, 'quarterly' is a generic cadence, 'cybersecurity team' is not a named cybersecurity-specific role, and 'third-party assessments' are unnamed.

thinking:
Let me analyze this paragraph.

The grammatical subject is "Our cybersecurity team" - they update the Audit Committee. The primary action is reporting TO the board committee. This is about board oversight - the Audit Committee receiving reports. But the subject is the cybersecurity team...

Actually, the paragraph describes the flow of information from the cybersecurity team to the Audit Committee. The primary communicative purpose is about how the Board (via Audit Committee) maintains oversight - through regular updates and quarterly reports. The board/committee is the recipient of oversight information.

Per Rule 2: "Board delegates responsibility to management" → Board Governance. But here management is reporting to the board.

So the question is whether this is Management Role or Board Governance. The cybersecurity team is the primary actor doing the reporting, which points to Management Role. But the content focuses on the oversight mechanism and what the board receives, which feels more like Board Governance. The paragraph doesn't name a specific role like CISO - it's just "our cybersecurity team" - and it emphasizes the reporting cadence and content that the Audit Committee receives. That oversight mechanism is really the heart of what's being described here.

Looking at the specificity: generic team reference, no named roles, no specific frameworks or dates, just a quarterly cadence and unnamed third-party assessments. This reads as generic boilerplate about board-level briefings rather than a substantive governance or management practice.


reasoning: The paragraph describes the company's internal cybersecurity risk management program — protecting confidentiality/integrity/availability, strategic investments in people/processes/technology, and ERM integration. The Audit Committee mention is brief and subordinate to the process description. No named frameworks, no cybersecurity-specific roles, no specific dates or numbers — all language is generic boilerplate that could apply to any company.

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity risk management program - comprehensive approach, protecting confidentiality/integrity/availability, investments in people/processes/technologies, integrated into overall risk management, reviewed by Audit Committee.

Category: This is primarily about the company's internal cybersecurity risk management processes. The Audit Committee mention is brief and subordinate. → Risk Management Process

Specificity: Let me check for specific facts:
- "Audit Committee" - on the NOT list (generic governance)
- "Board of Directors" - on the NOT list

- "at least annually" - generic cadence
- No named frameworks, no named roles (CISO etc.), no specific dates, no named tools, no numbers

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


reasoning: The paragraph describes the company's internal cyber risk management process — prevention, detection, mitigation, remediation, and investment in IT protection resources. While it names an SVP of Operations and VP/Deputy General Counsel, the person-vs-function test shows the paragraph is about what the program does, not about the individuals' qualifications or backgrounds. Neither 'SVP, Operations' nor 'VP, Deputy General Counsel' are cybersecurity-specific titles on the IS list (they are general corporate roles), and no named frameworks, tools, firms, dates, or specific numbers appear, leaving no qualifying specific facts.

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

Content: Describes cyber risk management process, mentions SVP Operations who manages it, mentions VP Deputy General Counsel working on cybersecurity strategy. Describes investments in IT protection.

Category: The paragraph starts by describing the cyber risk management process. It mentions SVP Operations and VP Deputy General Counsel, but the bulk is about what the process does - prevent, detect, mitigate, remediate threats, invest in resources, protect IT systems. The person-vs-function test: removing the titles, the paragraph still describes processes and investments. → Risk Management Process

Specific facts:

- SVP Operations and VP Deputy General Counsel are mentioned, but neither holds a cybersecurity-specific title according to the IS list (which includes CISO, CTO, CIO, VP of IT/Security, and similar roles)
- No named frameworks, dates, tools, firms, or specific numbers are provided
- The paragraph focuses on describing the cyber risk management process itself rather than highlighting cybersecurity expertise or governance structures

The activities described—preventing, detecting, mitigating, and remediating threats, plus investing in resources and protecting IT systems—are all generic industry language without concrete examples or differentiation. This reads as boilerplate cybersecurity messaging rather than substantive detail about the organization's actual approach.


reasoning: The paragraph contains an explicit materiality assessment ('not reasonably likely to materially affect us, our business strategy, results of operations or financial condition'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. No specific facts—dates, amounts, named firms, or firm-specific details—are present; the language is standard boilerplate materiality disclaimer.

thinking:
Materiality assessment + cross-reference. The paragraph explicitly assesses materiality ("not reasonably likely to materially affect us, our business strategy, results of operations or financial condition") → Strategy Integration per Rule 6. The cross-reference doesn't change this.

Specificity: boilerplate materiality language, no specific facts. Generic Boilerplate.


reasoning: The paragraph opens with the Director of IT and Security's experience but is primarily about what the CSIRT team does — executing risk assessments, reviewing incident response plans, compliance, training, and risk management. Applying the person-vs-function test: removing the Director's title and experience, the paragraph still describes the team's processes. The 40 years of experience is one QV-eligible fact and the cybersecurity-specific role title is one IS-list fact, but only one QV-eligible item exists, so specificity is Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the Director of IT and Security leading the CSIRT team, their experience, and what the team does (risk assessment, incident response, compliance, training, risk management). Also mentions the Board briefly.

Category: The paragraph starts with the Director of IT and Security's experience (person detail - 40 years), but then shifts to describing what the CSIRT does (processes). Let me apply the person-vs-function test: if I remove the Director's title and experience, the paragraph still describes what the CSIRT does. But the opening clause is about the person (40 years of experience).

Looking more carefully at the structure, the opening attribution to the Director is really just a framing device—the substance of the paragraph is all about the CSIRT's functions: risk assessment, incident response, compliance, training, and risk management. The Director's 40 years of experience is mentioned, but the paragraph's weight is on describing what the team actually does. The "Director of IT and Security" role qualifies as a cybersecurity-specific title on the IS list, while the 40 years of experience is the only QV-eligible fact here since named roles don't count toward that threshold. With just one quantified fact, this falls into Firm-Specific rather than QV classification.

fact: Director of Information Technology and Security ('Director of IT')

fact: over 40 years of experience in Information Technology


reasoning: The Audit Committee is the grammatical subject receiving cybersecurity reports, making this Board Governance. No firm-specific facts are present: 'audit committee' is standard at every public company, 'quarterly' is a generic cadence, and the listed report topics (risk management practices, vulnerability assessments, third-party reviews, threat environment) are all common practices that appear on the IS-NOT list.

thinking:
Classify this paragraph.

The Audit Committee is the grammatical subject, receiving reports on cybersecurity. This is Board Governance.

Specificity: "audit committee" is generic, "quarterly" is generic cadence. The list of topics (risk management practices, vulnerability assessments, third-party reviews, threat environment, etc.) are all generic. No named frameworks, no firm-specific facts.

Generic Boilerplate.


reasoning: The paragraph describes the company's own internal incident response program, escalation protocols, and severity assessment process — all internal cybersecurity processes. Third-party service providers are mentioned as one component, not the central topic. No named frameworks, roles, firms, tools, dates, or specific numbers appear; all language is generic and interchangeable across filings.

thinking:
Let me analyze this paragraph.

Content: Describes incident response program, escalation protocols, severity assessment, and third-party relationships for containment/remediation. This is about internal processes.

Category: Risk Management Process - describes the company's own internal IR program, escalation protocols, severity assessment. Third-party mention is incidental (one component).

Specificity: Let me check for specific facts.
- No named frameworks
- No cybersecurity-specific titles (just "designated personnel")
- No named firms ("a number of third-party service providers")
- No dates, numbers, tools
- "incident response program" is generic

- "escalation protocols" is generic

Everything here is generic boilerplate language. → Generic Boilerplate (1)


reasoning: The paragraph is overwhelmingly about the people responsible for cybersecurity — their names, career histories, credentials, and backgrounds. Katherine Dowling and Hong Kim are identified by name with detailed professional histories. Multiple QV-eligible hard facts: specific date (since 2015), specific duration (ten years), named university (University of Pennsylvania), named firm (Google), and named product (Google Drive).

thinking:
Let me analyze this paragraph carefully.

This is about a Trust (crypto ETF) that has no employees, with management delegated to a Sponsor. The paragraph describes two named individuals and their qualifications:

1. Katherine Dowling - General Counsel, Chief Compliance Officer, VP of Sponsor - responsible for cybersecurity risks. Background: CCO since 2015, 10+ years as Assistant U.S. Attorney, Economic Crimes Unit, Northern District of California.

2. Hong Kim - CTO of Bitwise. Background: University of Pennsylvania, BS in Computer Science, worked on Google's backend infrastructure for Google Drive, software security for South Korean military.

Now I'm evaluating which details are substantive and verifiable. The CTO designation is a specific role tied to cybersecurity, Katherine's Chief Compliance Officer title appears on the relevant list, and I can point to concrete facts like her tenure since 2015, her decade-plus background in economic crimes prosecution, Hong's degree from University of Pennsylvania, and his experience with Google's infrastructure and military security work.

fact: Katherine Dowling named as General Counsel, Chief Compliance Officer and VP

fact: Hong Kim named as Chief Technology Officer of Bitwise

fact: CCO since 2015

fact: More than ten years of experience as Assistant U.S. Attorney

fact: Economic Crimes Unit of the U.S. Attorney's Office for the Northern District of California

fact: South Korean military software security


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected or are reasonably likely to materially affect our business strategy, results of operations, or financial condition'), making it Strategy Integration per Rule 6. The appended cross-reference to Risk Factors does not change the classification. No specific facts are present — the language is boilerplate materiality disclaimer.


reasoning: The paragraph describes the company's internal cybersecurity processes (identify, assess, manage risks) covering various systems and data types. This is about the function/program, not any person, board, or third-party oversight. No named frameworks, specific roles, dates, or firm-specific facts are present — the language is generic and could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity program components — a security team managing risk assessments, security controls, and incident response, plus employee awareness training. These are all internal processes, making this Risk Management Process. No named frameworks, cybersecurity-specific roles, dates, tools, or other specific facts appear; 'security team' is generic, and the practices listed (risk assessment, controls, training) are common boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes internal cybersecurity program components - security team managing risk assessment, security controls, incident response, and employee training. Ends with a generic disclaimer.

Category: Risk Management Process - describes the company's own internal processes (risk assessment, security controls, incident response, training).

Specificity: Let me check for specific facts.
- "security team" - generic, not a named role
- "cybersecurity risk assessment processes" - generic practice
- "security controls" - generic

- "response to cybersecurity incidents" - generic
- "employee cybersecurity awareness training" - generic practice
- "upon onboarding" - slightly specific timing but not a named standard or firm-specific fact

No named frameworks, no named roles (CISO etc.), no dates, no numbers. This is Generic Boilerplate.


reasoning: The paragraph's primary communicative purpose is describing the company's own cybersecurity program assessment methodology (collaborating with third parties to assess effectiveness against NIST). The second sentence about considering third-party service providers' risk programs is a component of the overall internal risk management approach, not a central discussion of vendor oversight requirements imposed on vendors. Per Rule 3, third parties mentioned as one component of an internal program → Risk Management Process. NIST is a named standard triggering Sector-Adapted, but no firm-specific facts (third parties are unnamed, no specific roles, dates, or tools).

thinking:
Let me analyze this paragraph.

Content: Two sentences. First describes collaborating with third parties to assess their program against NIST. Second describes considering third-party service providers' risk programs.

Category: The first sentence is about using third parties to assess their own program (Risk Management Process - external assessor serving the company). The second sentence is about oversight of third-party providers (Third-Party Risk). The paragraph splits between RMP and Third-Party Risk. The first sentence is about assessing the company's own program effectiveness using external help and NIST framework. The second is about vendor oversight. Mixed, but I'd say the dominant theme leans toward Risk Management Process since the first sentence is about their own program assessment, and the second sentence mentions considering third-party providers as a component.

Per Rule 3, third parties mentioned as one component of an internal program point toward Risk Management Process. The paragraph really centers on assessing their cybersecurity risk program, with third-party involvement as part of that evaluation process. I'll categorize this as Risk Management Process.

Specificity: NIST framework is explicitly named, which indicates Sector-Adapted at Level 2. The language around third parties is generic without specific vendor names or roles. No firm-specific details from the IS list are present.

fact: NIST cybersecurity framework


reasoning: The paragraph describes the company's internal cybersecurity processes: risk management framework, ISO certification scope, incident response procedures, and internal reporting chains. The CTO and Board are mentioned as attribution but the substantive content is about what the program does and how it operates — passing the person-vs-function test for Risk Management Process. Specificity is Firm-Specific: the company holds ISO 27001:2013 certification (a verifiable firm fact beyond merely naming the standard), the CTO is a cybersecurity-specific role, and the ISMS scope references firm-specific operational infrastructure. However, no two QV-eligible hard facts (dates, dollar amounts, named third-party firms, named tools) are present, so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content Category: This describes the company's internal cybersecurity processes - risk management framework, ISO certification, incident response procedures, remediation plans. The CTO is mentioned but as attribution, not as the focus. The paragraph is about what the program does, not about the person. → Risk Management Process

Specific facts:
- CTO (cybersecurity-specific title) → named_role
- ISO 27001:2013 certification (they hold it, not just name it) → other_specific
- ISMS with specific scope (satellite command and control, data uplink/downlink, ground stations) → other_specific

- IT Security Team and Legal and Compliance teams are mentioned as part of the organizational structure, though these are more generic team names rather than uniquely identifiable entities. Now I'm checking whether the ISO 27001:2013 certification qualifies as QV-eligible—it's an organizational certification rather than one held by an individual, which makes it less clear-cut against the QV criteria, but it's still a verifiable, named certification that demonstrates a specific security standard.

The CTO role is a firm-specific cybersecurity title, and the detailed scope of their ISMS covering satellite command and control, data pipelines, and ground stations provides operational specificity. The team composition breakdown also counts as firm-specific detail. But looking at what actually qualifies for QV—specific dates, dollar amounts, headcounts, named third-party firms, named products, or individual certifications—I'm not finding the two or more QV-eligible facts I need here.

fact: Chief Technology Officer (CTO) reviews cybersecurity risk management

fact: ISO 27001:2013 certification held (not just named)

fact: ISMS scope includes satellite command and control, data uplink/downlink pipelines, and ground stations

fact: IT Security Team reports to Legal and Compliance teams (specific departmental composition)


reasoning: The paragraph makes an explicit materiality assessment — no material breach, immaterial expenses, no cybersecurity risks reasonably likely to materially affect the business. Per Rule 6, materiality disclaimers are Strategy Integration even when boilerplate. The appended cross-reference to Risk Factors does not change the classification. No specific facts from the IS list are present; all language is generic boilerplate.

thinking: Materiality assessment paragraph.


reasoning: The paragraph identifies the management team responsible for cybersecurity (CFO, VP of Finance, SVP of Legal/General Counsel, VP of Quality), describes their collective experience, and explains how they monitor cybersecurity incidents — this is about the people leading the program, not the program's processes. However, none of the listed roles are cybersecurity-specific titles from the IS list (they are generic corporate titles: CFO and General Counsel are explicitly on the NOT list), no individuals are named, experience is described only as 'significant' without specifics, and no frameworks, dates, or verifiable facts appear, resulting in Generic Boilerplate.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph describes who leads the cybersecurity risk management processes. Let me apply the person-vs-function test.

The paragraph names specific roles (CFO, VP of Finance, SVP of Legal/General Counsel, VP of Quality) and describes their collective experience and what they monitor. The primary content is about WHO these people are (their titles, their experience) and what they do in terms of oversight.

However, looking more carefully: the roles listed (CFO, VP of Finance, General Counsel, VP of Quality) are NOT cybersecurity-specific titles.

These are generic C-suite and management positions, so the paragraph is really identifying the management team that oversees cybersecurity. When I strip away the titles and credentials, what remains is still fundamentally about the people leading these efforts—their roles, their qualifications, and their monitoring responsibilities. This is clearly Management Role content.

Looking at the specifics: CFO, VP of Finance, SVP of Legal/General Counsel, and VP of Quality are all on the generic corporate titles list, not cybersecurity-specific roles like CISO or VP of IT/Security. The qualifications are vague—just "significant prior work experience"—with no named frameworks, specific dates, tools, or numbers. There's nothing firm-specific here after filtering out the boilerplate language. This is Generic Boilerplate.


reasoning: The paragraph contains an explicit materiality assessment ('such risks have not materially affected us, including our business strategy, results of operations or financial condition'), which per Rule 6 makes this Strategy Integration regardless of the appended cross-reference to Risk Factors. The brief mention of past threats/breaches is incidental and not a detailed incident narrative. No named frameworks, specific dates, cybersecurity-specific roles, named firms, or other facts from the IS list appear — all language is boilerplate.

thinking:
Let me analyze this paragraph.

Content: Contains a materiality assessment ("such risks have not materially affected us, including our business strategy, results of operations or financial condition"), mentions past threats/breaches briefly, and has a cross-reference to Risk Factors.

Category: The materiality assessment is the primary substantive content. Per Rule 6, materiality disclaimers → Strategy Integration. The cross-reference doesn't change this.

Specificity: No named frameworks, no specific dates, no named firms/tools, no cybersecurity-specific roles.

The materiality language here is just standard boilerplate—it's the kind of generic disclaimer you see across most filings, so this falls under Generic Boilerplate.


reasoning: This paragraph discusses how cybersecurity threats could 'adversely affect our business, financial condition, and results of operations' — framing cyber risk in terms of business/financial impact. However, it lacks an explicit materiality assessment and reads more like generic risk language. It borders on None/Other (generic risk factor language) but does make a substantive claim about business impact of cyber risk, fitting Strategy Integration. No specific facts, frameworks, roles, or dates are present.


reasoning: The paragraph describes CSB's internal cybersecurity controls — layered defense, preventative/detective tools, monitoring, and alerts — all of which are the company's own risk management processes. No named frameworks, tools, roles, dates, or quantified facts are present; every phrase ('layered defensive approach,' 'preventative and detective tools,' 'advanced persistent threats') is generic language that could apply to any financial institution.

thinking:
Classify this paragraph.

Content: Describes CSB's internal cybersecurity approach - layered defense, preventative/detective tools, monitoring, alerts, securing confidential information. This is about the company's own internal processes.

Category: Risk Management Process - describes internal cybersecurity processes, tools, monitoring approach.

Specificity: No named frameworks, no named tools, no named roles, no specific dates, no numbers. Everything is generic - "layered defensive approach," "preventative and detective tools," "suspicious activity." All generic boilerplate.


reasoning: This paragraph describes a hypothetical data breach risk in generic terms — no actual incident, no process description, no framework, no materiality assessment. It reads as general risk language that could apply to any company. While it touches on cybersecurity, it contains no substantive disclosure content — no program details, no governance structure, no specific actions taken. It functions as generic risk acknowledgment rather than meaningful cybersecurity disclosure.


reasoning: The paragraph describes the company's own incident response planning process, its integration into ERM, and its scope of application — all hallmarks of Risk Management Process. The named program 'Cybersecurity Incident Response Plan (IRP)' with a distinguishing abbreviation qualifies as a firm-specific fact per the IS list, but there is only one such fact, so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes a named internal program (IRP), its purpose, integration into ERM, and scope of application. This is about the company's own internal processes.

Category: Risk Management Process - describes incident response planning, ERM integration, scope of the program.

Specific facts:
- "Cybersecurity Incident Response Plan (the 'IRP')" - named internal program with unique identifier → IS list item

No named frameworks (NIST, ISO), no dates, no dollar amounts, no named firms, no headcounts, no named roles (CISO etc.).

The IRP with its abbreviation is a firm-specific item, so this qualifies as a single Firm-Specific fact and doesn't meet the threshold for QV.

fact: Cybersecurity Incident Response Plan (the 'IRP') — named internal program with unique identifier


reasoning: The SVP of IT is the grammatical subject performing the primary action (providing briefings to senior management). The paragraph describes this role's communication responsibilities rather than credentials or processes. 'SVP of IT' qualifies as a cybersecurity-adjacent leadership title analogous to 'VP of IT/Security' on the IS list, yielding one firm-specific fact but no second QV-eligible fact.

thinking:
Let me analyze this paragraph.

Content: The SVP of IT provides briefings to senior management on cybersecurity matters.

Category: The grammatical subject is "The SVP of IT" - a management role. The paragraph describes what this person does (provides briefings). But is it about the person or the function? It's about what the role does - providing briefings. However, it's really about the management role's activities in briefing senior management. The person is the subject performing the action. This is about the management role's function of briefing senior management.

Actually, let me reconsider. The person-vs-function test: if I remove "The SVP of IT" and replace with "the Company," does it still make sense? "The Company provides periodic briefings for our senior management team on cybersecurity matters..." - that's a bit odd but works.

The paragraph focuses on the briefing activity itself rather than the SVP's background or qualifications. Since it's describing a management role's communication and reporting function to senior leadership, this fits the Management Role category—the SVP of IT is the grammatical subject performing a key oversight function.

Looking at the specificity now: "SVP of IT" is a cybersecurity-adjacent title that aligns closely with the IS list's "VP of IT/Security," so I'd classify this as a cybersecurity-specific title variant. With just this one verifiable fact, it's Firm-Specific.

fact: SVP of IT


reasoning: The paragraph describes how cybersecurity risk assessment is integrated into the enterprise risk management program and how management prioritizes and mitigates threats. Although COO and General Counsel are named as participants, these are generic C-suite titles (NOT list), not cybersecurity-specific roles, and the paragraph is about the process/function rather than the people — it describes what the risk management process does, not who the individuals are. No named frameworks, no firm-specific facts from the IS list remain after validation.

thinking:
Let me analyze this paragraph.

Content: Describes integration of cybersecurity risk into ERM, mentions COO and General Counsel working with management to prioritize risk management, COO reports to audit committee.

Category: This is about the company's internal risk management processes - how they assess and manage cybersecurity risks, ERM integration. The COO and General Counsel are mentioned but they're generic C-suite roles (on the NOT list). The paragraph describes what the process does, not who the people are. → Risk Management Process

Specificity: Let me check facts:
- "Chief Operating Officer" - generic C-suite, NOT list

- "General Counsel" - generic C-suite, NOT list
- "audit committee" - generic, NOT list
- "enterprise risk management program" - generic program name, NOT list

No named frameworks, no firm-specific facts from the IS list. This is Generic Boilerplate.


reasoning: The audit committee of the Board of Trustees is the grammatical subject performing oversight—receiving reports and presentations on cybersecurity risks. The mention of Apollo's CSO/CISO is a cybersecurity-specific role (IS list), making this Firm-Specific. However, 'audit committee,' 'at least annually,' and 'vulnerability assessments' are all generic/NOT-list items, and there is only one QV-eligible fact, so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: The audit committee receives reports from management and service providers, including presentations from Apollo's CSO or CISO on cybersecurity topics. This is about board/committee oversight.

Category: Board Governance - the audit committee is the grammatical subject performing oversight, receiving reports and presentations.

Specificity analysis:
- "audit committee" - generic, NOT list
- "Board of Trustees" - generic governance
- "Apollo's CSO or CISO" - CSO/CISO are cybersecurity-specific titles → IS list item
- "at least annually" - generic cadence

- "vulnerability assessments" - common practice
- "third-party and independent reviews" - unnamed entities

The CSO/CISO role is Apollo-specific and cybersecurity-focused, so that counts as one IS fact. There are no QV-eligible facts here—no specific dates, dollar amounts, headcounts, or named third-party firms. Apollo itself is the adviser, not a third-party firm in the QV sense, and no named tools are mentioned.

→ Firm-Specific (3)

fact: Apollo's CSO or CISO provides presentations to audit committee