fact: World Gold Council

reasoning: The paragraph answers 'How does the board oversee cybersecurity?' by describing how the Board of Directors receives reports from the Sponsor's officers and from the World Gold Council and service providers regarding cybersecurity programs — this is oversight structure, making it BG. The named external entity 'World Gold Council' is a QV-eligible fact as it is a specific, independently identifiable organization providing cybersecurity-related reports to the board.

thinking:
Let me analyze this paragraph.

Content: Board receives reports from Sponsor's officers about due diligence on service providers, operational risks, incidents. Also receives reports from World Gold Council and service providers about their cybersecurity programs.

Category: This answers "How does the board oversee cybersecurity?" - Board Governance (BG). The paragraph describes how the Board receives information about cybersecurity.

Specificity: Let me scan for facts.
- "Board of Directors" - generic, every company has one
- "Sponsor's officers" - not a cybersecurity-specific role

- "annual due diligence" - generic cadence
- "World Gold Council" - this is a named external entity. Is it verifiable? Yes, it's a named organization that could be verified.
- "service providers" - generic

World Gold Council stands out as a named external entity providing reports to the board. Even though it's the parent organization rather than a third-party cybersecurity firm, it's still a verifiable named entity, which makes it QV-eligible under the codebook's criteria for named external entities.


content_category: Board Governance

fact: chief information security officer (CISO)

category_confidence: high

specificity_confidence: high

reasoning: The paragraph primarily answers how the board oversees cybersecurity — the CISO prepares a report and presents it to the Audit Committee, describing the information flow to the board. Senior management monitoring is framed as context for the governance chain. The CISO role elevates specificity to Level 3; remaining language (risk management process, enterprise risk assessment, quarterly, Audit Committee) is generic and does not qualify as domain terminology or QV-eligible.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Category: This describes how information flows from CISO to the Audit Committee - it's about the oversight structure. The governance chain (CISO → Audit Committee → Board) is the primary content. This answers "How does the board oversee cybersecurity?" → Board Governance.

But wait - there's also senior management monitoring. Let me re-read. The paragraph has two parts:
1. Senior management monitors cyber risks as part of overall risk management
2. CISO reports to Audit Committee quarterly

The second part is clearly BG - describing how information flows to the board.

The first part is generic, so the primary purpose is really about the oversight and reporting structure → BG. Looking at specificity, the CISO is a named firm role while the Audit Committee is standard across companies, and "quarterly" doesn't qualify as QV. There's no specialized domain terminology beyond generic risk management language, so this lands at Level 3 due to the CISO reference.


content_category: Management Role

fact: forensic analysis

fact: military veterans versed in forensic analysis and regulatory compliance

type: quantified

fact: Master's degree in Cybersecurity

reasoning: The paragraph describes the cybersecurity leadership team's qualifications, background, and composition — squarely answering 'how is management organized?' Person-removal test confirms MR: removing team credentials and experience leaves no substantive program description. Specificity reaches Level 4 due to 'over 23 years of combined Cybersecurity experience' (a verifiable lower-bound number) and 'Master's degree in Cybersecurity' (a verifiable educational credential).

thinking:
Let me analyze this paragraph.

Content: Describes the cybersecurity leadership team's qualifications, experience, and background. This is about WHO the people are and what qualifies them.

Category: Management Role (MR) - This answers "How is management organized to handle cybersecurity?" It's about team composition and qualifications. Person-removal test: remove all person-specific content and nearly nothing remains.

Specificity: Let me scan for facts.
- "over 23 years of combined Cybersecurity experience" - quantified, verifiable (lower bound ≥23 years)

- "Master's degree in Cybersecurity" - a specific credential, even without the university named
- "military veterans" - concrete detail about team composition
- "forensic analysis" - domain expertise mentioned
- "several industry certifications" - vague qualifier, no specific certs listed

The quantifiable claims and named credentials push this to Level 4 specificity.


content_category: Strategy Integration

reasoning: The paragraph states a backward-looking conclusion about cybersecurity's impact on business outcomes ('no cybersecurity impact on our results of operations or financial condition'), which is a materiality assessment → SI. The second sentence is generic speculation ('could occur in the future') that every 10-K includes. No domain terminology, firm-specific facts, or verifiable claims are present — the negative assertion about no incidents is a self-reported claim about absence, not externally verifiable.

thinking:
Let me analyze this paragraph.

Content: States no cybersecurity incidents have occurred, no impact on results/financial condition. Then speculates about future risks.

Category: The first sentence states a conclusion about materiality - "no cybersecurity impact on our results of operations or financial condition." This is a backward-looking materiality assessment → SI. The second sentence is speculation ("could occur in the future") which is generic.

Specificity: "We have not experienced a cybersecurity threat or incident" - negative self-assertion, not verifiable. No domain terms, no firm-specific facts, no QV facts. This is generic boilerplate language → Level 1.


content_category: Risk Management Process

fact: hardening our environment, systems and infrastructure

category_confidence: medium

specificity_confidence: medium

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing internal audits, environment hardening, and employee training — all program activities. The statement about not identifying material cybersecurity risks is about risk identification within the program, not a conclusion about business/financial impact (which would be SI). 'Hardening' is a cybersecurity domain term (an ERM professional would say 'strengthening' or 'improving'), elevating specificity to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Internal audits, no material cyber risks identified, hardening environment, cybersecurity training for employees.

Category: The paragraph describes what the cybersecurity program does - audits, hardening, training. But it also contains a materiality-like statement: "we have not identified any material cybersecurity risks." Let me check if that's a materiality assessment under SI rules.

"We have not identified any material cybersecurity risks" - this is a negative assertion about risk identification, not quite the same as "have not materially affected our business strategy, results of operations, or financial condition." It's more about risk identification than business impact. But it does state a conclusion about materiality of risks.

The bulk of this text is really about program activities—audits, hardening, training—with the materiality statement playing a supporting role. So the main question being answered is what the cybersecurity program actually does, which points toward RMP. Now I'm looking at the specificity of the facts mentioned: "internal audits" is pretty generic business language, and "cybersecurity training" is close to the domain list's "security awareness training" but still fairly broad. I'm wondering whether a non-security ERM professional would naturally use "cybersecurity training for all employees" as a descriptor, or if that's too specialized.

But "hardening our environment" is different—that's clearly domain-specific terminology. An ERM professional would more likely say "strengthening" or "improving" rather than "hardening," which is a cybersecurity concept. That pushes the specificity to Level 2.


content_category: None/Other

reasoning: This paragraph describes general IT infrastructure and business technology use without any substantive cybersecurity disclosure — no security measures, processes, governance, or risk management are discussed. It reads as generic business/technology context, making it N/O. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: This paragraph is a cross-reference pointing to Item 1A for materiality discussion — it does not itself state a conclusion about whether cybersecurity has materially affected the company. Per the N/O vs SI rule, 'risks that may materially affect... see Item 1A' → N/O. No substantive cybersecurity disclosure is present, so specificity is Level 1.


fact: SVP, Engineering

fact: VP, Technology & CISO

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' by identifying specific roles (SVP Engineering, VP Technology & CISO), their responsibilities, team oversight, and the CISO's qualifications. Person-removal test collapses the paragraph. Two cybersecurity-relevant VP+ titles are firm-specific, but no verifiable claims (no specific years of experience as a number, no named certifications, no named external entities) push it to Level 4.

thinking:
Let me analyze this paragraph.

Category: This is about management's organizational role - who is responsible, their titles, responsibilities, qualifications. Person-removal test: remove all person-specific content → very little remains. This is MR.

Specificity:
- "SVP, Engineering" - firm-specific role (VP+ level)
- "VP, Technology & CISO" - firm-specific role (CISO)
- "CISO positions" mentioned in experience - this is about qualifications
- No QV facts - no specific numbers, dates, named external entities, certifications

- The e-commerce and consumer retail expertise is generic industry knowledge, and there's no specialized domain terminology that would distinguish this as firm-specific.

Firm-specific facts: SVP Engineering, VP Technology & CISO roles. Level 3.


reasoning: This is a cross-reference to Item 1A Risk Factors with no substantive cybersecurity disclosure — it points elsewhere rather than providing any assessment or program detail. N/O always receives Specificity 1.


reasoning: This paragraph describes general IT managed services (vCIO operational review, strategic planning, technology road-mapping, IT policy development, SLA reporting) with no substantive cybersecurity disclosure — it answers none of the six cybersecurity questions. None/Other always receives Generic Boilerplate.

thinking:
Let me analyze this paragraph from Lightbridge Corp's 10-K Item 1C filing.

This describes vCIO (virtual CIO) services including operational review, strategic planning, technology road-mapping, IT policy/handbook development, and reporting per SLA. This is about general IT services, not cybersecurity specifically.

Category: This doesn't answer any of the six cybersecurity questions. It's describing general IT managed services. → None/Other

Specificity: N/O always gets Level 1.


fact: cybersecurity awareness training

reasoning: The paragraph answers 'what does the cybersecurity program do?' by listing program components (risk assessments, security team, external providers, training, incident response plan, third-party risk management), making it RMP. Most language is generic ERM ('risk assessments,' 'security controls,' 'incident response plan'), but 'cybersecurity awareness training' maps to the domain term 'security awareness training,' elevating to Level 2. No firm-specific or verifiable facts are present — the security team is unnamed, external providers are generic, and no frameworks, tools, or titles are mentioned.

thinking:
Let me classify this paragraph.

Content: Lists components of cybersecurity risk management program - risk assessments, security team, external service providers, training, incident response plan, third-party risk management.

Category: "What does the cybersecurity program do?" → RMP. It's a list of program components.

Specificity: Let me scan for facts.
- "risk assessments" → general ERM language → L1
- "security team" → not a specific title → L1
- "security controls" → general → L1

- "external service providers" → unnamed → L1
- "cybersecurity awareness training" → this matches the domain terminology for security awareness training → L2
- "incident response plan" → listed as NOT domain terminology → L1
- "third-party risk management process" → general → L1

So Level 2 based on "cybersecurity awareness training." The codebook lists "Security awareness training" as domain terminology, and "cybersecurity awareness training" is essentially the same thing.

Looking at the rest of the paragraph more carefully, it's fairly generic with terms like "ongoing risk assessments," "security controls," and "incident response plan." The only domain-specific term I can identify is "cybersecurity awareness training," which maps directly to the domain list.

Level 2.


reasoning: The first three sentences describe third parties hired to serve the company's own cybersecurity program (monitoring, risk assessment, remediation) → RMP per Rule 3. The final sentence about evaluating third-party risk for suppliers leans TP, but it is subordinate to the dominant RMP framing. Specificity is Level 1: no cybersecurity domain terminology passes the ERM test — 'continuous monitoring,' 'security controls,' 'security reviews,' 'investigation and remediation' are all general business/ERM language. No named frameworks, tools, roles, or quantified facts appear.

thinking:
Let me analyze this paragraph.

Content: Describes partnerships with cybersecurity companies, third-party engagement for risk management, third-party monitoring, and vendor risk evaluation.

Category: This is a mix of RMP and TP. The first three sentences describe third parties hired to serve the company (assessors, monitoring) → RMP. The last sentence describes evaluating third-party risk for critical suppliers → TP. By Rule 3, third parties hired to serve the company → RMP, while requirements/assessment of vendors → TP. The majority of text is about using third parties to serve the company's own program. The last sentence shifts to vendor oversight. I'd say RMP dominates since most text is about the company's own program using third-party help.

Specificity: Scanning through the language, I'm not finding much beyond generic terminology—"cybersecurity," "continuous monitoring," "security controls," and "remediation" are all standard business language without any named frameworks, specific tools, or quantified metrics. The descriptions of third-party risk reviews and security assessments are broad process statements rather than concrete details. This reads as Level 1 boilerplate.

Looking at the next section, terms like "cybersecurity infrastructure" and "cybersecurity products and services" are just using cybersecurity as a modifier without diving into specifics like penetration testing, SIEM systems, or particular frameworks. Even "continuous monitoring of our cybersecurity environment" and "investigation and remediation of events" stay at a generic level. "Security controls" doesn't pass the test either—it's internal control language applied to security. This confirms Level 1.


reasoning: The paragraph describes how the cybersecurity program integrates into ERM, answering 'what does the program do?' — but only at the level of organizational integration, not specific activities. All language is generic enterprise risk management vocabulary (methodologies, reporting channels, governance processes, compliance, strategic, operational, financial risk areas) that any ERM professional would use; no domain terminology, firm-specific facts, or verifiable claims are present.


fact: CIO coordinates cybersecurity program implementation

fact: CIO's team is deployed to address cybersecurity threats

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity — the CIO coordinates with CEO/CFO/GC, CIO's team is deployed, and the management team monitors and reports to the Board. While program activities are mentioned, they are generic ('protect information systems,' 'respond to incidents,' 'monitors prevention, detection, mitigation') and serve to contextualize the management roles. The person-removal test leaves only generic program language. Specificity is Level 3 because CIO is a firm-specific cybersecurity leadership role; however CEO, CFO, and General Counsel are generic governance roles that don't qualify, and the program language lacks domain terminology (no specific tools, frameworks, or security practices).

thinking:
Let me analyze this paragraph.

Content: Describes CIO coordinating with CEO, CFO, GC to implement cybersecurity program, team deployment, monitoring activities, and reporting to Board.

Category: This describes management's organizational role - who is involved (CIO, CEO, CFO, GC), how they coordinate, team deployment, and reporting structure. But let me apply the person-removal test: Remove CIO, CEO, CFO, GC, team references. What remains? "implement a program designed to protect information systems from cybersecurity threats and to promptly respond to any cybersecurity incidents in accordance with incident response and recovery plans... monitors the prevention, detection, mitigation and remediation of cybersecurity threats and incidents in real time, and report such threats and incidents to the Board when appropriate."

There's definitely some program substance underneath, but the paragraph's real focus is on the organizational structure - how the CIO coordinates with other executives, how the team is deployed, and the reporting chain to the Board. The core content is really about management's coordination and structure rather than the program itself. Though I notice the Board reporting aspect could potentially lean toward governance, it's clearly secondary to the main organizational narrative here. So this is fundamentally about management's role and organization.

But I'm also seeing descriptions of what the program actually does - protecting information systems from threats, responding to incidents according to recovery plans, and monitoring threat prevention and detection in real time. These are substantive program activities, not just generic placeholders. When I strip away the person-specific elements, I'm left with meaningful descriptions of program functions, though they're fairly broad in scope.

The tension here is that the paragraph contains both organizational structure details and program activity descriptions. The organizational specifics - the CIO's coordination with CEO, CFO, and GC, the team deployment structure, the Board reporting - these feel like the distinctive content. The program activities are real but generic. I think the organizational structure is what makes this paragraph distinctive, so I'm leaning toward this being management-focused rather than program-focused.

Actually, let me reconsider the specificity angle. The CIO is explicitly called out as a firm-specific cybersecurity leadership role according to the codebook. That's a concrete firm-specific element. The other roles mentioned - CEO, CFO, General Counsel - those are generic governance positions. The terminology around incident response and threat mitigation is standard industry language, not firm-specific. So the only firm-specific element here is the CIO designation itself.

That pushes this toward Level 3 - Firm-Specific, anchored on the CIO reference.


fact: security awareness education (information security and privacy training, ongoing security awareness via emails, talks, presentations)

reasoning: The first sentence mentions senior leadership but describes their participation in cybersecurity processes; applying the person-removal test, the substantive content is about incident response operations and employee training programs — RMP activities. The paragraph references 'information security and privacy training' and 'security awareness education,' which are cybersecurity domain terms (security awareness training), elevating to Level 2. No firm-specific roles or verifiable facts present.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes what management does regarding cybersecurity processes and also describes employee training. Let me apply the "what question" test.

"How is management organized to handle cybersecurity?" - First sentence about senior leadership being informed and monitoring.
"What does the cybersecurity program do?" - The training programs, incident response plan, security awareness education.

Person-removal test: Remove "Members of senior leadership" - remaining text describes processes: prevention, mitigation, detection, remediation, incident response plan, annual security training, security awareness education. That's a substantive program description → RMP.

Now I'm checking the specificity level. I see "security awareness training" and "information security and privacy training" which are domain terms, but the rest is general risk language like prevention and mitigation. There are no firm-specific facts like named roles or committees, so this is Level 2 with domain terminology.


fact: encryption and authentication technology

fact: threat intelligence service providers

fact: penetration testing firms

reasoning: The paragraph describes third-party service providers hired to serve the company's own cybersecurity program (assessors, pen testers, threat intel providers), which per Rule 3 maps to RMP rather than TP since no requirements are imposed ON vendors and no vendor cybersecurity posture is assessed. Domain terms like penetration testing, threat intelligence, and encryption/authentication elevate to Level 2, but no named firms, specific numbers, or firm-specific roles push it higher.

thinking:
Let me analyze this paragraph.

Content: Describes third-party service providers used for security functions and cybersecurity risk management. Lists types of services (SaaS, cloud, encryption, etc.) and types of third-party firms (threat intelligence, penetration testing, etc.).

Category: This mentions third parties but they are hired to serve the company's own program (assessors, pen testers, consultants). Per Rule 3, third parties hired to serve the company → RMP. The paragraph describes what external resources the company uses as part of its own cybersecurity program. However, the central topic IS about third-party service providers. Let me re-read...

The key distinction here is whether this focuses on vendor oversight or the company's internal program. The paragraph describes what third parties do for the company—providing security services and helping manage risks—rather than imposing requirements on those vendors or assessing their cybersecurity posture. That points toward RMP rather than third-party management.

Looking at the specificity: the text uses domain terminology like encryption, authentication, penetration testing, and threat intelligence, which meets the ERM threshold for Level 2. There's no firm-specific information, named vendors, numbers, or roles mentioned, so it stays at Level 2.


fact: CFO (Chief Financial Officer) provides cybersecurity updates to Board

fact: CCO (Chief Compliance Officer) provides cybersecurity updates to Board

reasoning: The paragraph answers 'How does the board oversee cybersecurity?' — describing Board oversight, periodic updates, and information flow from officers to the Board. CFO and CCO are not cybersecurity-specific titles (they appear on the NOT firm-specific list), but here they are named as the specific individuals responsible for cybersecurity reporting to the board, which is an unusual organizational choice (most companies use a CISO or CIO). However, per the codebook, CFO and CCO are generic governance roles that exist at every public company and are explicitly listed as NOT firm-specific. Reconsidering: the paragraph uses no domain terminology beyond general business language ('threat landscape' could be borderline but is increasingly common in general risk management). No QV facts. Downgrading to Level 1.


category_confidence: low

reasoning: This is a concluding summary paragraph that references program elements (third-party assessments, certifications, reporting structure) without substantively describing any single category; RMP is the best fit as it touches on what the program entails, though very superficially. All language is generic business prose — 'rigorous third-party assessments,' 'industry certifications,' and 'organizational reporting structure' are unnamed and unspecified, failing to introduce any domain terminology, firm-specific facts, or verifiable claims.

thinking:
Let me classify this paragraph.

Content: This is a summary/concluding paragraph that mentions third-party assessments, industry certifications, and organizational reporting structure in a very general way. It doesn't answer any specific question deeply.

Category: This is quite generic. It touches on governance, third-party assessments, certifications, and reporting structure but doesn't substantively describe any of them. It's more of a concluding flourish. However, it does reference cybersecurity governance approach - but very superficially.

The question is whether this is N/O or one of the substantive categories. It mentions "cybersecurity governance," "third-party assessments," "industry certifications," and "organizational reporting structure" but only at a surface level as a summary statement.

The key issue is that it name-drops these concepts without actually describing them—there's no explanation of how the board oversees, how management is structured, or what the program entails. The Rule 5 N/O threshold requires actual description of a cybersecurity measure, not just mentioning one in passing. This paragraph just lists concepts in a concluding flourish without substantive detail, so it should be classified as N/O. The language here is too generic and unverifiable to qualify as anything beyond Level 1 — no specific certifications are named, no firm-specific facts are present, and nothing meets the ERM standard.


reasoning: This paragraph is pure speculation about potential consequences of cybersecurity incidents ('may not be able to,' 'may also incur,' 'may also face') without describing any actual measures, processes, or assessments. It reads as generic risk factor language found in any 10-K, with no substantive cybersecurity disclosure. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing processes for assessing, identifying, and managing risks, including safeguards, system tests, and policy reviews — all RMP content. The external IT consultant serves the company's own program (Rule 3 → RMP, not TP). Every term used ('processes to identify, assess, and manage risks,' 'physical, procedural, and technical safeguards,' 'tests on our systems,' 'routine review of policies') is generic ERM language that fails the domain terminology test; the external party is unnamed; no firm-specific or verifiable facts appear.

thinking:
Let me classify this paragraph.

Content: Describes processes for assessing, identifying, and managing cybersecurity risks, including physical/procedural/technical safeguards, system tests, policy reviews, and engaging external parties.

Category: "What does the cybersecurity program do?" → RMP. The external parties are mentioned as serving the company's own program (Rule 3 → RMP, not TP).

Specificity: Let me scan for facts.
- "processes for assessing, identifying, and managing cybersecurity risks" → generic ERM language → L1

- "physical, procedural, and technical safeguards" → generic → L1
- "tests on our systems" → generic → L1
- "routine review of our policies and procedures" → generic → L1
- "information technology consultant" → unnamed → not firm-specific

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


reasoning: The paragraph describes the company's recognition of cybersecurity risk categories it seeks to manage, answering 'what does the program do?' at a very high level. However, it contains no domain terminology (just general business/risk language like 'assessing, identifying, and managing material risks'), no firm-specific facts, and no verifiable claims — pure boilerplate that could appear in any filing unchanged.


reasoning: The paragraph's header frames it as 'Material Impact of Cybersecurity Risks' and it states a conclusion about business impact: cybersecurity threats' potential to disrupt operations and the negative assertion that no incidents have occurred — matching the SI pattern for backward-looking materiality assessments. The speculative opening ('have the potential to disrupt') and generic risk management mention are subordinate to the assessment conclusion. Specificity is Level 1: 'proactive risk management processes' is generic ERM language, and 'As of March 31, 2025' is a date anchoring a negative self-assertion (absence of incidents is not externally verifiable), so it does not qualify as QV per the codebook's explicit guidance on reporting-anchored negative assertions.

thinking:
Let me analyze this paragraph.

Content category: The paragraph makes a materiality-related assessment. "As of March 31, 2025, we did not experience any cybersecurity incidents" is a negative assertion. The paragraph also mentions "proactive risk management processes" but very generically. The first sentence is about how cybersecurity affects the business (potential disruption, regulatory penalties). The materiality assessment rule: "Have not experienced any material cybersecurity incidents" → SI. Here the language is "did not experience any cybersecurity incidents" - this is a negative assertion about incidents, which is an SI-type statement.

The header frames this as "Material Impact of Cybersecurity Risks," and the paragraph concludes with a negative assertion about whether incidents occurred. Even though the body text doesn't explicitly use the word "material," the header's framing combined with the negative assertion about incidents makes this an SI statement per the materiality assessment rule.

For specificity, "proactive risk management processes" is generic boilerplate, and the date March 31, 2025 is tied to a negative assertion rather than a positive fact, so it doesn't qualify as QV. There's no domain-specific terminology or firm-specific details—just the topic of cybersecurity incidents and vague consequences like disrupting operations or compromising data. This lands at Level 1.


reasoning: This paragraph is pure speculation and disclaimer language ('cannot guarantee,' 'could have significant consequences,' 'no security measure is infallible') with a cross-reference to Risk Factors. It does not describe any actual cybersecurity measures, processes, or assessments — just acknowledges limitations and points elsewhere. The 'could have a material adverse effect' language is explicitly not SI per the codebook. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: The paragraph primarily answers how the board oversees cybersecurity — it describes the Board receiving periodic updates on cybersecurity effectiveness and material incidents, which is oversight structure. The IT department mention is brief attribution. All language is generic business terminology (Board, periodic updates, material incidents, framework) with no domain-specific terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Let me analyze this paragraph.

Category: This describes both management (IT department) and board oversight. The board receiving updates and being provided information about cybersecurity - this is about how information flows to the board. The IT department mention is brief attribution. The majority of text is about what the Board receives/will receive. This answers "How does the board oversee cybersecurity?" → Board Governance.

Specificity: Let me scan for facts.
- "Information Technology department" - generic, not a cybersecurity-specific role at VP+ level

- "Board" - generic, every company has one
- "cybersecurity and information security framework" - generic
- "data privacy and risk management" - generic
- "material incidents" - generic
- No domain terminology that passes the ERM test
- No firm-specific facts
- No QV facts

Everything here is boilerplate language without any distinguishing details. Level 1.


reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' — the CFO is identified as the responsible person, with details about his limitations (not full-time, not an experienced computer professional) and reliance on an outside IT firm. Person-removal test: removing the CFO and his attributes leaves almost nothing substantive, confirming MR. For specificity, CFO is explicitly NOT firm-specific per the codebook (general C-suite role), the outside IT firm is unnamed, 'second half of 2021' is not month+year precision, and no domain terminology or QV-eligible facts are present — the language is entirely general business vocabulary.

thinking:
Let me analyze this paragraph.

Content: Describes the CFO's role in overseeing cybersecurity, his limitations, reliance on outside IT firm, and alert process for breaches.

Category: This is primarily about how management is organized to handle cybersecurity. The CFO is identified as the primary person responsible, with details about his limitations and how he relies on others. Person-removal test: remove CFO, his experience, his reliance on outside firm → very little remains. This is MR.

Specificity:
- "Chief Financial Officer" — NOT firm-specific per codebook (generic C-suite role every company has)

- "second half of 2021" — this is a timeframe tied to when oversight began, but it's a range rather than a specific month and year, so it doesn't meet the QV threshold
- "outside information technology, or IT, support firm" and "third-party vendors" — both unnamed, so not firm-specific

Now I'm reconsidering the organizational details. The claims about lacking experienced computer professionals and cybersecurity not being a full-time function are specific to this company's structure. But the CFO being responsible for oversight — while unusual — doesn't qualify as firm-specific since CFO is a generic title. Looking at the domain terminology, "cybersecurity risk management program" and "cybersecurity breaches" are used generically here, not as specialized markers. This still looks like Level 1 — no firm-specific facts, no domain terminology that passes the test, and no qualifying QV details. These organizational details about the CFO's part-time role and lack of computer expertise are actually quite distinctive — they'd help identify this company even without the name. So I'm classifying this as Level 3 firm-specific based on those specific organizational claims, though I need to be careful about how the codebook defines "specific organizational claims" versus just listing a title. The firm-specific criteria really hinges on whether "not a full-time function" and "not an experienced computer professional" constitute specific organizational claims like the "24/7 security operations" example. These details do describe this company's unique cybersecurity posture, but they're more about what the company *doesn't* have rather than what it does—and the codebook's firm-specific list seems to focus on named roles, committees, and programs rather than generic organizational descriptions. I'm settling on Level 1, Generic Boilerplate, since the CFO oversight isn't firm-specific and the other details don't clearly match the IS criteria.


reasoning: The paragraph answers 'How does the board oversee cybersecurity?' — describing Board awareness, management working with the Board, and delegation to the Audit Committee. No domain terminology, no firm-specific facts (Audit Committee exists at every public company), and no verifiable claims, so this remains Level 1.


reasoning: The paragraph opens with a materiality assessment ('has not identified risks...that have materially affected or are reasonably anticipated to materially affect') — a backward-looking and forward-looking conclusion about business impact, making SI the primary category. The remaining content (cross-reference to Item 1A, mention of tabletop exercises and enhanced practices) is subordinate. No domain terminology passes the ERM test ('tabletop exercises,' 'risk management practices,' and 'response protocols' are all general business language), no firm-specific facts, and no verifiable claims, yielding Level 1.

thinking:
Let me analyze this paragraph.

The paragraph starts with a materiality assessment ("has not identified risks...that have materially affected or are reasonably anticipated to materially affect"). That's a backward-looking + forward-looking materiality conclusion → SI.

Then there's a cross-reference to Item 1A, some language about prior incidents enhancing practices, and tabletop exercises.

The primary question answered: "How does cybersecurity affect the business or finances?" — the materiality assessment is the lead sentence and frames the paragraph.

Content category: Strategy Integration

Specificity:
- "materially affected or are reasonably anticipated to materially affect" — this is the materiality assessment language, but it's generic boilerplate SI language

- The tabletop exercises mention includes a cybersecurity qualifier ("simulating potential cyber threats"), which pushes it toward Level 2 territory, though the codebook notes that tabletop exercises without such qualifiers are Level 1. The qualifier contextualizes the practice, but I need to consider whether this elevates it beyond general business practice.

- Looking at the rest of the disclosure: "cybersecurity risk management practices" and "response protocols" are both generic terms without domain-specific language or firm-specific details.

- Cross-referencing Item 1A shows this is subordinate to a non-obligatory element.

- Overall, there's no specialized terminology that would satisfy the ERM test, no firm-specific facts, and no quantifiable metrics. This reads as Level 1 generic boilerplate.


reasoning: This paragraph is a cross-reference pointing the reader to Item 1A for materiality discussion. While it uses language echoing the SEC's materiality formula ('reasonably likely to affect'), it does not itself state a conclusion — it describes what another section covers. Per the N/O vs. SI rule, cross-references are N/O. No substantive cybersecurity disclosure is present, so specificity is Level 1.

thinking: Cross-reference to Item 1A.


fact: security awareness training

fact: Chief Information Officer (CIO) supervises information security team

fact: Information Security Officer

reasoning: Person-removal test: removing CIO, ISO, and their experience still leaves substantial program content (cybersecurity strategy/policy/standards, security awareness training, third-party vendor onboarding assessments, contractual provisions, and ongoing monitoring), so this is RMP rather than MR. The paragraph answers 'what does the program do?' with third-party risk as one component rather than the central topic. Specificity reaches Level 4 because 'combined over 35 years' is a quantified lower bound that is independently verifiable against the individuals' resumes.

thinking:
Let me analyze this paragraph.

Content category: This paragraph covers multiple topics. Let me apply the "what question" test.

1. Management roles: CIO supervises info security team, ISO conducts training, their combined experience
2. Risk management: cybersecurity strategy, policy, standards, architecture processes, security awareness training
3. Third-party risk: processes for third-party service providers, onboarding assessments, contractual provisions, monitoring

Person-removal test: Remove CIO, ISO, their experience, team composition. What remains? "maintaining and implementing our enterprise-wide cybersecurity strategy, policy, standards, and architecture processes...

...conducting annual and ongoing company-wide information security awareness training... processes to identify and oversee risks from cybersecurity threats associated with third-party service providers, which include assessing cybersecurity robustness during third-party vendor onboarding, the inclusion of protective provisions in third-party vendor agreements, and risk-based monitoring of third-party vendors on an ongoing basis."

That's substantial - program activities and third-party risk management remain. So not MR.

The paragraph has roughly equal parts: management organization (first two sentences plus experience), and then third-party risk (last long sentence). The middle training sentence is RMP.

Actually, let me re-read. The first sentence is about CIO's role and what the team does (strategy, policy, standards, architecture). Second sentence is about ISO conducting training. Third sentence is qualifications. Fourth sentence covers the third-party vendor risk management processes - onboarding assessments, contractual protections, and ongoing monitoring.

The third-party risk portion is substantial but so is the program description. The person-removal test leaves substantial content, so not MR. Between RMP and TP: the paragraph covers both internal program activities and third-party risk. The third-party risk portion is about half the text, but there's also program description covering strategy and training.

I'd say RMP since it addresses the broader program with third-party risk as one component. The paragraph answers "what does the cybersecurity program do?" more broadly than just third-party risk.

For specificity: CIO is a named cybersecurity-specific role at VP+ level and listed as firm-specific in the codebook. Information Security Officer is also a cybersecurity-specific title, so firm-specific. The "combined over 35 years of IT management experience" indicates substantial tenure but the exact threshold needs checking.

Actually, "combined over 35 years" is a lower bound that's verifiable—the codebook treats these as quantified values. So that pushes this to Level 4.

Final classification: RMP, Level 4.


fact: Vice President of IT and Digital

fact: CISO

reasoning: Person-removal test: removing 'VP of IT and Digital' and 'CISO' leaves only generic language about staying informed and enhancing processes — the paragraph collapses, confirming MR. The two cybersecurity leadership titles (VP-level and CISO) are firm-specific facts, but no QV-eligible facts (no specific numbers, dates, named external firms, or certifications), so Level 3.

thinking:
Let me analyze this paragraph.

Content: The paragraph describes how the VP of IT and Digital and CISO stay informed about cybersecurity developments through third-party providers and seminars, and how this enhances their processes.

Category: This is about management roles - specifically how the VP of IT and Digital and CISO maintain their knowledge. But let me apply the person-removal test: remove "Vice President of IT and Digital and CISO" - what remains? "Through third party service providers and attendance at seminars, [someone is] regularly informed about the latest developments in cybersecurity, including potential threats and innovative risk management techniques.

This ongoing knowledge acquisition enhances our processes to identify, prevent, mitigate and remediate cybersecurity threats and incidents." Without the people, we have generic language about staying informed and enhancing processes. The paragraph collapses to near-nothing substantive → MR.

Specificity:
- "Vice President of IT and Digital" - this is a VP-level title with IT in portfolio → firm-specific
- "CISO" → firm-specific (named cybersecurity role)
- No QV facts (no numbers, dates, named firms, certifications)
- Domain terms: not really - "cybersecurity threats," "risk management techniques" are generic

Level 3 - Firm-Specific.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — describing audit committee oversight, management presentations, and information flow to the board. All terms are generic governance language (audit committee, management, periodic presentations, 'when material') with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Category: Board Governance - describes how the audit committee oversees cybersecurity, how management reports to the committee, and how the committee reports to the board. This answers "How does the board oversee cybersecurity?"

Specificity: Let me scan for facts.
- "audit committee" - every public company has one, NOT firm-specific
- "management" - generic
- "periodic presentations" - generic cadence
- "when material" - generic

No domain terminology (no cybersecurity-specific technical terms). No firm-specific facts. No QV facts.

This is Level 1 - it's generic governance language without any firm-specific details or technical depth.


reasoning: The paragraph states a materiality conclusion using SEC Item 106(b)(2) language ('have not materially affected, or are reasonably likely to materially affect our business strategy, results of operations, or financial condition') and discusses cybersecurity insurance coverage — both answering how cybersecurity affects the business. No domain terminology, firm-specific facts, or verifiable claims are present; all language is generic boilerplate usable by any filer.

thinking:
Let me analyze this paragraph.

Content: Mixed - mentions programs to decrease cybersecurity risks (RMP), then a materiality assessment (SI), then insurance (SI).

The materiality assessment language "have not materially affected, or are reasonably likely to materially affect our business strategy, results of operations, or financial condition" is the SEC's Item 106(b)(2) language → SI.

The insurance mention also falls under SI.

The opening about programs is brief and generic. The bulk is about materiality and insurance → SI.

Specificity: Let me scan for facts.

The language here is all boilerplate—generic references to human error risks, standard SEC materiality disclaimers, and vague insurance coverage statements. No firm-specific details or domain expertise evident. → Level 1.


reasoning: The first sentence states a backward-looking materiality conclusion ('have not...materially impaired our operations or financial standing'), making this SI under the materiality assessment rule. The cross-reference to Item 1A is subordinate. No domain terminology, firm-specific facts, or verifiable claims — the negative assertion about absence of material incidents is not externally verifiable.


reasoning: The paragraph states a materiality conclusion ('have not materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition'), which is the SEC's Item 106(b)(2) assessment language, making it SI. The mention of cyber insurance and generic controls is subordinate to the materiality assessment. No domain terminology, firm-specific facts, or verifiable claims are present — 'controls,' 'detect, triage and eradicate,' and 'cyber insurance policy' are all general business language that fails the ERM test.

thinking:
Let me analyze this paragraph.

Content category: This paragraph contains a materiality assessment ("have not materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition") → SI per Rule 5. It also mentions cyber insurance and generic controls, but the materiality conclusion is the key statement.

Wait, let me re-read: "have not materially affected or are reasonably likely to materially affect us" - this is the SEC's standard materiality language, both backward and forward-looking. This is SI.

Specificity: Let me scan for facts.
- "cyber insurance policy" - this is a firm-specific organizational claim...

Actually, cyber insurance is fairly common across companies, so it doesn't rise to the level of firm-specific. The incident management language around detecting, triaging, and eradicating threats is standard terminology. The materiality statement itself is pure SEC boilerplate. Nothing here demonstrates domain expertise, unique organizational structures, or quantifiable facts—this is just generic risk disclosure language.

This is Level 1 - Generic Boilerplate.


reasoning: The paragraph states a backward-looking materiality conclusion ('have not had a material impact on our operations, business strategy or financial results'), which is an SI assessment per the materiality rule. No domain terminology, firm-specific facts, or verifiable claims are present—the negative materiality assertion is a self-reported claim about absence and the cross-reference to Risk Factors is subordinate—so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: Mixed - materiality assessment + cross-reference + generic statement about enhancing program.

"To date, these risks, threats or attacks have not had a material impact on our operations, business strategy or financial results" - this is a backward-looking materiality assessment → SI

"but we cannot provide assurance that they will not have a material impact in the future" - forward-looking speculation

"See the section entitled 'Risk Factors'" - cross-reference (subordinate)

The materiality assessment is the core substantive content → Strategy Integration.

Specificity: Let me scan for facts.
- No domain terminology beyond generic risk language

- No firm-specific facts, no QV facts
- The negative self-assertion about past impact isn't verifiable

This lands at Level 1.


reasoning: The paragraph's core content is a materiality assessment using SEC's forward-looking language ('reasonably likely to materially affect us or our operations, business strategy, results of operations or financial condition'), which is an SI conclusion per Rule 5. The opening management sentence is generic attribution and the closing cross-reference to Item 1A is subordinate. No domain terminology, firm-specific facts, or verifiable claims are present — all language is standard boilerplate.

thinking:
Let me analyze this paragraph.

Sentence 1: "Management is responsible for the day-to-day administration of our risk management strategy and our cybersecurity policies, processes, and practices." - Generic management responsibility statement.

Sentence 2: "We do not believe that there are currently any known risks from cybersecurity threats that are reasonably likely to materially affect us or our operations, business strategy, results of operations or financial condition." - This is a materiality assessment using SEC's forward-looking language "reasonably likely to materially affect."

Sentence 3: Cross-reference to Item 1A Risk Factors.

The materiality assessment in sentence 2 is the key content.

The "reasonably likely to materially affect" language is a standard SEC materiality test, making this a boilerplate disclosure. The management statement is generic without firm-specific details, and there are no concrete facts or domain-specific terminology—just standard risk management language that could apply to any company.


reasoning: The opening sentence states a backward-looking materiality conclusion ('have not materially affected our business, strategy, results of operations or financial condition'), making this SI per the materiality assessment rule. The subsequent speculation ('could have a material adverse effect') and cross-reference to Item 1A are subordinate. No domain terminology, firm-specific facts, or verifiable claims are present, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

First sentence: "Such threats and breach attempts have not materially affected our business, strategy, results of operations or financial condition." - This is a backward-looking materiality assessment → SI.

Rest: speculation ("could have a material adverse effect") and a cross-reference to Item 1A.

The first sentence IS a materiality conclusion (SI). The cross-reference is subordinate. Per the rules: "Risks have not materially affected us. See Item 1A" → SI.

Specificity: The materiality assessment is generic boilerplate language.

This is Level 1 — no domain-specific terminology, no company-specific details, no quantifiable facts.


reasoning: The paragraph states a conclusion about whether cybersecurity has materially affected the business — no material breach, no material expenses, no penalties — which is a backward-looking materiality assessment (SI). All claims are negative self-assertions ('has not experienced,' 'has not been penalized') which are not externally verifiable, and 'during the last three years' is a soft timeframe, so specificity remains Level 1.


reasoning: The paragraph describes how the company's cybersecurity program operates — by outsourcing IT management including cyber defense to a third-party sub-contractor. Per Rule 3, third parties hired to serve the company's own security → RMP, not TP. The language ('protection against, detection, and response to cyberattacks') is entirely generic business language with no domain terminology (fails the ERM test — any risk manager could write this), no firm-specific facts (the sub-contractor is unnamed), and no verifiable claims, yielding Level 1.

thinking:
Classify this paragraph.

Content: They use a third-party sub-contractor to manage all IT issues including cybersecurity.

Category: This is about how third-party cyber risks is managed? No - this is about how the company manages its own cybersecurity BY using a third party. The third party is hired to serve the company's program. Per Rule 3: "Third parties hired to serve the company (assessors, pen testers) → RMP." So this is RMP.

Specificity: Let me check the terms. "protection against, detection, and response to cyberattacks" - this is fairly generic language.

The language here is too generic to qualify as domain-specific. "Third-party sub-contractor" lacks any identifying details, "IT" is broad, and "cyberattacks" doesn't pass the ERM test—it's the kind of term that could appear in any enterprise risk document. There are no firm-specific facts or domain terminology that would elevate this beyond Level 1.


reasoning: The paragraph states a conclusion about whether cybersecurity threats have materially affected business strategy, results of operations, or financial condition — both backward-looking ('did not identify any cybersecurity threats that have materially affected') and forward-looking ('are reasonably likely to materially affect'), which is the SEC Item 106(b)(2) materiality assessment language → SI. The second sentence is generic speculation ('if realized, would materially affect us'). No domain terminology, no firm-specific facts, and 'fiscal year 2023' is merely reporting-period context — pure boilerplate materiality language yields Level 1.

thinking:
Classify this paragraph.

Content: States no material cybersecurity threats identified, uses SEC materiality language, then adds speculative "could materially affect" language.

Category: The first sentence is a materiality assessment (backward-looking + forward-looking). The second sentence is speculation. The primary content is the materiality conclusion → Strategy Integration.

Specificity: Let me check for facts.
- "fiscal year 2023" — reporting period context, not a cybersecurity fact
- "have not materially affected or are reasonably likely to materially affect" — this is boilerplate SEC language

- No domain terms, no firm-specific facts, no QV facts. This is pure boilerplate materiality language with no substantive detail. Level 1.


reasoning: This is an exploration-stage company explicitly stating it has not adopted any formal cybersecurity program — similar to the SPAC/no-operations rule, the absence of a program is not a disclosure. The language about commitment to future implementation is aspirational, not a description of any actual cybersecurity measure. No domain terminology, firm-specific facts, or verifiable claims present.


content_category: Third-Party Risk

fact: SOC reports

reasoning: The paragraph primarily answers 'how are third-party cyber risks managed?' — describing vendor security assessments, ongoing monitoring, and review of providers' SOC reports, making TP the dominant category. The trailing materiality sentence is SI but subordinate by text volume. 'SOC reports' is domain terminology (security attestation artifacts) that passes the ERM test, elevating to Level 2, but there are no firm-specific or verifiable facts.

thinking:
Let me analyze this paragraph.

Content: This paragraph discusses third-party risk management (vendor assessments, SOC reports monitoring) and ends with a materiality statement.

Category: The central topic is third-party risk management - how they oversee vendors. The last sentence is a materiality assessment (SI), but the bulk of the text is about third-party risk. TP wins by text volume.

Wait, let me re-read. "Third-party Risk" seems like a header fragment. The bulk discusses: security assessments of third-party providers, ongoing monitoring, annual assessments of SOC reports, complementary controls. Then a materiality statement at the end.

The core question here is how third-party cyber risks are managed, which is clearly TP territory. The materiality statement at the end is just boilerplate SI language. Looking at specificity, "SOC reports" is domain terminology that signals Level 2, while the rest is fairly general vendor assessment language. No firm-specific or QV facts present, so this lands at Level 2.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing the board being informed of risk management and monitoring strategic risk, with executive officers handling day-to-day management — a classic oversight structure description. Specificity is Level 1: all terms ('Board,' 'executive officers,' 'periodically,' 'risk management process,' 'strategic risk exposure') are generic business language that would appear in any company's filing; no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Content: Board is periodically informed of risk management process including cybersecurity threats. Board monitors strategic risk, executive officers handle day-to-day risk management.

Category: This answers "How does the board oversee cybersecurity?" → Board Governance. It describes the board being informed and responsible for monitoring risk, with executive officers handling day-to-day. This is oversight structure.

Specificity: Let me scan for facts.
- "Board" / "Board of Directors" → NOT firm-specific (every company has one)
- "executive officers" → generic

- "periodically" → generic cadence
- "risk management process" → general business language, NOT domain terminology
- "cybersecurity threats" → just the topic, not domain expertise
- "strategic risk exposure" → general business
- "day-to-day management" → generic

Everything here is generic business language without any domain-specific terminology, firm-specific details, or substantive facts about their actual cybersecurity practices. This is Level 1.


reasoning: The paragraph states a materiality conclusion — 'have not identified risks...that have materially affected or are reasonably likely to materially affect us' — which is both a backward-looking and forward-looking assessment, making it SI per the materiality rule. The trailing board oversight clause is subordinate. No domain terminology, firm-specific facts, or verifiable claims are present; the language is standard SEC boilerplate.

thinking:
Let me analyze this paragraph.

This paragraph has two parts:
1. A materiality assessment: "We have not identified risks from known cybersecurity threats...that have materially affected or are reasonably likely to materially affect us..."
2. A brief governance statement: "Board considers cybersecurity risks as part of its risk oversight function..."

The first sentence is a clear materiality conclusion (both backward and forward-looking) → SI per Rule 5.
The second part mentions board oversight → BG.

The materiality assessment is the dominant content. The board mention is brief and subordinate. → **SI**

Both statements rely on standard SEC language and generic phrasing without any firm-specific details or technical specificity, which puts this at the lowest level of disclosure quality.


fact: protected health information (PHI) — HIPAA-specific data classification term

fact: confidentiality, integrity, or availability — CIA triad, a core information security concept

reasoning: The paragraph's central topic is managing cybersecurity risks arising from third-party service providers — vendor qualification, oversight limitations, and reliance on providers for incident notification — squarely answering 'how are third-party cyber risks managed?' The CIA triad language and PHI reference demonstrate cybersecurity domain vocabulary beyond generic ERM language, elevating to Level 2, but there are no firm-specific or verifiable facts.

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

Facts: "vendor qualification and management program" - generic program name, "protected health information" - this is a HIPAA-related term, "confidentiality, integrity, or availability" - CIA triad is a security concept.

Let me think about domain terminology: "protected health information" (PHI) is a HIPAA term used in cybersecurity/privacy context. "Confidentiality, integrity, or availability" is the CIA triad - a fundamental cybersecurity concept. These pass the ERM test - a generic ERM professional wouldn't naturally use "CIA triad" language or PHI terminology.

The CIA triad language definitely signals domain expertise in information security rather than general business risk management. PHI is more borderline since it appears in healthcare compliance contexts, but combined with the CIA framing, this points toward cybersecurity-specific knowledge. The paragraph's focus on vendor and third-party risk management, paired with these specialized terms, suggests Level 2 specificity.


fact: active interactions with children's hospitals while assisting with insurance prior approvals — firm-specific business context for cybersecurity risk

reasoning: The paragraph contains two materiality assessments: a backward-looking conclusion ('have not...materially affected us') and a forward-looking one using SEC Item 106(b)(2) language ('reasonably likely to materially affect'), making this clearly Strategy Integration. The mention of 'children's hospitals' and 'insurance prior approvals' as the specific source of ongoing cyber risk is a firm-specific detail that distinguishes this company's risk profile, elevating specificity to Level 3.

thinking:
This paragraph contains two materiality assessments plus a section header.

First sentence: backward-looking negative materiality assessment → SI
Second sentence: forward-looking materiality assessment using "reasonably likely to materially affect" → SI
Last part: "CYBERSECURITY GOVERNANCE" is just a section header.

Category: Strategy Integration - the paragraph states conclusions about materiality (both backward and forward-looking).

Specificity: Let me check for facts.
- "children's hospitals" - this is a firm-specific detail about their business context
- "insurance prior approvals" - firm-specific business detail

- The materiality language itself is standard SEC boilerplate, but the references to their specific business operations—actively working with children's hospitals and handling insurance prior approvals—reveal what makes their cyber risk profile distinct. These operational details are firm-specific facts that contextualize their cybersecurity vulnerabilities.

Level 3 - Firm-Specific due to the specific business context mentioned.


reasoning: The paragraph answers 'how is management organized to handle cybersecurity?' by describing the CEO's cybersecurity responsibilities, tasking, and reporting line to the Board. Person-removal test: removing CEO role and reporting structure leaves nearly nothing substantive. The brief mention of reporting to the Board is subordinate to the role description. No domain terminology (incident response plan, risk assessment are general business terms per codebook), no firm-specific facts (CEO and Board of Directors exist at every company), and no QV-eligible facts.

thinking:
Let me analyze this paragraph.

Content: The CEO leads cybersecurity risk assessment, oversees implementation, monitors prevention/mitigation/detection/remediation, and reports to the Board. This is about how management is organized - the CEO's role and responsibilities.

Category: This is about management's organizational role. The person-removal test: remove CEO, reporting lines, responsibilities → almost nothing remains. → MR

But wait - "reports to the Board of Directors on any appropriate items" has a BG element. However, the primary content is about the CEO's role and responsibilities, not about board oversight structure. The paragraph answers "how is management organized?" more than "how does the board oversee?"

→ MR

Now I'm checking the specificity. The language here is all generic - CEO, Board of Directors, incident response plan, cybersecurity risk assessment, prevention and mitigation - none of these are firm-specific or domain-specific terminology. It's standard boilerplate language that could apply to any organization.

→ Level 1, Generic Boilerplate


reasoning: This is a governance-chain paragraph (Board → Management) describing oversight structure, defaulting to BG per Rule 1; the negative incident assertion lacks materiality framing ('any cybersecurity incidents' vs. 'material cybersecurity incidents') and is subordinate to the governance frame. All language is generic ERM vocabulary — 'identifying, considering and assessing material cybersecurity risks,' 'processes to ensure... monitored' — with no domain terminology, no firm-specific facts, and no verifiable claims, keeping it at Level 1.

thinking:
Let me analyze this paragraph.

Content category: The paragraph starts with board oversight, then mentions management responsibility, then a negative incident assertion. Let me determine the primary question answered.

- "Board has overall oversight responsibility" → BG
- "Management is responsible for identifying..." → could be MR or RMP
- "We have not experienced any cybersecurity incidents" → SI (negative assertion with materiality framing? Actually it says "any cybersecurity incidents" not "material cybersecurity incidents")

Wait, the last sentence says "We have not experienced any cybersecurity incidents in fiscal year 2024." This doesn't use "material" - it's just a negative assertion about incidents.

Looking at the codebook, the standard phrasing for incident history is "material cybersecurity incidents," but this paragraph omits that qualifier. Still, the core content is about incident history. The paragraph actually covers three distinct topics: board oversight as the framing device, generic management responsibilities, and a negative incident assertion. Since the board oversight sentence opens the paragraph and sets the context, that's likely the primary category here. The incident statement is a negative assertion but without the "material" qualifier, so it's less clearly a materiality assessment. The governance structure—Board oversight and Management responsibilities—really does dominate the paragraph, so I'm settling on BG as the primary category. Looking at the specificity now: everything here is generic business language. "Board," "Management," "material cybersecurity risks," "processes to identify, consider and assess"—it's all standard ERM boilerplate with no firm-specific details or domain terminology. This is clearly Level 1 Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity — approving investments, overseeing compliance, ensuring legal counsel — making it Board Governance. All language is generic business terminology ("external vendors and consultants," "relevant cybersecurity regulations," "breach notification requirements") that any enterprise risk management professional could write; no domain-specific security terms, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: The paragraph discusses the board evaluating/approving cybersecurity investments based on management/vendor recommendations, compliance oversight roles, and legal counsel for cybersecurity issues.

Category: This is about board oversight of cybersecurity - approving investments, overseeing compliance, ensuring legal counsel. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

Specificity: Let me scan for facts:
- "cybersecurity technologies, training, and talent" - generic
- "external vendors and consultants" - unnamed, not firm-specific

- "breach notification requirements" - standard compliance language, not domain-specific
- "legal counsel" - generic

No domain terminology, no firm-specific details, no quantifiable facts. This is all boilerplate business language. Level 1.


reasoning: The paragraph acknowledges the importance of cybersecurity but describes no actual measures, processes, roles, or assessments — it is a statement of intent ('acknowledges the crucial necessity') without substantive disclosure answering any of the six category questions. No domain terminology, firm-specific facts, or verifiable claims are present; 'confidentiality, integrity, and accessibility' is general data governance language any ERM professional could write.

thinking:
Classify this paragraph.

"Inc. acknowledges the crucial necessity of establishing, executing, and sustaining strong cybersecurity measures to secure our information systems. This is undertaken to uphold the confidentiality, integrity, and accessibility of our data."

This is generic language about cybersecurity importance. No specific processes, no roles, no incidents. It's essentially saying "we recognize cybersecurity is important."

Does it answer any of the six questions? Not really. It's a general statement of intent. Could be N/O or very generic RMP.

Actually, "establishing, executing, and sustaining strong cybersecurity measures to secure our information systems" and "uphold the confidentiality, integrity, and accessibility of our data" - this is extremely generic.

The paragraph references the CIA triad but in such vague terms that even a general ERM professional might use this language in a data governance context. There are no actual measures described, no concrete practices or policies—just an acknowledgment that cybersecurity matters. This is a clear N/O under Rule 6: no substantive disclosure, just a statement of intent.

N/O, Specificity 1.


reasoning: The paragraph opens with a backward-looking materiality assessment ('have not experienced any material cybersecurity incidents' and 'expenses...have been immaterial'), which per the SI materiality rule states a conclusion about whether cybersecurity has affected business outcomes → SI. The remaining text is generic speculation ('could face cybersecurity risk', 'reasonably likely...may expend greater resources') and a cross-reference to Item 1A. No domain terminology, firm-specific facts, or verifiable claims are present — negative self-assertions about absence of incidents are not externally verifiable — so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: States no material incidents, expenses immaterial, references risk factors, mentions reliance on IT systems, and says it's reasonably likely they'll spend more on security.

Category: The paragraph starts with a materiality assessment ("have not experienced any material cybersecurity incidents, and the expenses incurred from any security incidents have been immaterial"). Then it references Risk Factors, then generic speculation about cybersecurity threats. The materiality assessment is the substantive disclosure here. Per Rule 5, "Have not experienced any material cybersecurity incidents" is a negative assertion with materiality framing → SI. The "could have" language and "reasonably likely that we may expend greater resources" is about future spending, not a materiality assessment per se. The dominant content is the materiality assessment → SI.

The backward-looking claims about no material incidents and immaterial expenses are the key SI indicators, while the forward-looking language about potentially spending more is just speculative risk language. Specificity-wise, there's nothing here that's firm-specific or verifiable—it's all generic boilerplate without any concrete facts, domain terminology, or quantifiable details. This lands squarely at Level 1.


fact: 21 CFR 11 (Part 11) compliant

type: framework

fact: antivirus and antimalware software

reasoning: The paragraph primarily answers how third-party cyber risks are managed — the company has no own policy and relies entirely on CROs, describing their compliance status, security measures, and the oversight/reporting requirements imposed on them. Domain terms (antivirus/antimalware, 21 CFR 11 as a named regulatory standard) elevate to Level 2, but the CRO is unnamed so nothing reaches QV, and 'CRO' is a generic entity type rather than a firm-specific fact.

thinking:
Let me analyze this paragraph.

Content: The company doesn't have its own cybersecurity policy but contracts with CROs. Describes CRO's compliance (21 CFR 11), their security measures (antivirus, antimalware), and the company's oversight of the CRO's cybersecurity.

Category: This is primarily about how third-party cyber risks are managed. The company relies entirely on CROs and describes requirements/oversight of those CROs. → Third-Party Risk

Specificity: Looking at the concrete details here - the company cites 21 CFR 11 as a specific FDA regulatory standard that the CRO meets, mentions antivirus and antimalware as security controls, and requires breach reporting from the CRO. The claim that the CRO "is compliant" with 21 CFR 11 is stated as fact, though it's unclear whether this is independently verified or based on the CRO's own assertion.

The challenge is that while 21 CFR 11 is a named, verifiable regulatory framework, the CRO itself remains unnamed, making it harder to independently confirm the compliance claim. The security terminology used is domain-appropriate but fairly generic. So the specificity here sits at a middle level - there's a named standard referenced, but the actual entity being evaluated isn't identified.


reasoning: The paragraph touches multiple categories (RMP, BG, TP, SI), but the plurality of text answers 'what does the cybersecurity program do?' — describing risk assessments, monitoring, security tools, testing, and third-party collaboration to assess effectiveness. The materiality assessment sentence is SI and the board mention is BG, but these are subordinate to the program description. Specificity remains Level 1 because all language is generic business/ERM vocabulary ('assess risks,' 'monitor information systems,' 'various security tools,' 'potential vulnerabilities') with no cybersecurity domain terminology passing the ERM test, no firm-specific facts, and no verifiable claims.

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

This is a dense paragraph covering multiple topics. Let me break it down:

1. "Management and Strategy regularly assess risks from cybersecurity threats, monitor our information systems for potential vulnerabilities, and test those systems..." → RMP
2. "we use various security tools that are designed to help identify, escalate, investigate, resolve, and recover from security incidents" → RMP
3. "Our board of directors assesses risks based on probability and potential impact..." → BG
4. "We collaborate with third parties to assess the effectiveness..." → RMP (third parties serving the company)

5. "We have also developed a third-party cybersecurity risk management process to conduct due diligence on external entities" → TP
6. "Cybersecurity threats...have not materially affected our Company, including our business strategy, results of operations, or financial condition." → SI
7. Cross-reference to risk factors → N/O

The bulk of this passage focuses on the company's risk management practices—their monitoring systems, security tools, and third-party assessments. There's also a statement that cybersecurity incidents haven't materially impacted the business, plus board oversight of these risks and a reference to additional risk factor disclosures.

Looking at what dominates the text, RMP is clearly the primary focus. The materiality statement is there, but it's secondary to the main narrative about what the cybersecurity program actually does.

Now checking for specificity—I'm looking for concrete facts rather than generic language. "Management and Strategy" appears capitalized, which might suggest a formal team name, but it's still vague. The references to "various security tools," "board of directors," and "third parties" are all generic without naming specifics. The language around materiality is standard boilerplate. Terms like "vulnerabilities" and "security incidents" are common cybersecurity vocabulary but don't meet the specificity threshold.

The process descriptions—identifying, escalating, investigating, resolving—are generic operational steps. Even "monitor our information systems for potential vulnerabilities" and "test those systems" lack the precision needed. There's no mention of specific frameworks, named tools, particular roles, or firm-specific facts. This is Level 1 boilerplate throughout.


reasoning: The paragraph answers 'How does the board oversee cybersecurity?' by describing Board delegation to the Audit Committee and oversight of management's program — a classic governance-chain paragraph defaulting to BG. No domain terminology, no firm-specific facts (Board and Audit Committee exist at every public company), and no verifiable claims, so Level 1.


reasoning: The paragraph primarily answers how third-party cyber risks are managed—security assessments before engagement, ongoing monitoring, and review of providers' SOC reports—making TP the dominant category. The trailing materiality sentence is subordinate. 'SOC reports' is domain terminology (a specific audit/attestation framework), elevating to Level 2, but there are no firm-specific or verifiable facts.

thinking:
Let me analyze this paragraph.

Content: Third-party risk management processes, SOC reports monitoring, and a materiality statement.

Category: The paragraph primarily answers "How are third-party cyber risks managed?" - security assessments of third-party providers, ongoing monitoring, SOC reports. There's a trailing materiality statement but the bulk is about third-party risk. → TP

Specificity:
- "SOC reports" → domain term (Level 2)
- "security assessments of all third-party providers" → general process
- "complementary controls" → general
- The materiality statement at the end is SI-type but subordinate

- No firm-specific facts or quantifiable values present, so this stays at Level 2 due to the domain terminology alone.


reasoning: The first two sentences describe consultants hired to design, implement, monitor, and test the company's own cybersecurity program (Rule 3: third parties serving the company → RMP). The final sentence discusses future intentions to impose requirements on vendors (TP), but it is aspirational ('in the future, we intend to') and does not describe current practices. RMP content about current activities edges out the aspirational TP content. All language is general business terminology ('risk assessment processes,' 'policies and procedures,' 'monitor and test safeguards') with no cybersecurity domain terms, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Describes third-party service providers helping with risk assessment, designing/implementing cybersecurity policies, monitoring/testing safeguards. Then discusses future intentions for vendor requirements.

Category: The first part describes third parties hired to serve the company's own security program → RMP per Rule 3. The second part about requiring vendors to certify security measures → TP. Let me assess which dominates.

First two sentences: consultants helping design/implement/monitor/test the company's own cybersecurity → RMP
Last sentence: future intentions to require third-party service providers to certify security → TP (but it's future intent, not current practice)

The opening sentences clearly fall under RMP since they describe third parties supporting the company's internal security operations, while the closing statement about future vendor certification requirements points toward TP, though it's aspirational rather than established practice.

Checking the specificity: the language stays general throughout—consultants, risk assessment, cybersecurity policies, safeguards, certification—without naming specific firms or detailing particular implementations, so this lands solidly at L1.


reasoning: The opening sentence states a materiality conclusion — both backward-looking ('have not materially affected') and forward-looking ('are not reasonably likely to materially affect') — which is the SEC's Item 106(b)(2) language, making this SI per Rule 5. The remainder is generic speculation and a cross-reference. No domain terminology, firm-specific facts, or verifiable claims are present, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: States no material cybersecurity incidents, mentions time-to-time threats, cross-references Item 1A.

Category: The first sentence is a materiality assessment - "have not identified any cybersecurity incidents or threats that have materially affected us or are reasonably likely to materially affect us" - this is SI per Rule 5 (both backward-looking and forward-looking assessment). The second sentence is generic speculation, and the third is a cross-reference. The materiality conclusion is the primary substantive content → Strategy Integration.

Specificity: Let me scan for facts.

The language here is entirely boilerplate—standard materiality phrasing about business strategy and financial condition, vague references to third-party vendors without naming them, and just a pointer to the risk factors section. There are no domain-specific details, no company-specific facts, nothing quantifiable. This is Level 1 - Generic Boilerplate.


reasoning: The first sentence states a backward-looking materiality conclusion ('does not believe that it has experienced any material cybersecurity incidents, nor any material costs') making this SI per Rule 5. The remaining text is speculation ('cannot provide assurance') and a cross-reference to Item 1A, both subordinate. Specificity is Level 1: 'past two years' is a soft timeframe, the negative assertion is not externally verifiable, and no domain terminology or firm-specific facts are present.

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. "In the past two years, the Company does not believe that it has experienced any material cybersecurity incidents, nor any material costs related to immaterial cyber incidents." — This is a backward-looking materiality assessment (negative assertion).
2. "we cannot provide assurance that our results of operations and financial condition and business strategy will not be materially impacted from cybersecurity risks in the future" — This is speculation/disclaimer.
3. Cross-reference to Item 1A.

The first sentence is a materiality conclusion — SI per Rule 5.

The second part is speculative language, while the third is just a cross-reference. The real substance here is that backward-looking materiality assessment in the opening sentence. Looking at the specifics, I'm seeing soft timeframes like "in the past two years" rather than precise dates, generic phrasing around "material cybersecurity incidents," and standard SEC boilerplate about operations and financial condition. There's no domain-specific terminology, no company-specific facts, and the negative assertion about not experiencing material incidents isn't something that can be externally verified according to the codebook. This falls squarely into generic boilerplate territory.


fact: SMIS and Cybersecurity Committee

fact: Cybersecurity committee

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing information flow from the SMIS and Cybersecurity Committee to the Board, including regular reports and incident escalation procedures. The named 'SMIS and Cybersecurity Committee' is a non-generic, firm-specific committee that elevates specificity to Level 3; no QV-eligible facts (specific numbers, dates, named external entities, or certifications) are present.

thinking:
Let me analyze this paragraph.

Content Category: The paragraph describes how the Board receives reports from committees about cyber risks, how incidents flow up to the board. This is about oversight structure and information flow to the board → Board Governance.

Specificity: Let me scan for facts:
- "SMIS and Cybersecurity Committee" - named non-generic committee → firm-specific
- "Cybersecurity Committee" - named non-generic committee → firm-specific
- "cyber incident response plan" - generic program name, not distinguishing
- "Audit committee" - every company has one, not firm-specific
- "SMIS's team" - this seems like a named internal entity → firm-specific

- No quantifiable facts like numbers or dates that would qualify for QV eligibility, and no named external entities or certifications mentioned. This lands at Level 3 - Firm-Specific based on the internal committee and team references.


fact: CGNC (named non-generic committee referenced as having oversight)

reasoning: The paragraph answers 'how is management organized to handle cybersecurity?' — senior management of business units handle day-to-day operations, units must report material events to the Company, and senior management reviews incident reports for SEC filing decisions. Person-removal test: removing management references leaves procedural shells without substance, confirming MR. The CGNC is a named non-generic committee elevating specificity to Level 3.

thinking:
Let me analyze this paragraph.

Content: Describes senior management responsibilities for day-to-day cybersecurity operations across business units, reporting requirements for material events, and SEC filing determination.

Category: This is about how management is organized to handle cybersecurity. Senior management of business units handle day-to-day operations, reporting structure for material events, senior management reviews incident reports. This is about management's organizational role and responsibilities.

But wait - the CGNC (a committee) oversight is mentioned first, then it shifts to management responsibilities. The primary content is about management's organizational role in cybersecurity - who is responsible (senior management of business units), what they do (day-to-day operations, reviewing incident reports), reporting requirements.

Now I'm applying the person-removal test. When I strip out the specific roles and names, what's left is the operational structure: business units report material cybersecurity events, and there's a review process to determine SEC filing obligations. That's describing the organizational framework and reporting procedures rather than substantive cybersecurity practices. The CGNC is a named committee specific to this firm, which pushes this to Level 3 firm-specificity. There's no specialized cybersecurity terminology or quantifiable facts here—just the governance structure.


reasoning: The first sentence is pure speculation ('could have a material adverse effect') which is explicitly not SI, but the second sentence makes a substantive factual disclosure that the company lacks cybersecurity insurance — insurance coverage is an SI topic, and stating its absence is a conclusion about the company's financial posture regarding cyber risk. No domain terminology, firm-specific facts, or verifiable claims are present, so specificity remains Level 1.

thinking:
Let me classify this paragraph.

Content: "may not be successful in preventing or mitigating a cybersecurity incident that could have a material adverse effect on us. Nor are we insured for damages that could result from such an incident."

Category: This is speculation ("could have a material adverse effect") - not a materiality assessment/conclusion. The insurance mention is a negative statement about not having insurance. The "could have" language is speculation per the codebook. But wait - "Nor are we insured for damages" is a factual statement about not having cybersecurity insurance, which relates to Strategy Integration.

Actually, I need to reconsider this split. The first part is pure speculation with the "could have" language, which the codebook explicitly excludes from SI. But the second sentence about lacking cybersecurity insurance is a substantive factual claim about their financial posture - that's Strategy Integration material. Though I should verify whether DHCC is a SPAC or shell company first, since that would affect the classification entirely.

Looking at the two components: the speculation about adverse effects doesn't qualify, but the insurance statement does answer how cybersecurity risk affects their business. The language is generic though - no domain-specific terminology, no firm-specific details, just standard business language about insurance coverage. That keeps it at Level 1 specificity. So this lands in SI based on the insurance disclosure being substantive, even if it's generic.


reasoning: The opening sentence states both a backward-looking ('have not previously materially affected') and forward-looking ('not reasonably likely to materially affect') materiality conclusion, making this SI under the materiality assessment rule. The remainder is generic speculation and an Item 1A cross-reference, which are subordinate. No domain terminology, firm-specific facts, or verifiable claims are present—'AI technologies' and 'security breaches' are general business language—so specificity stays at Level 1.

thinking:
Let me analyze this paragraph.

Content: Two parts - (1) materiality assessment stating risks haven't materially affected and aren't reasonably likely to, (2) speculation about future risks and cross-reference to Item 1A.

Category: The first sentence is a clear materiality assessment (both backward and forward-looking) → SI. The rest is speculation ("could"/"may" language) which doesn't override. SI dominates.

Specificity: Let me scan for facts:
- "have not previously materially affected us" - negative self-assertion, not verifiable

- "not reasonably likely to materially affect" - assessment, not verifiable
- "Item 1A" - cross-reference
- "AI technologies" - general term
- No domain terms that pass ERM test, no firm-specific facts, no QV facts

This is generic boilerplate language. Level 1.


reasoning: The paragraph's primary function is a backward-looking materiality assessment ('have not encountered cybersecurity challenges that have materially impaired our operations or financial standing'), which is an SI conclusion per Rule 5. The speculative language ('If we were to experience...may have a material effect') and cross-reference are subordinate. Specificity is Level 1: 'December 31, 2024' is reporting-period context (not a cybersecurity fact), the negative materiality assertion is not externally verifiable, and no domain terminology or firm-specific facts appear.

thinking:
Let me analyze this paragraph.

Content: This paragraph makes a backward-looking materiality assessment ("have not encountered cybersecurity challenges that have materially impaired our operations or financial standing"), includes forward-looking speculation ("If we were to experience...may have a material effect"), mentions continuing to monitor their program, and has a cross-reference to Governance section.

Category: The primary statement is a materiality assessment - "have not encountered cybersecurity challenges that have materially impaired our operations or financial standing during the financial year ended December 31, 2024." This is a backward-looking SI assessment per Rule 5. The speculation ("If we were to experience...") is NOT SI.

The cross-reference points to governance disclosures, but the core claim is the materiality conclusion, which makes this Strategy Integration. Looking at the specificity, the reporting date is just temporal context rather than a cybersecurity fact, and the negative assertion about not encountering material challenges isn't externally verifiable. There's no domain-specific terminology or firm-specific facts here—it's generic boilerplate materiality language at Level 1.


fact: threat intelligence feeds

fact: vulnerability management

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing a crisis response plan, monitoring, vulnerability management, and training — all program activities with no person-specific content. Domain terms 'threat intelligence feeds' and 'vulnerability management' pass the ERM test (a non-security risk professional wouldn't naturally use these), elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity program activities - crisis response plan, incident response team monitoring, vulnerability management, training, simulations, drills.

Category: "What does the cybersecurity program do?" → RMP. Person-removal test: no person-specific content to remove. This is about activities and processes.

Specificity: Let me scan for facts.
- "threat intelligence feeds" → domain term (threat intelligence)
- "vulnerability management" → domain term
- "simulations" → could be phishing simulations (domain) but just "simulations" is generic
- "incident response team" → not firm-specific per the rules (generic)

- "cyber crisis response plan" → has a name but it's somewhat generic, not a distinguishing identifier

Domain terms like threat intelligence feeds and vulnerability management pass the ERM test. No firm-specific facts or named roles present. This lands at Level 2.


reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' — it identifies CEO and CFO as responsible, discusses their lack of certifications but claims compensating experience, and describes reporting lines to the Audit Committee and Board. The qualification discussion (no direct cybersecurity expertise, reliance on experience and third-party consultants) is quintessential MR content. Person-removal test: removing CEO/CFO and their qualifications leaves almost nothing substantive. For specificity, CEO and CFO are generic executive roles (not cybersecurity-specific titles), Audit Committee exists at every public company, and the third-party expert is unnamed — no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Category: This describes management's role in cybersecurity - CEO and CFO responsibilities, their qualifications (or lack thereof), and reporting to Audit Committee/Board. The governance chain is present but the primary content is about management's organizational role and qualifications.

The paragraph answers "How is management organized to handle cybersecurity?" - it's about who (CEO, CFO) is responsible, their qualifications (no direct certifications but experience), and reporting lines. The Board/Audit Committee mention is subordinate to describing management's role.

Wait - let me reconsider.

The governance structure is there, but the real focus is on management's responsibilities and their qualifications - specifically that they lack formal certifications but have relevant experience. When I remove the CEO, CFO, and their qualifications, there's not much left except generic process language, which suggests this is really about management's role rather than the broader governance chain. The qualification discussion takes up significant space in the paragraph, reinforcing that management's competency is the central point here.

Looking at the specificity: CEO and CFO are just generic roles, the Audit Committee is a standard governance body, there's no domain-specific language, no certifications mentioned, no numbers, and the "third party information technology expert" is unnamed and generic. This is clearly Level 1 boilerplate with no domain terminology, no firm-specific details, and no qualitative value.


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