content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: This paragraph is a cross-reference to another section of the report and does not provide any substantive cybersecurity disclosure, so it falls under None/Other. It contains no specific facts about cybersecurity practices, roles, or incidents, resulting in Generic Boilerplate specificity.

provider: xiaomi

stage: benchmark


reasoning: This paragraph is a cross-reference to the Risk Factors section and does not contain any substantive cybersecurity information, so it is classified as None/Other. It lacks any specific facts, resulting in Generic Boilerplate specificity.


reasoning: This paragraph is solely a cross-reference to Item 1A for cybersecurity risk discussions, providing no substantive cybersecurity disclosure, so it is classified as None/Other. It contains no specific facts, domain terms, or verifiable claims, resulting in Generic Boilerplate specificity.


reasoning: The paragraph provides general context about technology systems and data reliance but does not address any specific cybersecurity governance, management, risk process, incident, or strategy, so it is classified as None/Other. It contains no specific, verifiable, or firm-unique facts, using only generic business language, resulting in Generic Boilerplate specificity.


content_category: Strategy Integration

reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a backward-looking materiality conclusion ('has not been materially affected') and referencing forward-looking risks, which aligns with Strategy Integration. It contains no specific facts such as domain terms, firm-specific details, or verifiable claims, making it generic boilerplate.


reasoning: The paragraph primarily serves as a disclaimer about cybersecurity program limitations and a cross-reference to risk factors, with no substantive disclosure on governance, processes, or incidents, fitting None/Other. It contains no specific facts—only generic language and a filing reference—resulting in Generic Boilerplate specificity.


content_category: Third-Party Risk

reasoning: The paragraph directly addresses how third-party cyber risks are managed through a dedicated program, fitting Third-Party Risk. It contains only generic descriptions of vetting and monitoring without any specific facts, tools, or verifiable details, resulting in Generic Boilerplate specificity.


reasoning: The paragraph is a generic statement about the company's exposure to cyber threats due to its business nature, without describing any specific governance, processes, or incidents, so it does not answer any of the substantive cybersecurity questions. It contains no verifiable or domain-specific facts, making it boilerplate language.


content_category: Board Governance

reasoning: The paragraph directly answers how the board oversees cybersecurity through its Enterprise Risk Management program, escalation processes, and engagement of third-party experts, making it Board Governance. It contains no specific facts—only generic oversight descriptions that lack domain expertise, firm-specific details, or verifiable claims, resulting in Generic Boilerplate specificity.


content_category: Risk Management Process

reasoning: The paragraph describes the cybersecurity risk management program's components, such as risk assessments, team responsibilities, and third-party oversight, which directly answers what the program does, making it RMP. However, it uses generic terms like 'risk assessments' and 'incident response plan' without any specific, verifiable, or domain-adapted details, resulting in Generic Boilerplate specificity.


fact: cybersecurity dashboard

fact: threat detection rates

fact: response times

fact: external penetration tests

fact: process audits

reasoning: The paragraph primarily describes how the Audit Committee oversees cybersecurity risk through reports and briefings, fitting Board Governance. Specificity is Domain-Adapted because it includes cybersecurity-specific terms like 'threat detection rates' and 'external penetration tests' that demonstrate domain expertise.


reasoning: The paragraph primarily addresses how cybersecurity impacts the business by stating no material incidents have occurred and speculating on potential material adverse effects, which aligns with Strategy Integration. It contains no specific facts, using only generic cybersecurity language, resulting in Generic Boilerplate specificity.


reasoning: This paragraph primarily answers how cybersecurity affects the business by stating a conclusion on material impact (no incidents have or are likely to materially affect operations or financial condition), fitting Strategy Integration per Rule 5. It contains no specific facts beyond a generic negative assertion and a reporting date, which does not elevate specificity above Level 1.


reasoning: This paragraph is a generic statement of commitment to protecting IT assets and data without describing any specific cybersecurity processes, roles, oversight, incidents, or business impacts, so it falls under None/Other. It contains no specific facts, domain-adapted terminology, or verifiable claims, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating that past incidents have not materially affected the company, which is a materiality assessment (Strategy Integration). It contains no specific facts—only generic statements about risks, actions, and investments—resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a negative conclusion about material incidents, which aligns with Strategy Integration. It contains no specific facts about cybersecurity practices, roles, or verifiable claims, making it generic boilerplate.


content_category: Incident Disclosure

fact: March 2021

fact: $2.4 million in costs for the year ended December 31, 2021

reasoning: The paragraph primarily answers 'What happened in a cybersecurity incident?' by detailing the March 2021 systems outage, its business impacts, and remediation, making it Incident Disclosure. It contains verifiable facts such as the specific date and quantified costs, elevating specificity to Level 4.


reasoning: The paragraph primarily describes the general context of cybersecurity risks and why ADP is a target due to the data and funds it handles, but it does not answer any specific questions about governance, management, processes, third-party risks, incidents, or strategy, making it None/Other. It contains no specific facts beyond generic risk language, with no verifiable or firm-specific details, so specificity is Generic Boilerplate.


reasoning: The paragraph directly addresses how third-party cyber risks are managed by describing steps to enhance monitoring and initiate a vendor risk management program, fitting Third-Party Risk. It contains no specific facts, names, numbers, or detailed processes, using only generic language that does not elevate specificity above Level 1.


fact: formal risk assessments

fact: data security controls and policies

fact: risk assessment and rating process

fact: contractual language involving collection, use, sharing and retention of user data and compliance with security terms

reasoning: The paragraph directly answers how third-party cyber risks are managed through assessments and contractual terms, fitting Third-Party Risk. It demonstrates cybersecurity domain expertise with specific practices like data security controls and risk rating processes, but lacks firm-specific or verifiable facts, resulting in Level 2 specificity.


fact: security incident and event manager interface

fact: behavioral analytics

fact: external and internal penetration testing

fact: system security assessments

reasoning: The paragraph focuses on cybersecurity program activities like incident response processes and tools, which aligns with Risk Management Process. It demonstrates domain expertise through specific terms such as SIEM and penetration testing, but lacks firm-specific or verifiable details, resulting in Domain-Adapted specificity.


reasoning: The paragraph primarily addresses how cybersecurity impacts the business by concluding that no incidents have had a material adverse effect and discussing insurance limitations, which aligns with Strategy Integration. It contains no specific, verifiable facts—only generic statements about materiality and insurance—resulting in Level 1 specificity.


fact: December 31, 2024

reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a materiality conclusion as of a specific date, making it Strategy Integration. The date 'December 31, 2024' is a verifiable fact, elevating specificity to Quantified-Verifiable.


reasoning: This paragraph states a conclusion about the material impact of cybersecurity incidents (backward and forward-looking), which directly aligns with Strategy Integration per Rule 5. It contains no specific facts about the company's cybersecurity program—only a generic negative assertion and a cross-reference—resulting in Generic Boilerplate specificity.


reasoning: This paragraph is solely a cross-reference to Item 1A for cybersecurity risk discussions, fitting the 'None/Other' category as it provides no substantive disclosure. As a cross-reference with no specific facts, it is assigned Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a materiality conclusion (no material impact), which aligns with Strategy Integration. It contains no specific, verifiable, or firm-unique facts, making it generic boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through vendor management policies and vetting processes, with a brief materiality conclusion appended. It contains no specific facts beyond generic descriptions, such as 'Vendor Management department' and standard risk mitigation language, resulting in Level 1 specificity.


reasoning: The paragraph describes oversight activities like reviewing regulatory reports and monitoring industry issues, which primarily answers how cybersecurity is overseen (Board Governance). It contains no specific facts—only generic descriptions of activities—making it generic boilerplate.


reasoning: The paragraph states a negative assertion about material cybersecurity incidents, which is a conclusion on materiality per Rule 5, fitting Strategy Integration. It contains no specific facts—only a generic negative statement, speculative language, and a cross-reference—making it generic boilerplate.


reasoning: This paragraph states a backward-looking conclusion about the lack of material cybersecurity incidents affecting business outcomes, which aligns with Strategy Integration. It contains no specific facts, domain-adapted terms, or verifiable claims, resulting in Generic Boilerplate specificity.


reasoning: The paragraph directly addresses how third-party cyber risks are managed through assessments, making Third-Party Risk the primary category. It contains no specific facts beyond generic descriptions of risk and compliance assessments, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating no material incidents have occurred and discussing potential costs, fitting Strategy Integration. It contains no specific, verifiable facts, using generic language about commitments and risks, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through assessments and requirements, fitting Third-Party Risk. It contains only generic process descriptions with no specific, verifiable, or domain-adapted facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers whether cybersecurity has affected the business by stating a negative conclusion about past incidents, which aligns with Strategy Integration. It contains no specific facts about the company's cybersecurity posture, as the negative incident assertion is not verifiable and the cross-reference is generic, resulting in Generic Boilerplate specificity.


fact: Cybersecurity Committee

reasoning: The paragraph primarily answers how cybersecurity affects the business by concluding that past incidents did not have a material impact, which is a Strategy Integration assessment. It contains a firm-specific fact, the 'Cybersecurity Committee,' which elevates specificity to Firm-Specific.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating that prior threats have not materially impacted it, which is a materiality assessment central to Strategy Integration. It contains no specific facts such as domain terms, firm-specific details, or verifiable claims, making it generic boilerplate.


reasoning: The paragraph discusses cybersecurity governance as part of risk management, aligning with business objectives and regulations, which primarily answers how oversight is structured (Board Governance). It uses generic language with no specific, verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a conclusion that risks have not materially affected operations to date but could in the future, which aligns with Strategy Integration. It contains no specific facts, domain terms, or verifiable claims, making it generic boilerplate.


fact: CISO has over thirty years of experience as a cybersecurity professional

fact: CSBDO has nearly twenty years of experience enabling digital transformation

fact: training at least annually on cybersecurity and information security for associates with access to confidential information

fact: overseen by VF's CISO and CSBDO

fact: maintains a cybersecurity risk insurance policy

reasoning: The paragraph primarily answers what the cybersecurity program does by detailing systems, processes, training, and incident response, with management roles described in oversight context; after person-removal, substantive program elements remain, supporting RMP. Specificity is driven by verifiable claims about CISO and CSBDO experience, along with firm-specific policies and roles, reaching Level 4.


reasoning: The paragraph describes incident response planning activities (reviews and drills) by senior management and an emergency team, which aligns with Risk Management Process. It contains no specific facts such as numbers, verifiable claims, or firm-unique details, using only generic terms like 'senior management' and 'Emergency Incident Response Team' without further specification.


content_category: Management Role

fact: Executive Vice President/Chief Information Security Officer with over 25 years' experience in cybersecurity risk management

fact: Chief Information Officer with over 27 years' experience in technology risk management

reasoning: The paragraph focuses on management organization, including leadership roles, qualifications, and reporting lines, which aligns with Management Role. It contains verifiable lower-bound claims about the CISO's and CIO's years of experience, setting specificity to Level 4.


fact: Cybersecurity attack occurred in May 2022

reasoning: The paragraph primarily describes a real cybersecurity incident from May 2022, including its nature (ransomware), response, and impact, fitting the 'Incident Disclosure' category. The specific date of the incident is a verifiable fact, elevating specificity to Level 4.


reasoning: The paragraph describes the board and audit committee's oversight structure for cybersecurity, fitting Board Governance. The mention of the Vice President, Information Systems and Technology is a firm-specific fact that elevates specificity to Level 3.


fact: TEP's Enterprise Cybersecurity team

fact: CISSP certification

fact: GICSP certification

fact: Electricity Information Sharing and Analysis Center

fact: Cybersecurity and Infrastructure Security Agency

fact: network monitoring

fact: vulnerability scanning

reasoning: The paragraph primarily answers what the cybersecurity program does by describing risk management activities like threat intelligence use and network monitoring, making it Risk Management Process. Specificity is Level 4 due to verifiable facts such as specific certifications (CISSP, GICSP) and named organizations (E-ISAC, CISA).


fact: compliance with applicable data protection laws

fact: implementation of administrative, physical, and technical safeguards

fact: data security addendum

fact: cybersecurity insurance

fact: mandatory incident reporting protocols

reasoning: The paragraph directly addresses how third-party cyber risks are managed by outlining vendor security requirements, fitting the Third-Party Risk category. It demonstrates cybersecurity domain expertise through specific terms like 'administrative, physical, and technical safeguards' and 'cybersecurity insurance,' but lacks firm-specific or verifiable details, placing it at Domain-Adapted specificity.


fact: In 2023, a third-party vendor experienced a cybersecurity incident due to a zero-day vulnerability in MOVEit Transfer software.

reasoning: The paragraph primarily describes actual cybersecurity incidents, including a specific 2023 event involving MOVEit Transfer, which is a verifiable fact that elevates specificity to Level 4.


reasoning: The paragraph primarily sets context about the Trust's lack of operations and data, with an incomplete reference to cybersecurity, but does not substantively answer any of the six cybersecurity questions (e.g., governance, processes, incidents), making it 'None/Other'. As a non-substantive paragraph, it is classified as Generic Boilerplate with no specific facts elevating specificity.


reasoning: This paragraph is a cross-reference to other disclosures and does not provide substantive cybersecurity information, fitting None/Other. It contains no specific facts, resulting in Generic Boilerplate specificity.


reasoning: This paragraph primarily describes the general cyber threat landscape without addressing the company's specific governance, management, risk processes, third-party risks, incidents, or strategic impacts, so it falls under 'None/Other'. It contains no firm-specific or verifiable facts and uses generic cybersecurity terminology, making it Generic Boilerplate.


fact: threat types including AI risks, hacktivists, state-sponsored organizations

specificity_confidence: medium

reasoning: The paragraph primarily answers how cybersecurity affects the business by concluding that no incidents have had a material adverse effect, which is a materiality assessment under Strategy Integration. It includes domain-specific threat terminology like 'state-sponsored organizations' and 'hacktivists', demonstrating cybersecurity expertise and elevating specificity to Level 2.


reasoning: The paragraph primarily answers whether cybersecurity has materially affected the business by stating no material impacts, which aligns with Strategy Integration per Rule 5. It contains no specific, verifiable, or domain-adapted facts, consisting entirely of generic statements, so specificity is Generic Boilerplate.


fact: network and perimeter defense

fact: infrastructure security

fact: cloud security

fact: endpoint protection

fact: data protection

fact: identity management

fact: network segmentation

fact: cybersecurity assessments

fact: cybersecurity threat intelligence

reasoning: The paragraph describes the cybersecurity program's tools and safeguards, directly answering what the program does (Risk Management Process). The specificity is Domain-Adapted because it lists cybersecurity-specific practices like endpoint protection and network segmentation, demonstrating domain expertise.


fact: formal policy related to employees that access corporate systems from personal devices

fact: migration of business-critical systems to Tier-1 cloud service providers

fact: two-factor authentication (2FA)

fact: real-time threat monitoring

reasoning: The paragraph primarily answers 'What does the cybersecurity program do?' by describing risk assessment processes and specific security measures, aligning with Risk Management Process. It contains domain-adapted terms like 'endpoint protection' and 'two-factor authentication,' demonstrating cybersecurity expertise, but lacks firm-specific or verifiable facts.


reasoning: The paragraph states a conclusion that cybersecurity risks have not materially affected the company, which directly answers the Strategy Integration question about business impact. It contains no specific, verifiable, or firm-unique facts, making it generic boilerplate.


reasoning: The paragraph primarily describes the establishment of a cybersecurity risk management program to address risks and regulatory requirements, aligning with Risk Management Process. It contains no specific facts such as domain-adapted terms, firm-specific details, or verifiable claims, using only generic risk and compliance language, resulting in Generic Boilerplate specificity.


reasoning: The paragraph centers on managing third-party cybersecurity risks via vendor assessments and contractual obligations, fitting Third-Party Risk. It lacks specific domain terminology, firm-unique details, or verifiable facts, making it generic boilerplate.


fact: Specific date: February 2023

fact: Cyberattack incident resulting in system interruption, data disclosure, litigation, and governmental inquiries

reasoning: The paragraph directly answers 'What happened in a cybersecurity incident?' by describing a real cyberattack in February 2023, making it Incident Disclosure. The specific date and incident details are externally verifiable facts, setting specificity to Level 4.


fact: phishing attempts

fact: ransomware

fact: malware

fact: computer viruses

fact: email attachments

fact: extortion

fact: scams

reasoning: This paragraph is classified as Strategy Integration because it states a negative assertion about material cybersecurity incidents, which is an assessment of materiality under SEC rules. The specificity is Level 2 due to the use of cybersecurity-specific threat terminology that demonstrates domain expertise.


reasoning: The paragraph directly addresses how third-party cyber risks are managed via contractual requirements on suppliers and vendors, aligning with the Third-Party Risk category. It lacks any domain-specific terminology, firm-unique details, or verifiable facts, rendering it generic boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating materiality conclusions (both backward and forward-looking), aligning with Strategy Integration. It contains no specific facts, domain terms, firm-specific details, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph is a generic statement about cybersecurity risks and potential impacts without describing any specific processes, governance, or incidents, so it fits 'None/Other'. It contains no specific facts, domain-adapted terms, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph states a conclusion about the material impact of cybersecurity incidents (backward and forward-looking), which aligns with Strategy Integration per Rule 5. It contains no specific facts—only a negative assertion and cross-reference—resulting in Generic Boilerplate specificity.


reasoning: This paragraph directly addresses the material impact of cybersecurity on the business, including past and potential future effects, which aligns with Strategy Integration. It contains no specific facts, domain-adapted terms, or verifiable claims, using only general language about materiality and a cross-reference, making it Generic Boilerplate.


reasoning: The paragraph primarily answers whether cybersecurity incidents have materially affected Verizon by stating a negative conclusion about past incidents and referencing future risks, which aligns with Strategy Integration. It contains no specific facts—only generic risk language and a non-verifiable negative assertion—making it generic boilerplate.


fact: Cyber Security Group

fact: Department of Homeland Security's list of Prohibited Nations

reasoning: The paragraph centers on vendor screening and supply chain protections, making Third-Party Risk the primary category. Specificity is driven by the verifiable reference to DHS's Prohibited Nations list and the firm-specific mention of the Cyber Security Group.


fact: lost revenue of approximately $80 million to $85 million

fact: operating earnings of $35 million to $40 million

fact: nine days to resume operations

reasoning: The paragraph primarily describes a specific cybersecurity incident with details on timing, impact, and response, fitting the Incident Disclosure category. It contains verifiable facts such as the incident date, financial loss ranges, and recovery duration, elevating specificity to Quantified-Verifiable.


fact: two-factor authentication

reasoning: The paragraph describes the Trust's cybersecurity protocols and personnel awareness, primarily answering what the cybersecurity program does (Risk Management Process). It includes the domain-specific term 'two-factor authentication,' which demonstrates cybersecurity expertise and elevates specificity to Level 2.


fact: CISO role title

fact: 30 years of information technology experience

fact: 17 years focused specifically on information security and risk management

reasoning: The paragraph primarily describes the CISO's responsibilities and qualifications, fitting Management Role. It contains verifiable facts about years of experience (30 and 17 years), elevating specificity to Quantified-Verifiable.


fact: CDO and CISO roles

fact: over 25 years of collective experience

fact: ISACA Certified Information Security Manager (CISM) certification

fact: ISC2 Certified Information Systems Security Professional (CISSP) certification

reasoning: The paragraph primarily answers how management is organized for cybersecurity by detailing the CDO and CISO roles, their qualifications, and responsibilities, fitting Management Role. Specificity is Level 4 due to verifiable facts like over 25 years of experience and named certifications (CISM, CISSP).


fact: John Bresney is EVP & CIO, reports directly to CEO

fact: John Bresney employed for approximately 30 years

fact: John Bresney has Columbia University CIO Program Certificate

fact: Robert McKenna is SVP of Enterprise Strategy and Execution, reports to CIO

fact: Robert McKenna has over 27 years of technology and information security experience

fact: Robert McKenna is a Certified Insurance Counselor

fact: Christopher Cunniff is SVP and CRO, reports to CFO and interim to CEO

fact: Christopher Cunniff has over 32 years of insurance industry experience

fact: Christopher Cunniff is a fellow of the Casualty Actuarial Society

fact: Christopher Cunniff chairs the ERC and Emerging Risk Committee

fact: Robert McKenna leads implementation of cybersecurity program and oversees incidents under Security Incident Response Plan (IRP)

reasoning: The paragraph focuses on management roles, responsibilities, and qualifications for cybersecurity, fitting Management Role. Specificity is Level 4 due to verifiable facts like specific years of experience, certifications, and firm-specific titles and reporting lines.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through evaluations and committee oversight, aligning with Third-Party Risk. It lacks any specific facts, relying on generic risk management language without domain-adapted or verifiable details.


reasoning: The paragraph primarily answers how cybersecurity affects the business by concluding that threats have not materially affected and are not reasonably likely to, but could in the future, which aligns with Strategy Integration. It contains no specific facts—only generic materiality assertions and a cross-reference—resulting in Generic Boilerplate specificity.


fact: security scoring

fact: threat intelligence

fact: cybersecurity risk posture

fact: continuous threat intelligence monitoring

reasoning: The paragraph directly addresses how third-party cyber risks are managed through supplier assessments, monitoring services, and contract provisions, fitting the Third-Party Risk category. It demonstrates cybersecurity domain expertise with terms like 'security scoring' and 'threat intelligence,' which elevate specificity to Level 2.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing implemented policies and systems to manage risks, aligning with Risk Management Process. It includes domain-specific terminology ('confidentiality, integrity and availability') that demonstrates cybersecurity expertise, raising specificity to Domain-Adapted.


fact: CIO and his security management team

reasoning: The paragraph focuses on the Board's oversight structure and Audit Committee updates, answering how the board oversees cybersecurity, so it is Board Governance. The mention of the CIO is a firm-specific role, which elevates specificity to Level 3.


fact: over 30 years of IT experience

fact: over 20 years specializing in cybersecurity

reasoning: This paragraph primarily answers how management is organized for cybersecurity, detailing the Senior Manager's role, qualifications, and reporting lines, which aligns with Management Role. The specificity is Quantified-Verifiable because it contains verifiable claims about the leader's experience (over 30 years in IT and over 20 years in cybersecurity).


reasoning: The paragraph centers on managing cybersecurity risks from third-party service providers, fitting the Third-Party Risk category. However, it contains no specific facts, domain-adapted terms, firm-specific details, or verifiable claims, making it generic boilerplate.


fact: Date: February 21, 2024

fact: Named entity: Change Healthcare, a subsidiary of UnitedHealth Group

fact: Specific role: acted as an intermediary for processing of our payment claims for all payors

reasoning: The paragraph primarily describes a specific cybersecurity incident involving Change Healthcare on February 21, 2024, including notification, response actions, and temporary impact, which aligns with Incident Disclosure. It contains verifiable facts such as the exact date and named third-party entity, making it Quantified-Verifiable.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating conclusions about materiality impact on strategy and finances, fitting Strategy Integration. It contains no specific facts, with all content being generic assertions about materiality and investments, resulting in Generic Boilerplate specificity.


fact: EVP, Chief Digital and Innovation Officer (CDIO)

fact: Vice President (VP) of Platforms, Infrastructure and Cybersecurity

fact: over 20 years of related experience

reasoning: This paragraph primarily answers how management is organized for cybersecurity by detailing specific leadership roles and their qualifications, fitting Management Role. The specificity is Level 4 due to the verifiable claim of 'over 20 years of related experience,' which is a quantified fact that could be externally checked.


fact: ransomware attack

reasoning: The paragraph primarily answers 'What happened in a cybersecurity incident?' by describing a ransomware attack in 2021, making it Incident Disclosure. The specificity is Level 4 because the year '2021' is a verifiable hard fact tied to a real event, and 'ransomware attack' is domain terminology.


fact: Director of Cybersecurity

fact: Chief Information Officer (CIO) reports directly to CEO

fact: CIO and Director of Cybersecurity both have over 20 years of cybersecurity oversight experience

fact: CIO previously served as CIO for a New York Stock Exchange listed manufacturing company

reasoning: The paragraph is categorized as Management Role because it focuses on cybersecurity leadership roles, responsibilities, and reporting lines. Specificity is Quantified-Verifiable due to verifiable claims such as 'over 20 years of experience' and specific previous employment details.


reasoning: The paragraph states that cybersecurity threats are reasonably likely to materially affect business strategy, results, or financial condition, which is a forward-looking materiality assessment fitting Strategy Integration. It contains no specific cybersecurity facts, processes, or verifiable claims, using only generic risk language, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business by discussing materiality assessments, investments in controls and insurance, and potential financial impacts, which aligns with Strategy Integration. It contains no specific, verifiable, or firm-unique facts, using only generic risk management language, resulting in Generic Boilerplate specificity.


fact: Specific disclosure date: February 22, 2024

reasoning: The paragraph describes an actual cybersecurity incident with a specific disclosure date, fitting Incident Disclosure, and the date is a verifiable fact, making it Quantified-Verifiable.


reasoning: The paragraph describes the Audit Committee's oversight of cybersecurity risks, which directly answers how the board oversees cybersecurity, fitting Board Governance. It contains no specific facts—only generic terms like 'Audit Committee' and 'risk oversight'—resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a conclusion that no threats have materially affected it, which aligns with Strategy Integration. It contains no domain-specific terms or verifiable facts, making it Generic Boilerplate.


fact: defense-in-depth and layered strategy

fact: endpoint detection and response

fact: network anomaly detection

fact: multi-factor authentication

fact: threat intelligence services

fact: phishing simulation exercises

reasoning: The paragraph focuses on describing the cybersecurity program's activities, such as risk management processes and specific security measures, aligning with Risk Management Process. It demonstrates cybersecurity expertise through domain-specific terms like endpoint detection and response and defense-in-depth, but lacks firm-specific or verifiable facts, resulting in Domain-Adapted specificity.


fact: automated event-detection notifications

fact: security operations team

fact: incident response team

reasoning: The paragraph primarily answers what the cybersecurity program does by describing incident detection and analysis processes, fitting Risk Management Process. It contains domain-specific terms like 'security operations team' and 'incident response team,' which demonstrate cybersecurity expertise and elevate specificity to Level 2.


reasoning: The paragraph states a conclusion about the material impact of cybersecurity risks on business strategy and operations, which aligns with Strategy Integration. It contains no specific facts about the company's cybersecurity posture, such as domain terms, firm-specific details, or verifiable claims, resulting in Generic Boilerplate specificity.


reasoning: This paragraph is a cross-reference to Item 1A Risk Factors for details on material cybersecurity impacts, so it does not substantively answer any of the six cybersecurity questions, fitting 'None/Other'. It contains no specific facts about cybersecurity practices, incidents, or governance, making it generic boilerplate with no elevated specificity.


fact: Third Party Risk Management (TPRM) program

fact: outside-in, hacker perspective

reasoning: The paragraph primarily describes how third-party cyber risks are managed through the TPRM program, making Third-Party Risk the central topic. It contains domain-specific terms like 'TPRM' and 'outside-in, hacker perspective,' which demonstrate cybersecurity expertise but lack firm-specific or verifiable details, resulting in Domain-Adapted specificity.


reasoning: The paragraph describes oversight by board-level committees (Audit and Risk Committees) monitoring cybersecurity governance, which directly answers how the board oversees cybersecurity, fitting Board Governance. It contains no specific, verifiable, or firm-unique facts, using only generic governance language, so specificity is Generic Boilerplate.


fact: CISO role

fact: Core Cybersecurity Management Team (CCMT)

fact: Cyber Incident Response Plan (CIRP)

reasoning: The paragraph primarily answers how management is organized for cybersecurity, focusing on the CCMT and its responsibilities, which aligns with Management Role. It contains firm-specific facts such as the CISO, CCMT committee, and CIRP program, setting specificity at Level 3.


reasoning: The paragraph directly answers how third-party cyber risks are managed by describing vendor security responsibilities and periodic assessments, fitting Third-Party Risk. It contains no specific facts, domain-adapted terms, firm-specific details, or verifiable claims, making it generic boilerplate.


fact: CSO (Chief Security Officer) role

reasoning: The paragraph primarily describes the cybersecurity program's activities, such as risk assessment and incident response, fitting Risk Management Process. Specificity is Firm-Specific due to the mention of the CSO role, which is a firm-specific cybersecurity leadership position.


reasoning: The paragraph primarily answers how cybersecurity affects the business by concluding that no threats have materially affected operations, which is a materiality assessment under Strategy Integration. It contains no specific facts beyond generic process descriptions, making it generic boilerplate.


fact: defense in depth strategy

fact: encryption

fact: data loss prevention technology

fact: advanced transport layer security encryption

fact: information security awareness training

fact: evolving threats such as phishing, malware and social engineering testing

reasoning: The paragraph describes the cybersecurity program's activities, such as defense in depth, encryption, and employee training, which directly answers what the program does, making it Risk Management Process. It contains domain-specific terms like 'defense in depth' and 'transport layer security' that demonstrate cybersecurity expertise, elevating specificity to Level 2.


fact: Chief Innovation Officer

fact: information technology security processes and procedures

fact: assessment of risks and threats

fact: internal controls regarding information technology security and cybersecurity

fact: steps to monitor and mitigate risks

reasoning: The paragraph focuses on the Board and Audit Committee's oversight roles in cybersecurity, answering how the board oversees cybersecurity, which aligns with Board Governance. It contains firm-specific facts like the Chief Innovation Officer role and domain-adapted terms such as specific cybersecurity processes and controls, elevating specificity to Level 3.


reasoning: The paragraph is a generic introduction that does not answer any of the six substantive cybersecurity questions (e.g., board oversight, management roles, risk processes), so it is classified as 'None/Other'. It contains no specific facts—only broad, non-domain-adapted statements about cybersecurity importance—resulting in Generic Boilerplate specificity.


fact: CISO

reasoning: The paragraph describes the Board's annual briefings from the CISO and periodic external expert presentations, directly addressing how the board oversees cybersecurity (Board Governance). The mention of 'our CISO' is a firm-specific fact that distinguishes the company's cybersecurity leadership role, elevating specificity to Level 3.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating no material incidents occurred and ongoing risks could materially impact operations, which is a materiality assessment under Strategy Integration. It contains no specific facts, using generic language without domain expertise or verifiable claims, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business by making a materiality assessment (no material incidents to-date and potential future impact), fitting Strategy Integration. It contains no specific facts—only generic statements and speculative language—resulting in Generic Boilerplate specificity.


fact: February 21, 2024 incident notification date

fact: Change Healthcare (subsidiary of UnitedHealth Group) as the affected vendor processing payment claims

reasoning: The paragraph primarily describes a specific cybersecurity incident involving Change Healthcare, including the date, response actions, and impact, making it Incident Disclosure. The verifiable date and named third party provide hard facts that elevate specificity to Quantified-Verifiable.


fact: Chief Information Officer (CIO) role

fact: CIO has more than 30 years of experience

fact: Team holds Certified Information Systems Security Professional (CISSP)

fact: Team holds Certified Information Security Manager (CISM)

fact: Team holds Microsoft Certified Cybersecurity Architect Expert

fact: Team holds Security+

fact: Team holds Certified Information Systems Auditor (CISA)

fact: Team holds Master's in Cybersecurity

fact: Team holds Graduate Certificates in Enterprise Cybersecurity and Data Science

reasoning: The paragraph primarily answers how management is organized for cybersecurity, focusing on the CIO's role and team qualifications, making it Management Role. Specificity is Level 4 due to verifiable facts such as the CIO's 30+ years of experience and specific certifications like CISSP and CISM held by the team.


reasoning: This paragraph is a cross-reference to risk factor disclosures and does not provide substantive cybersecurity information, classifying it as None/Other. It contains no specific facts, only generic references to cybersecurity threats and incidents, resulting in Generic Boilerplate specificity.


fact: 24/7 security operations center

reasoning: The paragraph describes cybersecurity program activities such as incident response plans, security operations, and employee training, which primarily answers 'What does the cybersecurity program do?' aligning with Risk Management Process. The firm-specific claim of a '24/7 security operations center' elevates specificity to Level 3.


fact: Chief Information Officer (CIO)

fact: reports to the CFO

fact: peer to the CSO

fact: appointed in March 2022

fact: nearly 20 years of experience in managing IT functions

reasoning: This paragraph primarily answers how management is organized for cybersecurity by detailing the CIO's role, reporting structure, and qualifications, making it Management Role. It contains verifiable facts such as the specific appointment date (March 2022), which elevates specificity to Level 4.


fact: Material cybersecurity incident occurred in 2017

fact: Incident involved theft of personal information from U.S., Canadian, and U.K. consumers

reasoning: The paragraph primarily answers 'What happened in a cybersecurity incident?' by referencing the real 2017 material incident, making it Incident Disclosure. It contains verifiable facts about the incident's year and scope of data theft, which are externally confirmable, leading to Level 4 specificity.


reasoning: The paragraph primarily describes implemented cybersecurity processes and potential risks, answering 'What does the cybersecurity program do?' for Risk Management Process. It contains no specific facts, using generic boilerplate language about risks and controls without domain expertise or firm-unique details.


fact: dedicated department within its Enterprise Risk Management division

fact: Bank's Information Technology Department

reasoning: The paragraph directly answers how third-party cyber risks are managed by describing a dedicated department and collaboration with the Bank's IT Department, centralizing it as Third-Party Risk. It contains firm-specific structural details that distinguish the company's approach, elevating specificity to Firm-Specific.


reasoning: The paragraph centrally describes how third-party cyber risks are managed through due diligence, risk assessments, and monitoring, aligning with Third-Party Risk. It contains no specific facts such as domain-adapted terms, firm-specific details, or verifiable claims, resulting in Generic Boilerplate specificity.


fact: our wholly-owned subsidiary Umpqua Bank

fact: MOVEit, a filesharing software

fact: unauthorized acquisition of names and social security numbers or tax identification numbers

fact: consumer and small business customers

fact: On June 22, 2023, sent an email to potentially affected customers

fact: In August 2023, sent notice via U.S. mail

fact: 429,252 Umpqua Bank customers

reasoning: The paragraph describes a real cybersecurity incident (the MOVEit-related Vendor Incident) with specific dates, scope, and remediation actions, fitting Incident Disclosure. Specificity is Level 4 due to verifiable facts like the exact number of affected customers (429,252) and precise dates.


fact: forensic reviews

fact: cybersecurity-related incidents

reasoning: The paragraph primarily answers what the cybersecurity program does by describing the use of external assessors for security activities, fitting Risk Management Process. The specificity is Domain-Adapted due to cybersecurity-specific terms like 'forensic reviews' and 'cybersecurity-related incidents' that demonstrate domain expertise.


fact: CIO

fact: Director of IT Security, Risk and Compliance

fact: combined 20 years of experience

fact: threat assessments

fact: risk management

fact: cybersecurity insurance

fact: incident response

fact: end user awareness

fact: vulnerability management

reasoning: This paragraph primarily answers how management is organized for cybersecurity by describing the ISC members and their experience, fitting the Management Role category. The specificity is elevated to Level 4 due to the verifiable fact of 20 years of combined experience, along with firm-specific roles and domain-adapted terms.


reasoning: The paragraph directly addresses how third-party cyber risks are managed through risk assessments and monitoring, but it uses generic language without any specific, verifiable facts, resulting in a boilerplate description.


reasoning: The paragraph centers on vendor due diligence and risk assessment for third-party vendors, directly answering how third-party cyber risks are managed, so it is Third-Party Risk. It uses generic risk management language (e.g., 'assessing and managing cyber risks') without any firm-specific details, domain-adapted terms, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph primarily answers 'What does the cybersecurity program do?' by describing the integration of cybersecurity risk management into the enterprise risk management process and annual assessments overseen by the Audit Committee. It contains no specific facts, only generic statements about processes and oversight, making it generic boilerplate.


reasoning: The paragraph speculates on potential cybersecurity risks without describing any actual processes, governance, or firm-specific details, fitting None/Other. It contains no specific facts, relying entirely on generic boilerplate language.


reasoning: The paragraph consists of forward-looking disclaimers and a cross-reference to risk factors, with no substantive cybersecurity disclosure, making it None/Other. It contains no specific facts, so specificity is Generic Boilerplate.


reasoning: This paragraph describes a management executive's career history and responsibilities without any reference to cybersecurity, so it answers none of the cybersecurity-related questions and is classified as None/Other. As per the rules, None/Other paragraphs are always assigned Generic Boilerplate specificity.


reasoning: This paragraph describes a human resources officer's role and background with no mention of cybersecurity, so it falls under None/Other. As a None/Other paragraph, it is assigned Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a conclusion on materiality (no material impacts to date but future risks), which aligns with Strategy Integration. It contains no specific facts—only generic statements and unverifiable negative assertions—resulting in Generic Boilerplate specificity.


reasoning: This paragraph is a cross-reference to risk factors in Item 1A and does not describe any cybersecurity governance, management, processes, or incidents, so it falls under 'None/Other'. It contains no specific facts about cybersecurity measures or verifiable claims, making its specificity Generic Boilerplate.


fact: CRO, CIO, and CISO each have over 15 years experience in managing cybersecurity

fact: CRO has more than 30 years of experience

fact: CRO is a member of RGA's Executive Committee

fact: CRO served as Global Chief Risk Officer

fact: CIO is a member of RGA's Executive Committee

reasoning: The paragraph describes management roles, responsibilities, and qualifications for cybersecurity, fitting Management Role. It includes verifiable claims about years of experience (e.g., over 15 years, more than 30 years), setting specificity at Level 4.


reasoning: The paragraph primarily describes the company's cybersecurity programs and processes to manage risks, aligning with Risk Management Process. However, it uses generic language with no specific, verifiable, or firm-unique facts, resulting in Generic Boilerplate specificity.


fact: Retrieval-Masters Credit Bureau, Inc. d/b/a/ American Medical Collections Agency (AMCA)

reasoning: The paragraph primarily answers 'What happened in a cybersecurity incident?' by detailing the AMCA Incident with a specific date and named third-party, fitting Incident Disclosure. It contains verifiable facts (exact date and entity name), elevating specificity to Quantified-Verifiable.


reasoning: The paragraph primarily addresses how cybersecurity impacts business operations and finances by discussing IT system dependence, a negative assertion about material incidents, and potential consequences, fitting Strategy Integration. No specific facts are present; the language is generic with a non-verifiable negative claim, resulting in Generic Boilerplate specificity.


reasoning: The paragraph centrally focuses on managing third-party cybersecurity risks through evaluations, contractual safeguards, and integration into incident response plans, fitting the Third-Party Risk category. It lacks any firm-specific or verifiable facts, using only generic process descriptions that do not demonstrate cybersecurity domain expertise, resulting in Generic Boilerplate specificity.


reasoning: The paragraph focuses on contractual requirements imposed on the Custodian to manage third-party cyber risks, fitting the TP category. It contains no specific, verifiable facts—only generic language about cybersecurity measures and incident reporting—resulting in Level 1 specificity.


reasoning: The paragraph centers on managing cybersecurity risks from third-party acquisition targets through due diligence and testing, aligning with Third-Party Risk. It describes general processes without specific cybersecurity domain terms, firm-unique details, or verifiable claims, resulting in Generic Boilerplate specificity.


reasoning: This paragraph directly answers how cybersecurity affects the business by concluding that no incidents have materially impacted strategy, finances, or operations, which is a Strategy Integration assessment. It contains no specific facts such as domain terms, firm-specific details, or verifiable claims, making it generic boilerplate.


reasoning: The paragraph primarily answers how cybersecurity risks are managed through integration into the enterprise risk management (ERM) process and audit planning, aligning with Risk Management Process. It contains no specific facts, domain-adapted terminology, firm-specific details, or verifiable claims, making it generic boilerplate.


fact: Over 18 years of experience in information technology and information security

fact: Master's degree in business administration from Boston University

fact: Master's degree in electrical and computer engineering from Utah State University

fact: Bachelor's degree in electronics engineering from Mumbai University

fact: Previous employment at Biogen, AstraZeneca, Iron Mountain, and consulting roles at Charles River Labs, Sunovion Pharmaceuticals, Agero, DentaQuest

fact: Information Technology team has over 10 years of experience with managing cybersecurity risks

reasoning: This paragraph primarily answers how management is organized for cybersecurity, focusing on the VP's role, responsibilities, and qualifications, so it is Management Role. It contains multiple verifiable facts such as specific years of experience, degrees from named universities, and previous employers, making it Quantified-Verifiable.


fact: IT security

fact: privacy

fact: Information Security

reasoning: The paragraph centers on managing cybersecurity risks from third-party service providers, directly answering how third-party cyber risks are handled, which aligns with Third-Party Risk. Specificity is Domain-Adapted because it includes domain terms like 'IT security' and 'Information Security' that demonstrate cybersecurity expertise beyond generic risk management language.


fact: Chief Security Officer (CSO) role

fact: Reports to CFO

fact: Served since 2018

fact: Over 14 years of global executive cybersecurity experience

reasoning: This paragraph primarily answers how management is organized for cybersecurity by detailing the CSO's responsibilities, reporting line, tenure, and qualifications. The specificity is Quantified-Verifiable because it contains the verifiable claim of 'over 14 years of experience,' which is a hard fact that can be independently checked.


fact: CISO

fact: over 20 years of information technology and cybersecurity experience

fact: team comprises security engineers, detection specialists, and business cybersecurity experts

reasoning: The paragraph primarily answers how management is organized for cybersecurity by detailing the CISO's qualifications and team composition, fitting Management Role. Specificity is Quantified-Verifiable due to the verifiable claim of over 20 years of experience and firm-specific team roles.


fact: information security programs

fact: cybersecurity protocols

fact: information security incidents

reasoning: The paragraph directly addresses how third-party cyber risks are managed through due diligence, contractual controls, and incident coordination, fitting the Third-Party Risk category. It employs cybersecurity-specific terminology such as 'information security programs' and 'cybersecurity protocols', indicating domain expertise, but contains no firm-specific or quantified-verifiable facts.


fact: aligned with the National Institute on Standards and Technology Cybersecurity Framework

fact: third party security operation center

fact: multi-factor authentication

fact: access controls

fact: email filtering

fact: firewalls

fact: intrusion prevention and detection systems

fact: partitioning and encryption of information

fact: backup and data recovery procedures

fact: malware defenses

fact: disaster recovery and incident plan responses

fact: hardware and software updates and patching

reasoning: The paragraph primarily describes the cybersecurity program's processes and tools, fitting Risk Management Process. It contains multiple domain-specific terms like NIST CSF and various security controls, demonstrating cybersecurity expertise and elevating specificity to Domain-Adapted.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating no material incidents to date and warning about future impacts, which aligns with Strategy Integration under Rule 5. It contains no specific facts, only generic risk statements, making it Generic Boilerplate.


fact: pre-onboarding security assessments

fact: annual re-assessments

fact: third-party security controls

reasoning: The paragraph centrally addresses third-party cyber risk management through policies and assessments, fitting the Third-Party Risk category. It contains domain-specific terms like 'pre-onboarding security assessments' and 'annual re-assessments' that demonstrate cybersecurity expertise, but lacks firm-specific or verifiable details, resulting in Domain-Adapted specificity.


reasoning: The paragraph states a conclusion about the lack of material cybersecurity incidents and the low likelihood of future material impact, directly answering how cybersecurity affects the business, which fits Strategy Integration. It contains no specific, verifiable facts—only negative assertions and generic risk language—making it generic boilerplate.


reasoning: The paragraph describes the Board's oversight of cybersecurity risk management through the Audit and Compliance Committee and interactions with senior management, which directly answers how the board oversees cybersecurity, making it Board Governance. It contains no specific facts beyond generic governance roles and interactions, such as 'ERM process' and 'Director - Information Systems', which do not demonstrate cybersecurity expertise or firm-specific details, resulting in Generic Boilerplate specificity.


fact: CISO has more than 20 years of experience in cybersecurity and information technology

fact: CISO holds a Master's degree in Business Administration with a focus on Information Technology

fact: CISO holds a Certified Information Security Manager (CISM) certification

reasoning: The paragraph primarily answers how management is organized for cybersecurity by detailing the CISO's responsibilities, qualifications, and reporting structure, making it Management Role. Specificity is Level 4 because it contains verifiable facts such as the CISO's years of experience, educational background, and professional certification.


fact: Chief Security and Trust Officer

fact: reports to Executive Vice President, Operations

fact: over 25 years of experience

reasoning: The paragraph primarily answers how management is organized for cybersecurity by detailing the Chief Security and Trust Officer's role, reporting line, and qualifications, fitting Management Role. It contains verifiable facts such as the specific title, reporting structure, and a quantified experience claim ('over 25 years'), elevating specificity to Quantified-Verifiable.


fact: Incident involving Progress Software Corporation's MOVEit Transfer in 2023

fact: Vendor implemented recommended patches released by Progress Software Corporation

fact: MOVEit Transfer incident materially affected the Corporation during the 2023 fiscal year

reasoning: The paragraph primarily describes a specific cybersecurity incident (MOVEit Transfer) with details on its nature, scope, response, and impact, fitting Incident Disclosure. It contains verifiable facts such as the named incident, timing, and actions taken, which elevate specificity to Quantified-Verifiable.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a materiality conclusion (no material effects or likely effects), which aligns with Strategy Integration. It contains no specific facts, using generic language about third-party risk management and a non-verifiable negative assertion, resulting in Generic Boilerplate specificity.


fact: penetration testing

fact: information security risk assessments

fact: risk weighted basis

fact: security posture

reasoning: The paragraph primarily answers how third-party cyber risks are managed through vendor assessments, monitoring, and legal requirements, making it Third-Party Risk. It demonstrates cybersecurity domain expertise with terms like 'penetration testing' and 'risk weighted basis,' but lacks firm-specific or verifiable facts, so specificity is Domain-Adapted.


reasoning: The paragraph primarily answers how the board oversees cybersecurity risk through quarterly reports and incident communication, fitting Board Governance. It contains no specific facts—only generic oversight descriptions like 'quarterly' cadence and vague thresholds—resulting in Generic Boilerplate specificity.


fact: On February 16, 2022, we became aware of a cybersecurity intrusion

reasoning: The paragraph primarily discloses a specific cybersecurity incident on February 16, 2022, answering 'What happened?', and the verifiable date elevates specificity to Level 4.


reasoning: The paragraph centrally discusses managing cybersecurity risks of third-party service providers through vendor oversight processes, fitting Third-Party Risk. It uses generic language with no specific, verifiable, or firm-unique facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a negative assertion about past material incidents and speculating on future impacts, which is a Strategy Integration assessment. It contains no specific facts; the language is generic and the negative assertion is not externally verifiable, resulting in Generic Boilerplate.


reasoning: The paragraph centers on managing cybersecurity risks from third-party vendors through due diligence and contractual obligations, fitting Third-Party Risk. It contains no specific facts—only generic risk assessment language without domain expertise, firm-specific details, or verifiable claims, resulting in Generic Boilerplate specificity.


reasoning: This paragraph is a cross-reference to Item 1A Risk Factors for details on cybersecurity risks, providing no substantive cybersecurity disclosure, hence None/Other. It contains no specific facts, making it Generic Boilerplate.


fact: The Risk Committee

fact: Incident Management and Information Security Plan

reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Risk Committee's assurances, fitting Board Governance. It contains firm-specific facts like the named committee and plan, elevating specificity to Firm-Specific.


reasoning: The paragraph primarily describes the company's cybersecurity risk management processes, such as policies and standards for incident response and access control, but it uses generic language without any firm-specific or verifiable details, making it generic boilerplate.


fact: February 16, 2022

reasoning: The paragraph primarily describes a real cybersecurity incident on February 16, 2022, including detection and response, fitting Incident Disclosure. The specific date is a verifiable fact, elevating specificity to Level 4.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a materiality conclusion (risks have not materially affected and are not reasonably likely to materially affect), which aligns with Strategy Integration. It contains no specific facts—only generic language about threats and measures—resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a negative assertion about material incidents and discussing insurance and potential financial impacts, fitting Strategy Integration. It contains no specific facts—only generic statements about incidents, insurance, and risks—resulting in Generic Boilerplate specificity.


reasoning: This paragraph is a generic statement of commitment to data protection that does not describe specific board governance, management roles, risk processes, third-party risks, incidents, or strategy integration, so it falls under None/Other. As a None/Other paragraph, it is assigned Generic Boilerplate specificity by rule.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Audit Committee reporting and management briefings, fitting Board Governance. It contains no specific facts, domain-adapted terms, or verifiable claims, making it generic boilerplate.


reasoning: The paragraph directly addresses the management of cybersecurity risks from third parties, making Third-Party Risk the primary category. It uses generic language like 'risk-based approach' without any specific practices, tools, or verifiable details, resulting in Generic Boilerplate specificity.


fact: ISMS

fact: information security governance framework

fact: Chief Information Officer

reasoning: The paragraph primarily describes the board's oversight of cybersecurity through its audit and risk committee and management updates, fitting Board Governance. Specificity is Firm-Specific due to named senior roles (CIO, Executive Director of Information Security) and domain terms like ISMS that demonstrate cybersecurity expertise.


reasoning: This paragraph primarily serves as a forward-looking disclaimer about potential cybersecurity incidents and a cross-reference to risk factors, containing no substantive cybersecurity disclosure. It lacks any specific facts, domain terms, firm-specific details, or verifiable claims, making it generic boilerplate.


fact: Head of Global IT

fact: IT Security Team

fact: CompTIA certifications

fact: over 20 years of combined infrastructure architecture experience

fact: PCI, SOC1, SOC2 level compliance

reasoning: The paragraph primarily answers how management is organized for cybersecurity by detailing the Head of Global IT and IT Security Team's roles, responsibilities, and qualifications, making it Management Role. Specificity is Quantified-Verifiable due to verifiable facts like CompTIA certifications and the lower-bound claim of over 20 years of combined experience.


fact: security questionnaires

fact: vulnerability scans

reasoning: The paragraph primarily addresses how third-party cyber risks are managed through vendor assessments and contractual obligations, fitting Third-Party Risk. It includes domain-specific practices like security questionnaires and vulnerability scans, which demonstrate cybersecurity expertise and elevate specificity to Level 2.


reasoning: The paragraph primarily answers how management is organized to handle cybersecurity incidents by specifying CEO and CFO oversight and decision-making roles, with board notification as a secondary element; it contains no firm-specific, verifiable, or domain-adapted facts beyond generic procedural language.


fact: firewalls

fact: intrusion prevention

fact: endpoint detection and response systems

fact: access controls

fact: vulnerability assessments

fact: cybersecurity threat intelligence

reasoning: This paragraph describes the technical safeguards and processes of the cybersecurity program, directly answering what the program does, so it is classified as Risk Management Process. The specificity is Domain-Adapted because it includes multiple cybersecurity-specific terms like firewalls, intrusion prevention, and endpoint detection and response, demonstrating domain expertise beyond generic risk management language.


fact: February 2022

fact: approximately three weeks

fact: Chief Information Security Officer (CISO)

fact: CSRM program

reasoning: The paragraph describes a real cybersecurity incident from February 2022, including its scope, impact, and response, which aligns with Incident Disclosure. It contains verifiable facts like the specific date and duration of the incident, as well as firm-specific details such as the addition of a CISO and the CSRM program, justifying a Quantified-Verifiable specificity level.


reasoning: The paragraph directly answers how third-party cyber risks are managed, fitting the Third-Party Risk category. It contains no specific facts, using generic risk management language that does not demonstrate cybersecurity expertise or firm-specific details, resulting in Generic Boilerplate specificity.


reasoning: This paragraph is a generic introductory statement that does not provide substantive cybersecurity details, fitting None/Other, and contains no specific facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph centers on managing third-party cyber risks through vendor evaluation and contractual safeguards, but it lacks any domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


fact: CISO

reasoning: The paragraph describes board oversight through regular briefings from the CISO and management to the Audit and Risk Committee and Board, fitting Board Governance. The specific mention of 'CISO' is a firm-specific cybersecurity leadership role, elevating specificity to Level 3.


reasoning: The paragraph is a generic statement about ongoing investment in cybersecurity and a cross-reference to risk factors, providing no substantive disclosure on governance, processes, or incidents, so it is classified as None/Other. No specific facts, domain expertise, firm-specific details, or verifiable claims are present, making it Generic Boilerplate.


reasoning: The paragraph describes cybersecurity risk assessment processes, directly answering what the program does, which aligns with Risk Management Process. The language is generic and lacks any specific, domain-adapted, firm-unique, or verifiable facts, resulting in Generic Boilerplate specificity.


fact: Director of IT Infrastructure and Security

fact: over 30 years of experience

fact: GIAC Security Essentials certification

fact: GIAC Certified Enterprise Defender certification

fact: GIAC Certified Incident Handler Certification

fact: GIAC Certified Windows Security Administrator certification

fact: GIAC Critical Controls Certification

fact: Vice President of Information Technology

fact: over 19 years of experience

fact: Masters of Business Administration

fact: Certified Information Systems Security Professional certification

reasoning: The paragraph primarily answers how management is organized for cybersecurity, focusing on leadership roles, qualifications, and reporting lines, making it Management Role. It contains verifiable facts such as specific years of experience and named certifications, which elevate specificity to Level 4.


fact: CIO has more than 30 years of experience

fact: CIO's prior roles at Aegon N.V., Citigroup, Inc., and JP Morgan Chase & Company

fact: CISO has more than 20 years of cybersecurity experience

fact: CISO's prior roles at Brighthouse Financial, GE Healthcare, and Allstate Insurance Company

fact: CISO holds certifications: CISA, CISM, CISSP

reasoning: This paragraph primarily answers how management is organized for cybersecurity by detailing the CIO and CISO's experience and qualifications, fitting 'Management Role'. It contains multiple verifiable facts, including years of experience, prior employment at named companies, and specific certifications, setting specificity at Level 4.


reasoning: The paragraph primarily answers how the board oversees risk management, fitting Board Governance, but it contains no specific cybersecurity terms, firm-unique details, or verifiable facts, making it generic boilerplate.


fact: Cybersecurity incident detected in early April 2023

reasoning: The paragraph describes a specific cybersecurity incident with detection and response actions, fitting Incident Disclosure. The verifiable date of the incident (early April 2023) elevates specificity to Quantified-Verifiable.


fact: SOC Reports

reasoning: The paragraph directly addresses how third-party cyber risks are managed through processes like diligence, contracts, and monitoring, central to the Third-Party Risk category. The reference to SOC Reports demonstrates cybersecurity domain expertise, elevating specificity to Domain-Adapted.


fact: risk assessments

fact: security questionnaires

fact: review of vendor security programs

fact: review of available security assessments, reports, and audits

reasoning: The paragraph centers on managing cybersecurity risks from third-party providers, directly answering the Third-Party Risk question. It includes domain-specific practices like security questionnaires and vendor security program reviews, which demonstrate cybersecurity expertise and elevate specificity to Domain-Adapted, but lacks firm-specific or verifiable facts.


fact: SOC 2

reasoning: The paragraph centers on managing cybersecurity risks with third-party vendors through assessments and imposed security requirements, making Third-Party Risk the primary category. Specificity is Domain-Adapted due to references to cybersecurity standards like SOC 2 and ISO 27001, which demonstrate domain expertise beyond generic risk management language.


fact: Announcement date of cybersecurity incident: October 11, 2023

fact: Disruption duration: approximately three days

fact: Time to restore operations: within three days

fact: Time to fulfill backlog: within one week

reasoning: The paragraph focuses on describing a specific cybersecurity incident that occurred, including its date, scope, and resolution, which aligns with the Incident Disclosure category. It contains verifiable facts such as the announcement date (October 11, 2023) and specific timeframes, making the specificity Level 4.


reasoning: The paragraph primarily answers how the board oversees cybersecurity by describing board commitment and delegation to the audit committee, fitting Board Governance. It contains no specific facts, using generic language that lacks cybersecurity domain expertise or verifiable details, resulting in Generic Boilerplate specificity.


fact: The Board has not assigned cybersecurity oversight responsibility to any committee or subcommittee

reasoning: The paragraph directly addresses how the board oversees cybersecurity by describing its retained responsibility and management updates, fitting Board Governance. It contains a firm-specific fact about the Board not delegating oversight to any committee, which distinguishes Unitil's governance structure and elevates specificity to Level 3.


reasoning: This paragraph primarily answers how the board oversees cybersecurity through regular reporting to the Board and Audit Committee, fitting Board Governance. It contains no specific facts—only generic oversight language with no verifiable claims, firm-specific details, or domain expertise—resulting in Generic Boilerplate specificity.


reasoning: This paragraph is a cross-reference to another section of the filing and does not describe any specific cybersecurity governance, processes, or incidents, so it is classified as None/Other. It contains no substantive facts, resulting in Generic Boilerplate specificity.


fact: FFIEC

fact: NIST

reasoning: The paragraph primarily describes how the company designs its Information Security Program using specific industry frameworks (FFIEC and NIST), which answers the question of what the cybersecurity program does, fitting Risk Management Process. The specificity is Domain-Adapted because it references named cybersecurity frameworks that demonstrate domain expertise, but lacks firm-specific or verifiable facts.


fact: mentions specific threat types: malware and computer virus attacks

reasoning: This paragraph is classified as Strategy Integration because it directly states a conclusion about the material impact of cybersecurity risks on the business. Specificity is Domain-Adapted due to the inclusion of cybersecurity-specific threat terminology (malware and computer virus attacks), which demonstrates domain expertise beyond generic risk language.


fact: Incident occurred in the fourth quarter of fiscal year 2019

fact: Ransomware incident encrypted information on systems

fact: Disrupted customer and employee access to systems and services

fact: Costs incurred to retain third-party consultants and forensic experts

fact: Assistance from law enforcement in investigation

fact: Adversely affected operations and fourth quarter 2019 revenue

reasoning: The paragraph primarily describes a specific past cybersecurity incident (ransomware in Q4 2019), fitting Incident Disclosure. It contains verifiable facts such as the exact timing and details of the attack, supporting Quantified-Verifiable specificity.


reasoning: This paragraph is solely a cross-reference to Item 1A for cybersecurity risk discussion, providing no substantive disclosure on governance, processes, or incidents, so it is classified as 'None/Other'. It contains no specific facts about cybersecurity measures, roles, or verifiable claims, resulting in 'Generic Boilerplate' specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business by concluding that no material incidents have occurred and acknowledging potential future impacts, which is a materiality assessment under Strategy Integration. It contains no specific facts, only generic risk descriptions and boilerplate language, resulting in Generic Boilerplate specificity.


reasoning: The paragraph centrally describes assessing third-party service providers' security measures and breach reporting, fitting Third-Party Risk. It contains no specific domain terms, firm-unique facts, or verifiable claims, making it generic boilerplate.


fact: ransomware actors

fact: exfiltrated personal information

reasoning: The paragraph describes an actual cybersecurity incident involving ransomware and potential data exfiltration, directly answering 'What happened?' for Incident Disclosure. Specificity is Level 2 due to domain terms like 'ransomware' and 'exfiltrated,' which demonstrate cybersecurity expertise beyond generic risk management language.


reasoning: This paragraph generically acknowledges cybersecurity risks and their importance for business success but does not answer any substantive questions about governance, management, processes, or incidents, making it None/Other. It contains no specific facts, domain expertise, firm-specific details, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph is a generic statement about technology reliance and associated security risks that does not answer any specific cybersecurity question (e.g., governance, management, processes, incidents, or strategy), so it is classified as None/Other. It contains no specific facts—only vague references to 'digital technology' and 'security risks'—resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the integration and cross-functional approach of the information security program, which primarily answers what the cybersecurity program does, fitting Risk Management Process. It contains no specific facts, using generic language that fails to demonstrate cybersecurity domain expertise, firm-specific details, or verifiable claims, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through vendor assessment and oversight, fitting the Third-Party Risk category. It contains no specific verifiable or firm-unique facts, using generic risk management language that does not elevate above Level 1.


reasoning: The paragraph is solely a cross-reference to risk factors in another section, providing no substantive cybersecurity disclosure, so it is classified as 'None/Other'. It contains no specific facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes board oversight of cybersecurity through Audit Committee conversations and Board updates, fitting Board Governance. It contains no specific facts, using only generic governance language without verifiable or firm-specific details, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily describes how the Board and Audit Committee oversee cybersecurity, fitting Board Governance. It contains no firm-specific, domain-adapted, or verifiable facts, using only generic governance language, so specificity is Level 1.


reasoning: The paragraph primarily answers how third-party cyber risks are managed by emphasizing the Company's dependence on the Investment Adviser and other service providers for cybersecurity, making Third-Party Risk the central topic. It contains no specific facts—only generic descriptions of processes and reliance—so specificity remains at Level 1.


reasoning: The paragraph primarily answers how cybersecurity risks are managed through integration into the enterprise risk management program and a general cross-functional approach, aligning with Risk Management Process. It contains no specific facts, using only generic language without verifiable or firm-specific details, resulting in Generic Boilerplate specificity.


reasoning: The paragraph is a cross-reference to risk factors in Item 1A and does not contain any substantive cybersecurity disclosure, making it None/Other. It lacks any specific facts about cybersecurity practices, roles, or incidents, so specificity is Generic Boilerplate.


reasoning: The paragraph directly answers how cybersecurity affects the business by stating a materiality conclusion, fitting Strategy Integration. It contains no specific facts—only a generic negative assertion about materiality—resulting in Level 1 specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business by concluding no material adverse impact, which is a Strategy Integration assessment. It contains no specific facts, domain expertise, or verifiable claims, making it generic boilerplate.


reasoning: The paragraph is a cross-reference to risk factors in Item 1A, providing no substantive cybersecurity disclosure here, and contains no specific facts about the company's cybersecurity posture, making it generic boilerplate.


reasoning: This paragraph is solely a cross-reference to risk factors in Item 1A, providing no substantive cybersecurity disclosure, so it falls under None/Other. It contains no specific facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the Board and Audit Committee's oversight of cybersecurity risks, which directly answers how the board oversees cybersecurity (Board Governance). It contains no specific facts—only generic oversight language applicable to any public company—resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Audit Committee and integration into enterprise risk management, fitting Board Governance. However, it contains no specific facts—only generic governance and risk management language that fails to demonstrate domain expertise or firm-specific details, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the cybersecurity oversight chain from the Global Director of IT to the audit committee and board, fitting Board Governance. It contains no specific facts—only generic roles, cadences, and oversight language—resulting in Generic Boilerplate specificity.


reasoning: This paragraph is a cross-reference to risk factors in Item 1A, providing no substantive cybersecurity disclosure, so it is classified as None/Other. It contains no specific facts about cybersecurity measures or incidents, leading to Generic Boilerplate specificity.


reasoning: The paragraph directly addresses how third-party cyber risks are managed through vendor control reviews, fitting the Third-Party Risk category. It uses generic risk management language without any cybersecurity-specific terminology, firm-unique details, or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the oversight structure with the CFO managing cybersecurity risk and the Audit Committee overseeing it, which aligns with Board Governance. It contains no specific, verifiable, or domain-adapted facts, as all elements are generic governance roles and processes.


fact: Merger with SomaLogic Operating Co, Inc. completed in early 2024

fact: SomaLogic has ongoing ISO 27001 compliance certification

reasoning: The paragraph primarily describes cybersecurity integration activities post-merger, such as reviewing policies and tools, which aligns with Risk Management Process. Specific verifiable facts include the merger date and ISO 27001 certification, elevating specificity to Level 4.


reasoning: The paragraph states conclusions about the material impact of cybersecurity on business outcomes, directly answering how cybersecurity affects the business, which aligns with Strategy Integration. It contains no specific facts—only generic statements about risk materiality and a cross-reference—resulting in Generic Boilerplate specificity.


fact: over thirty years of experience

fact: threat intelligence

reasoning: The paragraph primarily answers how management is organized for cybersecurity by describing the Head of IT's responsibilities and experience, making it Management Role. It contains a verifiable fact ('over thirty years of experience') and domain-specific terminology ('threat intelligence'), setting specificity at Level 4.


fact: Director of Information Security role

fact: Over 30 years of experience in IT and information security

fact: CISSP certification

fact: OD Technology Department

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity, focusing on the Director of Information Security's qualifications and team structure, thus classified as Management Role. Specificity is Quantified-Verifiable due to verifiable facts such as over 30 years of experience and CISSP certification.


reasoning: This paragraph is a cross-reference to Item 1A for cybersecurity risk factors, containing no substantive disclosure, so it is classified as None/Other. With no specific facts presented, it is Generic Boilerplate.


reasoning: The paragraph describes the incident response plan as part of the cybersecurity program's activities, answering what the program does, so it is Risk Management Process. The description is generic with no domain-adapted terms, firm-specific details, or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph directly answers how cybersecurity affects the business by concluding that no risks have materially affected or are likely to materially affect it, which is a materiality assessment under Strategy Integration. It contains no specific facts, domain terms, or verifiable claims, making it generic boilerplate.


fact: Certified Information Systems Auditor (CISA)

fact: Certified Information Systems Security Professional (CISSP)

fact: Fellow of Information Privacy

fact: Certified Information Privacy Professional (CIPP)

reasoning: The paragraph focuses on management organization and leadership qualifications in cybersecurity, answering 'How is management organized?' for the Management Role category. Specificity is Level 4 due to verifiable certifications like CISSP and CISA that can be externally confirmed.


fact: Vice President and Chief Information Officer (CIO)

fact: Chief Information Security Officer (CISO)

fact: CISO has 27 years of cybersecurity experience

fact: 17 of which are in the oil and gas industry

fact: One of less than 400 CISOs globally that has graduated from the FBI's CISO Academy in Quantico, Virginia

fact: Cybersecurity Executive Committee

reasoning: This paragraph primarily answers how management is organized for cybersecurity, focusing on roles like CIO and CISO, their reporting structure, and qualifications, which aligns with Management Role. It contains verifiable facts such as specific years of experience and a unique FBI Academy graduation claim, elevating specificity to Quantified-Verifiable.


reasoning: This paragraph primarily answers how the board oversees cybersecurity by describing the delegation of oversight to the Audit Committee and assignment of responsibility to the General Counsel, fitting the Board Governance category. It contains no specific or verifiable facts, using only generic roles and processes, so specificity is Generic Boilerplate.


reasoning: The paragraph describes third-party service providers assessing and supporting the company's cybersecurity program, which primarily answers what the program does (Risk Management Process). It contains no specific, verifiable, or firm-unique facts, using generic language about third-party involvement without elevating specificity above Level 1.


reasoning: The paragraph describes the Audit Committee's oversight role in reviewing cybersecurity/data privacy risks and internal controls, which directly answers how the board oversees cybersecurity (Board Governance). The language is generic corporate governance without any specific cybersecurity domain terms, firm-unique details, or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph answers how management is organized for cybersecurity incident response by listing roles that may be involved, fitting Management Role. It contains no specific facts beyond generic role names, making it generic boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a materiality conclusion (no material impact), which aligns with Strategy Integration. It contains no specific facts—only generic statements about threats and incidents, plus a cross-reference—resulting in Generic Boilerplate specificity.


fact: Senior Vice President and Chief Information Officer (CIO)

fact: over 25 years of IT Risk Management experience

fact: team with more than 30 years of collective information and product security experience

reasoning: The paragraph primarily answers how management is organized for cybersecurity, detailing the CIO's role, qualifications, and team composition, fitting Management Role. Specificity is Quantified-Verifiable due to verifiable claims like the CIO's over 25 years of experience.


reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by describing their responsibilities, expertise sources, and oversight activities, fitting the Management Role category. It contains no specific facts—only generic statements about responsibilities and standard cybersecurity activities without verifiable, firm-specific, or domain-adapted details, resulting in Generic Boilerplate specificity.


fact: Chief Technology and Digital Officer

fact: Senior Vice President, Technology

fact: over 10 years of experience

fact: over 25 years of experience

fact: Cybersecurity Committee

fact: Committee composition: representatives from accounting, finance, legal, internal audit, and information technology

fact: cyber risk assessments

fact: key risk indicators

fact: cybersecurity training procedures

reasoning: The paragraph primarily answers how management is organized for cybersecurity, with specific roles and a committee structure, fitting Management Role. It contains verifiable lower-bound experience claims (over 10 and 25 years), elevating specificity to Level 4.


reasoning: The paragraph primarily addresses how the board oversees cybersecurity by stating support from management and the Board, including the Audit Committee, which aligns with Board Governance. It contains no specific facts—only generic commitments and standard governance references—resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes a Chief Risk Officer providing oversight in general enterprise risk management without any reference to cybersecurity, so it does not answer a cybersecurity-specific question and is classified as None/Other. As a None/Other paragraph, it automatically receives Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a materiality assessment (no material impact to date and not reasonably likely in the future), which aligns with Strategy Integration. It contains no specific facts—only generic language and unverifiable self-assertions—resulting in Generic Boilerplate specificity.


fact: HITRUST framework

fact: SOC2 framework

fact: penetration testing

fact: threat modeling

fact: network firewalls

fact: access controls

fact: vulnerability scanners

fact: intrusion prevention and detection systems

fact: identity and access management systems

fact: NIST framework

reasoning: The paragraph primarily answers what the cybersecurity program does by detailing internal security measures and processes, making it Risk Management Process. It demonstrates cybersecurity expertise through domain-specific terms like HITRUST, SOC2, NIST, and various security tools, but lacks firm-specific or verifiable facts, resulting in Level 2 specificity.


fact: threat intelligence services

reasoning: The paragraph focuses on managing cybersecurity risks from third parties via a Third-Party Risk Management program, directly answering the 'How are third-party cyber risks managed?' question. Specificity is Domain-Adapted because 'threat intelligence services' is a cybersecurity-specific term that demonstrates domain expertise, while other content is generic.


fact: Chief Information Security Officer (CISO)

reasoning: The paragraph primarily describes cybersecurity risk management processes and activities, such as assessments and enhancements, fitting the Risk Management Process category. The mention of the CISO role is a firm-specific fact that elevates specificity to Firm-Specific.


fact: over 25 years of work experience in various roles in information technology and cybersecurity

reasoning: The paragraph primarily describes management roles and qualifications for cybersecurity oversight, fitting 'Management Role', and it contains a verifiable claim of over 25 years of experience, which elevates specificity to Level 4.


reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing Board-level updates, presentations, and escalation processes, fitting Board Governance. Specificity is Generic Boilerplate because it contains no firm-specific, domain-adapted, or verifiable facts; all language is generic governance oversight without concrete details.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a conclusion that no threats are anticipated to have a material effect, which is a materiality assessment under Strategy Integration. It contains no specific facts, relying on generic risk management language without verifiable or firm-specific details, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a conclusion on material effects (no breaches in the past and no risks likely to materially affect operations or finances), fitting Strategy Integration. It contains no specific facts—only generic assertions and negative claims that are not verifiable—resulting in Generic Boilerplate specificity.


reasoning: The paragraph directly describes the Board's oversight role in cybersecurity, answering 'How does the board oversee cybersecurity?' for Board Governance. It contains no specific facts—only generic governance language without domain expertise, firm-specific details, or verifiable claims, resulting in Generic Boilerplate specificity.


fact: February 13, 2023, security breach disclosure date

reasoning: The paragraph answers 'What happened in a cybersecurity incident?' by describing a specific breach on February 13, 2023, involving a third-party vendor. The date is a verifiable fact, setting specificity at Level 4.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating conclusions about material impact and costs, fitting Strategy Integration. It contains no specific facts, relying on generic statements and negative assertions, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through descriptions of Board and Audit Committee oversight roles, fitting Board Governance. It contains only generic governance language with no specific, verifiable, or firm-unique facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the Audit Committee's oversight of cybersecurity risks and management's annual and quarterly risk assessments, which directly answers how the board oversees cybersecurity (Board Governance). It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate with no elevated specificity.


reasoning: This paragraph is a cross-reference directing readers to risk factors in Item 1A for cybersecurity threats, containing no substantive disclosure about governance, management, processes, or incidents, so it is classified as None/Other. It lacks any specific facts, domain terms, or verifiable claims, resulting in Generic Boilerplate specificity.


fact: Interim Chief Financial Officer

fact: Chief Legal Officer

fact: February 2024

reasoning: The paragraph primarily answers how the board oversees cybersecurity through delegation to the Audit Committee and reporting lines, fitting Board Governance. It contains verifiable facts including specific dates (February 2024) and named executive roles (Interim CFO, Chief Legal Officer), elevating specificity to Level 4.


fact: Director of Information Security

fact: 27 years of technology leadership experience

fact: Doctor of Business Administration

fact: 27 years of experience in infrastructure and security operations

fact: degree in Information Technology Management

fact: Information Security Committee

fact: Executive Information Security Oversight Committee

fact: Specific members: Vice President and Chief Information Officer, Senior Vice President Chief Financial Officer, Senior Vice President Chief Legal Officer and Secretary, Senior Vice President Chief Human Resources Officer

reasoning: The paragraph primarily answers how management is organized for cybersecurity, detailing roles, qualifications, and committee structures, making it Management Role. Specificity is Level 4 due to verifiable facts like exact years of experience and educational degrees.


reasoning: This paragraph primarily answers how cybersecurity affects the business by stating a materiality conclusion, which aligns with Strategy Integration. It contains no specific facts, domain expertise, firm-specific details, or verifiable claims, making it Generic Boilerplate.


reasoning: This paragraph defines terms for the disclosure and does not address any substantive cybersecurity topic, classifying it as None/Other. By rule, None/Other paragraphs are assigned Generic Boilerplate specificity.