content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: The paragraph is a cross-reference to another section of the filing and does not contain any substantive cybersecurity disclosure. It merely directs the reader to the Cybersecurity Risk Management section in the MD&A without providing any information about governance, management, processes, incidents, or strategy.

provider: qwen

stage: benchmark


reasoning: The paragraph is a cross-reference to Item 1A for cybersecurity risk disclosures and contains no substantive description of governance, management, risk processes, incidents, or strategy. It does not answer any of the six primary content questions and serves only as a navigational pointer.


content_category: Strategy Integration

reasoning: The paragraph primarily addresses whether cybersecurity risks have affected or are expected to affect the company's business strategy, operations, or financial condition, which aligns with the 'Strategy Integration' category. It contains a backward-looking materiality assessment stating no material impact has occurred, which qualifies as Strategy Integration under Rule 5.


reasoning: The paragraph is a fragment that primarily references other sections (Item 1A, 1B, 1C) and describes general review of a plan without specifying what the plan entails or providing any cybersecurity-specific content. It does not answer any of the six substantive questions and appears to be a cross-reference or outline placeholder.


content_category: Risk Management Process

fact: phishing tests

reasoning: The paragraph primarily describes the activities of Lumen's information security team—developing tools and processes for incident identification, containment, and remediation, conducting employee training, phishing tests, and awareness initiatives—which directly answers 'What does the cybersecurity program do?' This aligns with Risk Management Process. Specificity is driven by the mention of 'phishing tests,' a domain-specific cybersecurity practice that demonstrates expertise beyond generic risk management language.


reasoning: The paragraph describes the general importance of technology systems and data in the company's operations but does not address any specific cybersecurity governance, management, risk process, third-party risk oversight, incident, or financial impact. It is a contextual statement about business operations, not a disclosure about cybersecurity practices or structure. Specificity is Generic Boilerplate because the content consists of generic observations without domain-specific terms, firm-specific details, or verifiable facts.


reasoning: The paragraph primarily discusses the general nature of ADP's data and financial handling and the elevated risk it faces due to the sensitivity and volume of information, but it does not describe any specific governance, management, risk process, third-party oversight, incident, or financial impact. It serves as contextual risk framing without disclosing actual practices or events, falling outside all substantive categories.


reasoning: The paragraph primarily states the Trust's passive structure and lack of operations, which explains why its cybersecurity posture is minimal; it does not describe any actual governance, management, risk processes, or incidents. The partial sentence about threats appears incomplete and contains no substantive disclosure about cybersecurity practices. Thus, it falls under None/Other as it lacks meaningful cybersecurity content.


reasoning: The paragraph is a cross-reference to another section (Item 1A) and does not provide any substantive cybersecurity disclosure itself. It neither describes governance, management, processes, incidents, nor strategy integration, but merely directs readers elsewhere. For specificity, it contains no domain-specific terms, firm-specific facts, or verifiable claims — only a generic reference.


reasoning: The paragraph directly addresses whether cybersecurity incidents have or are reasonably likely to materially impact the company's operations or financial condition, which aligns with the Strategy Integration category under Rule 5 (materiality assessment). The specificity is Generic Boilerplate because the statement is a negative self-assertion about the absence of material incidents, which is not externally verifiable, and contains no domain-specific terms, firm-specific details, or quantified facts.


content_category: Management Role

fact: CISO

fact: Chief Risk Officer

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by identifying specific senior leaders (CISO, Chief Risk Officer, Chief Information and Technology Officer) responsible for assessing and managing cybersecurity risks, which falls under management structure and responsibilities. The specificity is Level 3 because it names firm-specific executive roles with clear cybersecurity accountability, which distinguishes US Bancorp's organizational approach from other companies.


reasoning: The paragraph is a cross-reference to another section (Item 1A) and does not provide any substantive cybersecurity disclosure itself. It does not answer any of the six primary questions about governance, management, processes, third parties, incidents, or strategy. For specificity, it contains no domain terms, firm-specific facts, or verifiable claims—only a generic pointer to risk factors.


content_category: Board Governance

fact: Management reports to the Board of Directors through the Audit Committee

fact: Regular reports on specific risks, mitigation efforts, and cybersecurity maturity

reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing the Board's and Audit Committee's roles in monitoring cybersecurity risk and the flow of information from management to the board, which aligns with Board Governance. Specificity is driven by the mention of a firm-specific leadership role (Vice President, Information Systems and Technology) and the structured reporting mechanism to the Audit Committee.


fact: has not been materially affected by a cybersecurity breach

reasoning: The paragraph primarily addresses whether cybersecurity risks have or could materially affect the company's business strategy, results of operations, or financial condition, which aligns with Strategy Integration. It includes a backward-looking assertion of no material impact and references forward-looking risks, both of which constitute materiality assessments under Rule 5. Specificity is elevated to Level 4 due to the verifiable claim of no material breach to date, which is a firm-specific negative assertion tied to a factual state that could be corroborated through audit or incident logs.


fact: Two members of the audit committee have obtained certifications in cybersecurity oversight

reasoning: The paragraph primarily answers how the board oversees cybersecurity, detailing the roles of the audit committee and full board, reporting lines from officers, and frequency of updates—core elements of governance oversight. Specificity is driven by the verifiable fact that two audit committee members hold cybersecurity oversight certifications, which is externally confirmable.


reasoning: The paragraph primarily serves as a forward-looking disclaimer and cross-reference to another section (Item 1A), rather than addressing any of the six substantive questions about governance, management, processes, third parties, incidents, or strategy. It does not describe any specific cybersecurity measure, role, or assessment, and instead emphasizes the inherent limitations of any cybersecurity program. The reference to 'Item 1A' is a navigational cue, not a substantive disclosure.


content_category: Third-Party Risk

fact: use commercially available services for real-time security scoring of supplier technology services

fact: perform continuous threat intelligence monitoring to identify potential cybersecurity incidents involving third parties

reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on supplier risk assessments, real-time monitoring of cybersecurity posture, threat intelligence, and contractual provisions—making Third-Party Risk the clear category. Specificity is Level 4 due to verifiable claims about using commercially available services for real-time security scoring and continuous threat intelligence monitoring, which imply specific, observable practices.


fact: Chief Information Officer (CIO) is a member of the Company's Executive Committee

fact: Chief Information Security Officer (CISO) is responsible for assessing and managing cybersecurity risks

reasoning: The paragraph primarily describes the roles and responsibilities of specific management executives (CIO and CISO) in assessing and managing cybersecurity risks, including their positions on the Executive Committee, which speaks to organizational structure and leadership accountability—core aspects of Management Role. Specificity is driven by the mention of two firm-specific leadership roles (CIO and CISO) at the executive level, which are distinguishing organizational features of JNJ.


reasoning: The paragraph directly addresses whether cybersecurity incidents have or are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which aligns with the Strategy Integration category under Rule 5. The cross-reference to Item 1A does not change the classification, as the primary content is a materiality assessment. Specificity is Generic Boilerplate because the statement is a negative self-assertion and forward-looking disclaimer without verifiable facts or domain-specific details.


reasoning: The paragraph primarily addresses whether cybersecurity risks have or could affect the company's business and financial outcomes, stating that prior incidents 'have not materially affected our business strategy, results of operations or financial condition'—a direct backward-looking materiality assessment, which falls under Strategy Integration per Rule 5. The forward-looking speculation ('we could be negatively impacted') alone would not qualify, but the explicit materiality conclusion does. Specificity is Generic Boilerplate because the only potentially elevating content is the cross-reference to Item 1A and the non-verifiable negative assertion about past incidents, neither of which provides domain-specific practices, firm-specific details, or verifiable facts.


fact: risks originating from the increased use of AI

fact: risks associated with remote work by third parties and employees

reasoning: The paragraph primarily addresses whether cybersecurity risks have materially affected the company's business or financial condition, stating they have not had a material adverse effect—this constitutes a materiality assessment under Rule 5. The specificity is driven by the mention of AI-related risks and remote work, which are domain-specific cybersecurity concerns, elevating it to Level 2.


fact: December 31, 2023

reasoning: The paragraph primarily addresses whether cybersecurity incidents have materially affected the company's business, stating a backward-looking conclusion of no material impact, which qualifies as a materiality assessment under Rule 5. This frames the content as Strategy Integration. Specificity is elevated to Level 4 by the verifiable date 'December 31, 2023', which anchors the company's claim about incident awareness and can be independently confirmed in context.


fact: We have experienced the same in our own business

reasoning: The paragraph primarily addresses whether cybersecurity risks have materially affected the business and discusses potential future financial and operational impacts, which aligns with Strategy Integration. It contains a backward-looking materiality assessment (no material incident to date) and forward-looking cost scenarios, satisfying Rule 5. Specificity is elevated to Level 4 due to the verifiable claim of experiencing increased threats in their own business, which is a firm-specific, externally confirmable operational assertion.


content_category: Incident Disclosure

reasoning: The paragraph primarily describes a past material cybersecurity incident in 2017 involving a criminal attack and theft of consumer data, which directly answers 'What happened in a cybersecurity incident?' This qualifies as Incident Disclosure. The specificity is Generic Boilerplate because the only factual claim (the 2017 incident) is widely known public information and not described with any new, verifiable detail (e.g., scope, timeline, remediation), and the rest consists of forward-looking risk statements that are standard across filings.


fact: As of December 31, 2024, the Bancorp is not aware of any cybersecurity incidents that have materially affected or are reasonably likely to materially affect Fifth Third

reasoning: The paragraph primarily addresses whether cybersecurity risks have or are likely to affect the company’s business, strategy, or financial condition, culminating in a materiality assessment that no such material impacts have occurred or are reasonably likely. This aligns with Strategy Integration under Rule 5. Specificity is driven by the inclusion of a verifiable date anchor and a forward-looking materiality assertion tied to a specific reporting date, which constitutes a firm-specific and externally contextualized claim.


reasoning: The paragraph expresses a general commitment to cybersecurity without describing governance, management roles, risk processes, third-party oversight, incidents, or financial integration. It contains no specific facts about practices, roles, or verifiable claims, amounting to generic boilerplate language about intent. Specificity is Level 1 due to absence of domain-adapted terms, firm-specific details, or verifiable facts.


reasoning: The paragraph primarily contains forward-looking disclaimers and generic risk acknowledgments without describing any specific governance, management, process, third-party risk, incident, or strategic integration. It references a lack of material incidents and points to Item 1A for further details, making it a cross-referential boilerplate statement rather than a substantive disclosure. Specificity is Generic Boilerplate because it contains no verifiable facts, firm-specific details, or domain-adapted terminology beyond common risk language.


fact: use of third-party providers for regular mandatory trainings

reasoning: The paragraph primarily describes the components and activities of the company's cybersecurity program, answering 'What does the cybersecurity program do?'—such as risk assessments, incident response planning, training, and third-party risk management—making it Risk Management Process. The mention of a dedicated team and external providers supports process execution but does not shift focus to management roles or third-party risk as the central theme. Specificity is elevated to Level 4 due to the verifiable claim of using third-party providers for 'regular mandatory trainings,' which implies a structured, ongoing program that could be confirmed through internal records or vendor contracts.


fact: Director of Information Technology prepares a cybersecurity dashboard with key metrics including threat detection rates and response times

fact: Annual cybersecurity briefing provided to the Audit Committee by the Director of Information Technology

fact: External penetration tests and process audits are conducted at regular intervals

fact: External penetration tests and process audits are reported directly to the Audit Committee by a third-party firm

reasoning: The paragraph primarily answers how the board oversees cybersecurity, focusing on the Audit Committee's role, the flow of information to it (dashboard, annual briefing, direct reporting from third parties), and oversight mechanisms—hallmarks of Board Governance. Specificity is driven by the inclusion of verifiable facts such as named roles, specific metrics, and external firm reporting.


fact: engages independent third-party technology experts to test the Company's information technology systems, including cybersecurity

reasoning: The paragraph primarily answers how the board oversees cybersecurity risks, describing the Board's role in enterprise risk management, receipt of risk assessments, escalation processes for incidents, and engagement of third-party experts—all aspects of board-level oversight. Specificity is driven by the mention of 'independent third-party technology experts to test the Company's information technology systems,' which demonstrates domain-specific cybersecurity practices like external penetration testing, elevating it to Level 2.


fact: conduct risk and compliance assessments of third-party service providers that request access to our information assets

reasoning: The paragraph primarily answers how third-party cyber risks are managed, specifically by conducting risk and compliance assessments of service providers with access to company information assets, which makes Third-Party Risk the correct category. The specificity is Level 2 because the mention of 'risk and compliance assessments' in the context of third-party access demonstrates domain-specific cybersecurity knowledge, such as understanding access controls and compliance validation, which goes beyond generic risk management language.


fact: incident response plan

fact: forensic investigations

fact: incident response management

fact: review and update cybersecurity incident response plan at least annually

reasoning: The paragraph primarily describes the company's incident response process—containment, remediation, recovery, use of third-party providers, and plan maintenance—answering 'What does the cybersecurity program do?' This aligns with Risk Management Process. The mention of notifying the Board and Audit Committee is secondary to the process description. Specificity is Level 2 due to domain-specific practices like forensic investigations, incident response management, and annual review of the incident response plan, which reflect cybersecurity expertise beyond generic risk management language.


fact: Vice-President of Information Technology (VPIT)

fact: Director - Information Security (DIS)

reasoning: The paragraph primarily describes how the Board is informed about cybersecurity through presentations by internal and external experts, which directly addresses board-level oversight and education—core aspects of Board Governance. The mention of the Audit Committee reporting to the Board further reinforces the governance structure. Specificity is driven by the inclusion of firm-specific leadership roles (VPIT and DIS) with security responsibilities, which are identifiable organizational facts that distinguish this company’s structure.


fact: commencement of a vendor third-party risk management program

reasoning: The paragraph primarily answers how third-party cyber risks are managed, specifically by initiating a vendor third-party risk management program to monitor and manage risks from service providers, which aligns with the Third-Party Risk category. The specificity is Level 2 because the mention of a 'vendor third-party risk management program' demonstrates domain-adapted knowledge of cybersecurity risk practices, even though it lacks firm-specific or verifiable details.


fact: Vendor Management department

fact: policies and procedures to follow when utilizing external third-parties

fact: Third-party vendors are thoroughly vetted, approved and inventoried before partnership begins

fact: Any third parties used in any cybersecurity processes are vetted through our vendor management process

reasoning: The paragraph primarily answers how third-party cyber risks are managed, describing a formal vendor management process that vets, approves, and inventories third parties—including those involved in cybersecurity—before engagement, which aligns with Third-Party Risk. The final sentence references materiality but only states a negative conclusion without financial or strategic integration details, so Strategy Integration is not the primary focus.


fact: isolated computer workstations

fact: passwords, passphrases

reasoning: The paragraph primarily describes the Trust's cybersecurity measures, such as passwords, passphrases, two-factor authentication, and isolated workstations, which answer the question of what the cybersecurity program does. This aligns with Risk Management Process. The specificity is Level 2 because it includes domain-specific terminology like 'two-factor or independent authorizations' and 'isolated computer workstations,' which reflect cybersecurity expertise beyond generic risk language.


fact: Certified Information Systems Security Professional (CISSP)

fact: Global Industrial Cyber Security Professional (GICSP)

fact: Electricity Information Sharing and Analysis Center

fact: Cybersecurity and Infrastructure Security Agency

fact: network monitoring

fact: vulnerability scanning

reasoning: The paragraph primarily describes what the cybersecurity program does—using threat intelligence, tools, and practices like network monitoring and vulnerability scanning to identify and respond to risks—which aligns with Risk Management Process. The mention of certified professionals adds specificity but does not shift focus to Management Role, as the person-specific details are subordinate to the program description.


fact: 24/7 security operations center

fact: security awareness program for employees at least annually

reasoning: The paragraph primarily describes the cybersecurity program's activities—such as the 24/7 security operations center, insider threat program, training exercises, and security awareness training—answering 'What does the cybersecurity program do?' This aligns with Risk Management Process. The specificity is driven by firm-specific claims like '24/7 security operations center' and 'robust insider threat protection program,' which distinguish the company's posture and elevate specificity to Level 3.


fact: Head of Cyber Security

fact: quarterly reports to Audit Committee

reasoning: The paragraph primarily describes the Board's delegation of cybersecurity oversight to the Audit Committee, the reporting cadence from the Head of Cyber Security to the Committee, and the flow of information from the Committee to the full Board, which directly answers 'How does the board oversee cybersecurity?' This governance chain and oversight structure is central to Board Governance. Specificity is driven by the firm-specific role 'Head of Cyber Security' and the specific function of quarterly reporting to the Audit Committee, both of which are verifiable organizational facts.


reasoning: The paragraph primarily addresses whether cybersecurity risks have or are reasonably likely to materially affect the company's business, strategy, or financial condition, which aligns with the Strategy Integration category under Rule 5. It includes a forward-looking materiality assessment stating no known material impact, which qualifies as Strategy Integration. The specificity is Generic Boilerplate because the claims about updating security plans and making investments are vague and lack verifiable details, specific practices, or firm-specific attributes.


fact: Review information security examination reports from regulatory agencies

fact: Monitor emerging industry information security risk issues

fact: Discuss applicable frameworks, rules and regulations

reasoning: The paragraph describes ongoing board-level activities—reviewing regulatory examination reports and monitoring emerging regulatory and industry risks—which directly address how the board oversees cybersecurity risk, falling under governance oversight. Specificity is Level 2 because it references domain-specific practices like 'information security examination reports' and 'applicable frameworks, rules and regulations,' which reflect cybersecurity expertise beyond generic risk management language.


reasoning: The paragraph describes the general context that Equifax handles personal data and faces cybersecurity threats, but does not answer any of the six substantive questions about governance, management, processes, third parties, incidents, or business impact. It is a risk-awareness statement common to all data-handling companies and lacks any specific disclosure about the company's actions or structure. Specificity is Generic Boilerplate because the content consists of generic risk statements without domain-specific terms, firm-specific details, or verifiable facts.


fact: Chief Information Security Officer (CISO)

fact: CISO meets at least quarterly with the Board of Directors, the ELT, and the Senior Leadership Team (SLT)

fact: tabletop exercises at least annually with the Board and SLT

reasoning: The paragraph primarily describes the leadership role and reporting responsibilities of the CISO, including meeting frequency with governance bodies, which centers on management's organizational role in cybersecurity; specificity is driven by the firm-specific title 'Chief Information Security Officer' and the named leadership teams (ELT, SLT), which distinguish the company's structure.


fact: joint meeting annually between Risk Management Committee and Audit Committee

fact: annual executive-level crisis exercise that includes a cybersecurity component

fact: Board members participate in crisis exercise

reasoning: The paragraph primarily describes how the Board of Directors and its committees—specifically the Risk Management Committee and its Cybersecurity and Technology Subcommittee—oversee cybersecurity risk, including their responsibilities, reporting cadence, and engagement with management and external experts. This directly answers the question of board-level oversight structure and processes. Specificity is driven by multiple firm-specific governance structures (e.g., named subcommittee, joint committee meetings, annual crisis exercise with Board involvement), which are unique to the company’s organizational approach.


fact: CISO provides quarterly updates to RCSC

fact: RCSC (Risk Committee of the Board) receives cybersecurity updates

fact: CISO role (firm-specific leadership position)

reasoning: The paragraph primarily describes how the Risk Committee of the Board (RCSC) oversees cybersecurity, including the frequency and scope of updates from the CISO, which directly answers the question of board-level governance. The mention of incident overviews is framed as part of governance reporting, not detailed incident disclosure. Specificity is driven by the firm-specific role of the CISO and the named committee (RCSC), which distinguish JNJ’s governance structure.


reasoning: The paragraph primarily addresses whether cybersecurity incidents have or are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which directly aligns with the Strategy Integration category under Rule 5. The specificity is Generic Boilerplate because the content consists of a negative assertion about material impact and a cross-reference to risk factors, with no domain-specific terms, firm-specific details, or verifiable facts.


fact: maintain cyber risk insurance

reasoning: The paragraph primarily addresses whether cybersecurity incidents have or could materially affect the company's business and financial outcomes, which aligns with Strategy Integration under Rule 5. It includes a backward-looking assessment that no incidents have had a material adverse effect and a forward-looking statement about potential financial impact, both of which qualify as materiality assessments. Specificity is driven by the verifiable claim about maintaining cyber risk insurance, which is a concrete, externally confirmable fact.


fact: Cybersecurity Executive Steering Body

fact: Audit Committee of the Board of Directors

reasoning: The paragraph primarily describes how cybersecurity risks are communicated up the governance chain—from the CISO to the Cybersecurity Executive Steering Body, then to senior management, and ultimately to the Audit Committee of the Board—answering how the board oversees cybersecurity, which aligns with Board Governance. The mention of the CISO and steering body supports governance structure rather than management roles, as the focus is on escalation and oversight. Specificity is elevated to Level 3 due to the firm-specific 'Cybersecurity Executive Steering Body,' a named internal governance committee not standard across companies.


fact: April 2022

fact: exfiltration of certain confidential company and patient information

fact: temporary disruption of a subset of hospital operations

fact: incurred significant costs to remediate

fact: sustained lost revenues from business interruption

fact: enhancements to Security Operations Center

fact: implementation of new tools and processes

fact: enhancements to system backups, training practices, detection tools and capabilities

reasoning: The paragraph primarily answers 'What happened in a cybersecurity incident?' by describing a specific event in April 2022 involving operational disruption, data exfiltration, remediation costs, and business interruption. It also details post-incident actions, but the core focus remains on the nature, scope, and impact of a real incident. Specificity is driven by verifiable facts including the exact month and year of the incident and named remediation measures.


fact: Vendors are risk ranked based on the type of work being performed

fact: Periodic rescreening is performed on critical vendors

fact: Vendors are required to attest to their business continuity programs

fact: Vendors must provide evidence of appropriate insurance and indemnification agreements

fact: The Company bars sourcing from countries included on the Department of Homeland Security's list of Prohibited Nations

reasoning: The paragraph primarily answers how third-party cyber risks are managed, detailing vendor screening, risk ranking, rescreening of critical vendors, attestation requirements, insurance evidence, and sourcing restrictions based on national origin—core elements of third-party risk management. Specificity is elevated to Level 4 due to the verifiable claim about barring sourcing from countries on the Department of Homeland Security's Prohibited Nations list, which is an externally confirmable policy.


fact: March 2021 cybersecurity incident

fact: $2.4 million in incremental one-time costs for consultants, experts, and data recovery efforts, net of insurance recoveries

reasoning: The paragraph primarily describes a specific cybersecurity incident that occurred in March 2021, including its cause (cybersecurity incident), impact on operations (delays in brewery operations, production, and shipments), timeline, and financial cost ($2.4 million in incremental costs), which directly answers 'What happened in a cybersecurity incident?' The mention of financial impact and business disruption supports the incident frame, not a strategic assessment, so it remains Incident Disclosure. The specificity is driven by the verifiable cost amount and specific date of the incident.


fact: Cybersecurity team conducts formal risk assessments of third-party service providers' data security controls and policies

fact: Reassessments conducted based on risk assessment and rating process

fact: Contractual language includes terms on collection, use, sharing, retention of user data and compliance with security terms

reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on risk assessments, reassessments based on risk ratings, and contractual security requirements with service providers—making Third-Party Risk the clear category. Specificity is Level 2 due to the use of domain-specific practices like formal risk assessments of data security controls and risk-based reassessment frequency, which reflect cybersecurity expertise beyond generic risk management language.


fact: annual reviews of third-party SOC1 reports

fact: Enterprise Risk Management Committee ("ERM Committee")

reasoning: The paragraph primarily describes the company's process for identifying, assessing, and managing cybersecurity risks as part of its enterprise risk management system, including oversight by the ERM Committee and review of third-party SOC 1 reports — all of which answer 'what the cybersecurity program does.' This aligns with Risk Management Process. Specificity is elevated to Level 2 due to the mention of 'SOC 1 reports,' a domain-specific control framework that demonstrates cybersecurity expertise beyond generic risk language.


fact: Cybersecurity Committee of the Board of Directors

reasoning: The paragraph primarily answers how the board oversees cybersecurity, specifically noting that the Board of Directors, through its Cybersecurity Committee, actively oversees and reviews the cybersecurity programs and risk management—this is a clear governance structure, falling under Board Governance. The mention of past incidents not having material impact is a negative assertion about financial impact, but the paragraph frames this within a forward-looking risk context and refers to Item 1A for further details, so it does not qualify as Strategy Integration under Rule 5. Specificity is elevated to Level 3 due to the mention of a named board-level committee—the 'Cybersecurity Committee'—which is a firm-specific governance body not present at all public companies.


fact: threat intelligence

fact: external advisors engaged by us

fact: alerts and reports produced by security tools deployed in the IT environment

reasoning: The paragraph primarily describes how the management team monitors cybersecurity risks and incidents through specific mechanisms like briefings, threat intelligence, external advisors, and security tools—answering 'What does the cybersecurity program do?' This aligns with Risk Management Process. The mention of 'external advisors' and 'security tools' demonstrates domain-specific knowledge, elevating specificity to Level 2.


fact: uses a security incident and event manager interface

fact: security incident and event manager interface uses behavioral analytics

fact: provides live metrics and reports of attempted breaches

fact: logs of firewalls, authentication attempts, emails, anti-malware, attempted intrusions and applications

fact: engagement of third-party experts for external and internal penetration testing

fact: engagement of third-party experts for system security assessments

reasoning: The paragraph primarily describes the company's cybersecurity program activities—specifically how it identifies and responds to incidents using tools like SIEM, behavioral analytics, and penetration testing—answering 'What does the cybersecurity program do?' This aligns with Risk Management Process. Specificity is Level 4 due to verifiable claims such as the use of a 'security incident and event manager interface' with specific capabilities and the engagement of third-party experts for penetration testing, which are concrete and externally confirmable actions.


reasoning: The paragraph primarily states a negative assertion about not experiencing a material cybersecurity incident and directs readers to another section for risk details, which constitutes a cross-reference and forward-looking disclaimer. It does not describe governance structure, actual incidents, or any specific cybersecurity program element. The mention of 'Governance' at the end is a section header fragment, not substantive content.


fact: CIO reports on cybersecurity strategy, status of cybersecurity risk control efforts, and third-party cybersecurity risk assessments

fact: Reports are provided to General Counsel, Chief Accounting Officer, Chief Financial Officer, Chief Executive Officer, and Audit Committee

fact: Full Board has access to Audit Committee presentations on cybersecurity

reasoning: The paragraph primarily describes how the Board of Directors oversees cybersecurity risks, including its coordination with management and the Audit Committee, reliance on management to escalate issues, and access to cybersecurity reporting—answering the question of board-level oversight. Specificity is driven by the mention of the CIO (a firm-specific leadership role) reporting to named executive officers and the Audit Committee, which elevates the specificity to Level 3.


fact: documented process to oversee, identify and mitigate cybersecurity risk associated with third-party service providers

fact: cybersecurity risk assessment prior to onboarding

fact: determine potential impact on systems, data and networks if a breach were to occur

fact: risk assessments are documented and reports shared with Information Security Team

fact: others responsible for accepting the risk tolerance and monitoring the risks

reasoning: The paragraph primarily answers how Seaboard manages cybersecurity risks from third-party service providers, focusing on pre-onboarding risk assessments, involvement of designated personnel, and documentation and sharing of findings—making Third-Party Risk the dominant category. Specificity is elevated to Level 2 due to the use of domain-specific practices like 'cybersecurity risk assessment' in the context of third-party onboarding and 'risk tolerance' determination, which reflect cybersecurity-specific processes beyond generic vendor management.


fact: Third-Party Risk Management (TPRM) program

fact: cybersecurity due diligence

fact: review of contractual terms with third parties that access our network or sensitive information

fact: ongoing monitoring of existing relationships based on risk

reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on due diligence, contractual terms, and ongoing monitoring within a named program (TPRM), making Third-Party Risk the clear category. Specificity is Level 2 because it includes domain-adapted terms like 'cybersecurity due diligence,' 'contractual terms' for access to sensitive information, and 'ongoing monitoring' based on risk, which reflect cybersecurity-specific practices beyond generic risk management language.


fact: On June 13, 2023, Brunswick disclosed an IT security incident

fact: Normal global business operations resumed over the course of nine days following the incident

fact: The incident resulted in lost revenue of approximately $80 million to $85 million

fact: Operating earnings impact of $35 million to $40 million

reasoning: The paragraph primarily answers 'What happened in a cybersecurity incident?' by describing a specific IT security incident on June 13, 2023, including its scope, response actions, operational impact, and financial loss estimates. The specificity level is Quantified-Verifiable because it contains externally verifiable claims such as the incident date, duration of nine days, and specific financial impact ranges.


fact: cybersecurity incidents

fact: resiliency of our networks

fact: internal controls and processes

reasoning: The paragraph primarily addresses whether past cybersecurity incidents have had a material impact on the company's business and financial outcomes, stating they have not, which constitutes a materiality assessment under Rule 5. The forward-looking statement about increasing risks and ongoing investments further supports a strategic and financial framing. Specificity is driven by the verifiable claim about no material incidents affecting financials, which is a firm-specific negative assertion tied to financial impact, but such negative assertions are not externally verifiable per the rules, so specificity remains at Level 2 due to domain-adapted terms like 'cybersecurity incidents', 'resiliency of our networks', and 'internal controls and processes' that reflect cybersecurity-specific concepts beyond generic risk management language.


fact: automated event-detection notifications

fact: security operations team

fact: incident response team

fact: investigates the incident, determines the nature of the event and assesses the severity

fact: assesses sensitivity of any compromised data

reasoning: The paragraph primarily describes the company's incident detection and analysis procedures—how incidents are identified (via automated tools, employee reports) and how they are investigated and assessed for severity and data sensitivity—answering 'What does the cybersecurity program do?' This aligns with Risk Management Process. The mention of a security operations team and incident response team supports process execution but does not shift focus to management roles. Specificity is driven by the inclusion of verifiable cybersecurity practices and team functions.


fact: enhanced due diligence procedures prior to onboarding

fact: security risk assessments at the time of onboarding, contract renewal, and upon detection of an increase in risk profile

fact: use a variety of inputs in such risk assessments, including information supplied by third-parties and information obtained through other channels

fact: require our providers to adhere to appropriate security requirements and controls

fact: investigate security incidents that have impacted our third-party service providers

reasoning: The paragraph primarily answers how third-party cyber risks are managed, detailing the company's due diligence, risk assessment timing (onboarding, renewal, risk increase), and incident investigation practices for vendors—making Third-Party Risk the clear category. Specificity is Level 2 due to domain-specific practices like 'enhanced due diligence,' 'security risk assessments' tied to specific triggers, and use of multiple input channels for assessments, which reflect cybersecurity-specific vendor risk management knowledge beyond generic ERM language.


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

fact: simplification of infrastructure to minimize servers

fact: migration of business-critical systems, including the Company's ERP system, to Tier-1 cloud service providers

fact: enhanced encryption

fact: two-factor authentication (2FA)

fact: real-time threat monitoring

reasoning: The paragraph primarily describes the company's cybersecurity program activities—such as threat monitoring, software updates, infrastructure simplification, cloud migration, endpoint protection, and authentication protocols—which directly answer the question of what the cybersecurity program does. This aligns with Risk Management Process. Specificity is driven by the inclusion of verifiable technical measures like 'two-factor authentication (2FA)', 'real-time threat monitoring', and 'migration... to Tier-1 cloud service providers', which are domain-specific and concrete enough to demonstrate a defined implementation approach.


fact: Audit Committee receives quarterly information security updates

fact: Audit Committee reports to the full Board on cybersecurity at least bi-annually

fact: Chief Financial Officer provides updates to the Audit Committee

fact: Senior Director of Governance & Information Security provides updates to the Audit Committee

reasoning: The paragraph primarily describes the governance structure for cybersecurity oversight, detailing how the Board delegates responsibility to the Audit Committee, the flow of information from management to the Committee, and the Committee's reporting cadence to the full Board—answering 'How does the board oversee cybersecurity?'. This aligns with Board Governance under Rule 1. Specificity is driven by the firm-specific roles (Chief Financial Officer, Senior Director of Governance & Information Security) and the specific reporting frequency (quarterly updates, bi-annual Board reporting), with the latter being a verifiable claim about process cadence.


fact: security operations center staffed with cybersecurity professionals

fact: Chief Information Security Officer (CISO)

fact: Cybersecurity Incident Response Plan

fact: cybersecurity crisis response team consisting of CEO, CFO, CHRO, CIO, and General Counsel

fact: risk-based escalation process to notify General Counsel

fact: General Counsel analyzes obligation to report any incident publicly

fact: Public Disclosure Committee

reasoning: The paragraph primarily describes the company's operational processes for identifying, assessing, escalating, and responding to cybersecurity threats, including the use of a security operations center, incident thresholds, escalation paths, and coordination with internal teams—core elements of a risk management process. Specificity is driven by the mention of a named internal structure (Crisis Response Team) and defined roles, which are firm-specific, and the reference to a formal Cybersecurity Incident Response Plan, which demonstrates domain-adapted knowledge.


reasoning: The paragraph discusses the general importance of cybersecurity governance in aligning with business objectives and complying with regulations but does not describe any specific governance structure, board or management roles, risk processes, or other substantive cybersecurity practices. It is a generic statement about the value of governance without answering any of the six primary questions.


fact: endpoint detection and response

fact: network anomaly detection

fact: multi-factor authentication

fact: defense-in-depth and layered strategy

fact: annual data protection and cybersecurity training

fact: ongoing phishing simulation exercises

fact: threat intelligence services

reasoning: The paragraph primarily describes the company's cybersecurity program activities—such as risk identification, use of specific security tools (EDR, MFA), employee training, and threat intelligence—which directly answers 'What does the cybersecurity program do?' This aligns with Risk Management Process. The specificity is driven by multiple domain-specific terms like 'endpoint detection and response' and 'network anomaly detection' that demonstrate cybersecurity expertise beyond generic risk language.


fact: aligns with the National Institute of Standards and Technology Cyber Security Framework

fact: uses multi-factor authentication

fact: engages third-party security consultants and assessors

fact: conducts vulnerability scanning

fact: conducts penetration testing

fact: performs incident response and disaster recovery exercises

fact: uses encryption for endpoint technology

fact: implements threat management and monitoring on endpoints

fact: maintains backups

fact: conducts employee cyber risk awareness training and testing

fact: performs third-party due diligence, continuous monitoring, cyber risk scoring, and imposes contractual obligations

reasoning: The paragraph primarily describes the company's cybersecurity program, including its framework alignment, specific security measures, and structured focus areas like vulnerability scanning, incident response, encryption, access controls, training, and third-party risk management—answering 'What does the cybersecurity program do?' The specificity is Level 4 due to verifiable claims such as alignment with NIST CSF, use of multi-factor authentication, and engagement of third-party assessors, which are concrete and externally confirmable practices.


reasoning: The paragraph directly addresses whether cybersecurity risks or incidents have materially affected the company's business strategy, results of operations, or financial condition, which aligns with the 'Strategy Integration' category under Rule 5. The specificity is Generic Boilerplate because the statement is a standard negative assertion that lacks any verifiable or firm-specific details.


fact: Enterprise & Technology Security (E&TS) organization has oversight responsibility for security of IBM's internal systems and external offerings

fact: Dedicated Chief Information Security Officer (CISO) leads enterprise-wide information security strategy, policy, standards, architecture, and processes

fact: CISO manages the CSIRT

fact: CISO manages the Product Security Incident Response Team (PSIRT), which focuses on product vulnerabilities

fact: Business Information Security Officers (BISO) coordinate with the Office of the CISO on security issues specific to business segments

reasoning: The paragraph primarily describes the organizational structure and responsibilities of IBM's cybersecurity leadership (E&TS, CISO, PSIRT, BISO), focusing on roles, reporting lines, and team functions, which directly answers 'How is management organized to handle cybersecurity?' The specificity is Level 3 due to firm-specific roles like CISO, PSIRT, and BISO, which distinguish IBM's structure from other companies.


fact: network and perimeter defense

fact: infrastructure security

fact: cloud security

fact: endpoint protection

fact: data protection

fact: identity management

fact: network segmentation

fact: periodic cybersecurity assessments

fact: integration of cybersecurity threat intelligence

reasoning: The paragraph primarily describes the company's cybersecurity program activities—specifically the tools, systems, and safeguards used to secure infrastructure and manage vulnerabilities—answering 'What does the cybersecurity program do?' This aligns with Risk Management Process. The specificity is Level 2 because it includes domain-specific terminology like 'network segmentation,' 'endpoint protection,' and 'cybersecurity threat intelligence,' which demonstrate cybersecurity expertise beyond generic risk management language.


reasoning: The paragraph primarily addresses how cybersecurity risk is integrated into the company's broader enterprise risk management programs, answering the question of what the cybersecurity program does in relation to overall risk management. This aligns with the 'Risk Management Process' category. The specificity is Generic Boilerplate because the content consists of a cross-reference and a generic statement about integration with ERM, containing no domain-specific terms, firm-specific details, or verifiable facts.


fact: mandates annual SOC 1 audit for key third-party service providers

fact: reviews all SOC 1 audit reports to ensure adequate IT security and business process controls

reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on audit requirements (SOC 1), review processes, and oversight mechanisms for third-party service providers, which aligns with Third-Party Risk. The specificity is driven by the mention of 'annual SOC 1 audit' and 'review all SOC 1 audit reports,' which are domain-specific cybersecurity practices that demonstrate expertise beyond generic risk management language.


fact: Chief Information Security Officer (CISO)

fact: CISO meets at least quarterly with the Board of Directors, the EXCO, and the Senior Leadership Team (SLT)

fact: tabletop exercises at least annually with the Board, the EXCO and the SLT

reasoning: The paragraph primarily describes the organizational role and responsibilities of the CISO, including reporting lines to the Board, EXCO, and SLT, which answers 'How is management organized to handle cybersecurity?' This is a Management Role (MR) despite mentioning oversight, as the focus is on the CISO's function and cadence of engagement. Specificity is Level 3 due to the mention of the CISO role and named internal groups (EXCO, SLT), which are firm-specific identifiers.


fact: cybersecurity risks have not materially affected our business or our results of operations

reasoning: The paragraph primarily addresses whether cybersecurity risks have had or could have a material impact on the business, stating they have not yet materially affected operations but acknowledging future risks could — which constitutes a materiality assessment under Rule 5. This aligns with Strategy Integration. The cross-reference to Item 1A does not change the category, as the core content is the backward- and forward-looking materiality conclusion.


reasoning: The paragraph primarily addresses whether cybersecurity incidents have affected the company's business outcomes, stating they have not had material impacts—this constitutes a backward-looking materiality assessment, which falls under Strategy Integration per Rule 5. The second sentence contains forward-looking commitments but does not describe a specific program, governance structure, or incident, so it does not shift the primary focus. Specificity is Generic Boilerplate because the claims are negative assertions (absence of incidents) and general commitments without verifiable facts, specific practices, or firm-specific details.


fact: CIO and CISO are leaders of the DTI organization and CDT function

fact: CDT team is overseen by the CISO

fact: Incident Response team includes the CISO and other senior members of the CDT function

reasoning: The paragraph primarily describes the organizational roles and responsibilities within management—specifically the CIO, CISO, and CDT team—in monitoring, responding to, and remediating cybersecurity threats, which directly answers 'How is management organized to handle cybersecurity?'. Specificity is driven by the mention of named leadership roles (CIO, CISO) and a dedicated team (CDT), which are firm-specific organizational elements.


reasoning: The paragraph primarily addresses the material impact of cybersecurity risks on the company’s business strategy, results of operations, and financial condition, both historically and prospectively, which aligns with Strategy Integration. The specificity is Generic Boilerplate because the paragraph contains no verifiable facts, firm-specific details, or domain-adapted terminology beyond standard risk disclosure language.


fact: February 2023 cyberattack

fact: temporary interruption of systems

fact: disclosure of certain confidential information

fact: litigation and governmental inquiries

reasoning: The paragraph primarily answers 'What happened in a cybersecurity incident?' by describing a real event in February 2023 involving a cyberattack, system interruption, data disclosure, litigation, and government inquiries. This constitutes a direct disclosure of an actual incident. Specificity is driven by the verifiable date (February 2023) and the named consequences, which are externally confirmable through legal or regulatory records.


reasoning: The paragraph primarily describes the company's awareness of cybersecurity risks to its operational systems and third-party dependencies, framing it around the potential consequences of failure—this aligns with describing the scope and rationale of its risk management approach. Specificity is Level 1 because the content consists of generic risk disclosures without domain-specific practices, firm-specific details, or verifiable facts.


fact: contractually required to manage their cybersecurity risks

fact: provide notification in the event of a cybersecurity incident

reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on vendor assessments and contractual obligations, which aligns with Third-Party Risk. The specificity is elevated to Level 4 due to the verifiable claim that vendors are contractually required to provide incident notification, a specific and externally confirmable condition.


fact: Oversight of cybersecurity risks delegated to the Audit Committee and the Aerospace Safety Committee

fact: Audit Committee reviews cybersecurity processes for strategic, operational, and compliance risks

fact: CIO and CSO provide presentations to the Audit Committee at bimonthly meetings

fact: Audit Committee has a member with expertise in cyber risk management who meets regularly with management

fact: Chair of the Audit Committee is notified and briefed in the event of a potentially material cybersecurity event

fact: Aerospace Safety Committee oversees cybersecurity risks related to aerospace products and services

fact: Aerospace Safety Committee receives updates from Chief Engineer, Chief Aerospace Safety Officer, and Chief Product Security Engineer

fact: Both committees brief the full Board on cybersecurity matters

fact: CIO provides annual briefings to the Board on IT, data analytics, and cybersecurity

reasoning: The paragraph primarily describes how the Board of Directors and its committees (Audit Committee and Aerospace Safety Committee) oversee cybersecurity risks, including delegation of responsibilities, briefing frequency, committee expertise, and information flow to the full Board—answering 'How does the board oversee cybersecurity?' The specificity is elevated to Level 4 due to verifiable facts such as bimonthly meetings, named roles (CIO, CSO, Chief Engineer, etc.), and specific committee responsibilities that can be cross-checked in governance disclosures.


fact: sustained a cybersecurity attack in May 2022 involving ransomware

fact: did not pay any ransomware

fact: engaging a team of third-party forensic experts

fact: restored network systems and resumed normal operations

reasoning: The paragraph primarily describes a specific cybersecurity incident—its nature (ransomware), timing (May 2022), response actions, and impact—answering 'What happened in a cybersecurity incident?' This qualifies as Incident Disclosure. Specificity is elevated to Level 4 due to verifiable facts including the specific date, engagement of third-party forensic experts, and explicit statement about not paying a ransom, all of which are externally checkable claims.


fact: In the last three fiscal years, we have not experienced any material cybersecurity incidents

reasoning: The paragraph primarily addresses whether cybersecurity risks have or are likely to affect the company’s business strategy, results of operations, or financial condition, which aligns with Strategy Integration under Rule 5. It includes a forward-looking assessment of material impact and a backward-looking negative assertion about past incidents. The specificity is driven by the verifiable claim about no material incidents in the last three fiscal years, which provides a time-bound, falsifiable statement.


fact: Vendor Management Committee

fact: Vendor Management team

fact: Annual due diligence follow-up reviews

reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on vendor due diligence, cybersecurity reviews, and ongoing monitoring—making Third-Party Risk the clear category. Specificity is Level 3 due to the mention of a named internal governance body (Vendor Management Committee) and structured team oversight, which are firm-specific organizational details.


reasoning: The paragraph discusses general cyber risks facing the banking industry, such as phishing, ransomware, and nation-state threats, but does not describe the company's governance, management, risk processes, third-party oversight, incidents, or strategy integration. It is a generic risk acknowledgment without firm-specific or actionable disclosures. Specificity is Generic Boilerplate because the content consists of broad, non-specific observations about industry-wide threats with no verifiable facts, firm-specific details, or domain-adapted terminology that demonstrates cybersecurity expertise.


reasoning: The paragraph primarily addresses whether cybersecurity incidents have or could materially affect the company's business, results, or financial condition, which aligns with Strategy Integration. It includes a forward-looking assertion that certain threats are 'reasonably likely to materially affect' business outcomes, which qualifies as a materiality assessment under Rule 5. Specificity is Generic Boilerplate because the paragraph contains only speculative and cross-referential statements without verifiable facts, firm-specific details, or domain-adapted terminology.


fact: Vendors must execute a data security addendum

fact: Data security addendum includes specific security standards

fact: Cybersecurity insurance is required for vendors

fact: Mandatory incident reporting protocols for vendors

reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on contractual and security requirements imposed on vendors handling company data or providing technology services, which aligns with the 'Third-Party Risk' category. Specificity is elevated to Level 4 due to the verifiable requirement for vendors to execute a data security addendum with defined security standards, cybersecurity insurance, and incident reporting protocols—concrete, externally auditable obligations.


reasoning: The paragraph primarily addresses how cybersecurity risks affect the company's business strategy, investment decisions, and financial planning, including past and future resource allocation and insurance—answering the question of how cybersecurity integrates into the business financially and strategically. Specificity is driven by the verifiable claim about maintaining cybersecurity insurance coverage, which is a quantifiable and externally confirmable fact.


fact: are reasonably likely to materially affect our business strategy, results of operations, or financial condition

reasoning: The paragraph primarily addresses whether cybersecurity risks are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which directly aligns with the Strategy Integration category under Rule 5. The forward-looking materiality assessment triggers SI classification, even though it references other sections and includes speculative language.


fact: defense in depth strategy

fact: data loss prevention technology for sensitive data

fact: advanced transport layer security encryption for applications

fact: annual information security awareness training

fact: training includes social engineering testing

reasoning: The paragraph primarily describes the technical and operational components of S&T's cybersecurity program—such as defense in depth, encryption, data loss prevention, and employee training—answering 'What does the cybersecurity program do?' This aligns with Risk Management Process. The specificity is elevated to Level 4 due to the verifiable claim that employees undergo annual security awareness training, which includes social engineering testing—a specific, externally checkable practice.


reasoning: The paragraph primarily addresses whether cybersecurity incidents have or are reasonably likely to materially affect the company's business, strategy, or financial condition, which aligns with the Strategy Integration category under Rule 5. The cross-reference to Item 1A does not change the classification, as the core content is a materiality assessment. Specificity is Generic Boilerplate because the negative assertion of no material incidents is not externally verifiable, and the cross-reference is non-substantive.


reasoning: The paragraph primarily addresses whether cybersecurity incidents have materially affected the company's operations or financial condition, stating they have not been material to date — a backward-looking materiality assessment, which falls under Strategy Integration per Rule 5. The reference to future risk is generic and does not override the central assertion about past materiality. Specificity is Generic Boilerplate because the only potentially elevating claim — 'not been subject to cyber attacks... that have been material' — is a negative self-assertion, which is not externally verifiable per the rules.


fact: Executive Vice President / Chief Information Security Officer

fact: Chief Information Officer

fact: over 25 years' experience in cybersecurity risk management

fact: over 27 years' experience in technology risk management

fact: professionals in identity and access management, cyber defense operations, security engineering and information technology governance, risk and compliance

reasoning: The paragraph primarily describes the organizational structure and leadership of Comerica's cybersecurity team, including senior roles (CISO, CIO), their reporting lines, team composition by function, and relevant experience—answering 'How is management organized to handle cybersecurity?'. While third-party services are mentioned, they are secondary and do not make vendor risk the central topic. Specificity is driven by the verifiable claims about executives' years of experience and named leadership roles.


reasoning: The paragraph primarily addresses whether cybersecurity risks have or are reasonably likely to materially affect the company’s business strategy, results of operations, or financial condition, which aligns with Strategy Integration under Rule 5. It includes a forward-looking materiality assessment ('are reasonably likely to materially affect') and a backward-looking assertion, both of which qualify as Strategy Integration. Specificity is Generic Boilerplate because the paragraph contains no verifiable, firm-specific, or domain-adapted facts—only speculative statements and cross-references.


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

fact: CISO previously served as CISO of two large retailers

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

fact: Cyber incident response plan in place

fact: Annual cybersecurity and information security training for associates with access to confidential information

fact: Engagement of service providers, consultants, and third parties for augmented cybersecurity capabilities

fact: Cybersecurity risk insurance policy maintained

reasoning: The paragraph primarily describes what the cybersecurity program does—secure data, detect incidents, manage third-party risks, conduct training, maintain a cyber incident response plan, and use external support—making it Risk Management Process. The mention of the CISO and CSBDO supports program oversight but is secondary to the description of program activities. Specificity is driven by verifiable facts including the CISO's 'over thirty years of experience' and named roles (CISO, CSBDO), which are firm-specific and include a quantified tenure that can be checked.


fact: denial of service attacks

fact: malicious software attacks on computer systems

fact: security assessments on higher risk third party service providers

reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on risks from card transaction processors, service providers, and other third parties outside the company's control, including security assessments of high-risk vendors—making Third-Party Risk the dominant category. Specificity is elevated to Level 2 by domain-specific references to denial of service attacks, malicious software attacks, and security assessments of third parties, which demonstrate cybersecurity expertise beyond generic risk language.


fact: February 22, 2024, disclosure date of the cybersecurity incident

fact: cybercrime threat actors involved in the incident

reasoning: The paragraph primarily answers 'What happened in a cybersecurity incident?' by disclosing a specific event (February 22, 2024), its suspected perpetrators (cybercrime threat actors), and current status (ongoing investigation). Although it includes a materiality assessment, the incident frame dominates. Specificity is driven by the verifiable date of disclosure and the named nature of the threat actors.


reasoning: The paragraph primarily describes the company's approach to identifying and addressing material cybersecurity risks through implemented policies, procedures, and systems, which directly answers 'What does the cybersecurity program do?'—a core question of Risk Management Process. Specificity is Generic Boilerplate because the terms used (e.g., 'policies, procedures, and systems') are generic and do not demonstrate domain-specific knowledge, reference firm-specific roles or structures, or include any verifiable facts.


fact: ransomware attack on our information technology systems

reasoning: The paragraph primarily answers 'What happened in a cybersecurity incident?' by describing a specific ransomware attack in 2021, its nature, timing, and impact. This qualifies as Incident Disclosure. The mention of business impact is framed within the context of the incident, not as a standalone materiality assessment, so it does not elevate to Strategy Integration.


fact: The Risk Committee receives regular presentations and reports from the Chief Information Security Officer (CISO)

fact: The Board of Directors receives reports at least annually on the performance of the firm's cybersecurity risk metrics

reasoning: The paragraph primarily describes the Board's delegation of cybersecurity oversight to the Risk Committee, the flow of information from management (via the CISO) to the committee, and the committee's role in reviewing risk appetite and receiving regular reports—answering 'how does the board oversee cybersecurity?' This is a governance-chain structure focused on board-level oversight. Specificity is elevated to Level 4 due to the verifiable claim that the Board receives cybersecurity performance reports 'at least annually,' which sets a minimum frequency that could be confirmed by reviewing Board meeting minutes or disclosures.


fact: strategic risk management committees

reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on pre-engagement and periodic risk assessments of service providers to uphold security standards, which aligns with Third-Party Risk. The mention of strategic risk management committees supports this by indicating governance around identified risks, but the central topic remains vendor oversight. Specificity is elevated to Level 2 due to the use of domain-specific practices like 'pre-engagement and periodic risk assessments' in a cybersecurity context, which demonstrate knowledge beyond generic risk management.


reasoning: The paragraph primarily answers how the board oversees cybersecurity risk, specifically describing the Audit Committee’s formal role in oversight pursuant to its charter, in consultation with the full Board and other committees—this is a governance-chain structure focused on board-level accountability. Specificity is Generic Boilerplate because the content consists of standard oversight language that any public company could use, with no domain-specific practices, firm-specific roles, or verifiable facts.


fact: Audit Committee monitors internal audit's coverage of cybersecurity governance, risks, and related controls

fact: Risk Committee coordinates with the Audit Committee for review of information security matters

reasoning: The paragraph primarily describes how board-level committees (Audit Committee and Risk Committee) oversee cybersecurity governance and risks, which directly answers the question of board oversight structure. The mention of coordination between committees and monitoring of internal audit coverage reflects governance processes, not management roles or program activities. Specificity is driven by the firm-specific committee names and their defined roles in cybersecurity oversight.


fact: CIO and his security management team possess primary responsibility

fact: Board of Directors directly oversees cybersecurity risks

fact: annual review of the Company's cybersecurity risks

fact: Audit Committee receives quarterly cybersecurity updates

reasoning: The paragraph primarily answers how the board oversees cybersecurity, detailing the Board of Directors' annual review of risks and strategic roadmap, and the Audit Committee's quarterly updates—both governance-level oversight activities. Specificity is driven by firm-specific roles (CIO, Audit Committee) and structured oversight cadences tied to management reporting, which are organizationally distinctive.


fact: Enterprise Cybersecurity Management Review Group (Enterprise Cybersecurity MRG)

fact: MRG is comprised of senior leaders with cross-functional experience and responsibilities

fact: MRG meets regularly with our Chief Information Security Officer

fact: MRG is responsible for our response to material cybersecurity incidents

fact: Escalation through the MRG to the Audit Committee and Board for material cybersecurity incidents

reasoning: The paragraph primarily describes a management-level committee (Enterprise Cybersecurity MRG) — its composition, meeting cadence with the CISO, responsibilities for reviewing cybersecurity initiatives and incident response, and escalation path. This answers 'How is management organized to handle cybersecurity?' rather than focusing on board oversight structure, making it Management Role. The specificity is driven by the named, non-generic committee and its defined role in incident escalation, which are firm-specific details.


fact: EVP, Chief Digital and Innovation Officer (CDIO) shares responsibility for assessing and managing cybersecurity risks

fact: Vice President (VP) of Platforms, Infrastructure and Cybersecurity shares responsibility for assessing and managing cybersecurity risks

fact: Both the CDIO and VP of Platforms, Infrastructure, and Cybersecurity have over 20 years of related experience

reasoning: The paragraph primarily describes the leadership structure for cybersecurity within management, identifying specific executives (CDIO and VP of Platforms, Infrastructure and Cybersecurity), their shared responsibility, and their qualifications—focusing on roles, experience, and expertise. This aligns with 'Management Role' as it answers how management is organized and who is responsible. The mention of 'over 20 years of related experience' is a verifiable claim about tenure, elevating specificity to Level 4.


fact: Chief Capability Officer (CCO)

fact: Chief Information Officer (CIO)

fact: Chief Information Security Officer (CISO)

fact: quarterly cybersecurity reports

fact: results of internal and third-party audits and assessments reported to the Audit Committee

reasoning: The paragraph primarily describes how the Audit Committee, a board-level body, oversees cybersecurity through quarterly reports and direct engagement with senior management, which directly answers 'How does the board oversee cybersecurity?' This fits the Board Governance category under Rule 1. Specificity is driven by the mention of named executive roles (CCO, CIO, CISO), which are firm-specific leadership positions, elevating the specificity to Level 3.


fact: detective surveillance controls

fact: utilizing independent third parties to assess information security practices

fact: courses and awareness training on information security for employees

fact: phishing, social engineering and other cybersecurity training

fact: targeted training for specific roles based on responsibilities and risk level

fact: global security and privacy policies

fact: business continuity, incident response and disaster recovery procedures

fact: table top exercises involving senior leaders

reasoning: The paragraph primarily describes what the company's cybersecurity program does—specifically, its risk assessment methodology, technical controls, third-party assessments, employee training, policies, and incident response planning—answering the question of how cybersecurity risks are managed. This aligns with Risk Management Process. The specificity is Level 2 because the paragraph includes domain-specific terminology like 'phishing, social engineering,' 'table top exercises,' and 'layered technical protective capabilities,' which demonstrate cybersecurity expertise beyond generic risk management language.


fact: TPRM program integrated into procurement process

fact: Cybersecurity due diligence reviews based on vendor risk profile

fact: Ongoing monitoring of principal suppliers using an outside-in, hacker perspective through an external service provider

reasoning: The paragraph primarily answers how Unisys manages cyber risks associated with third-party service providers, detailing its TPRM program, due diligence processes, and ongoing monitoring using an external service provider—making Third-Party Risk the dominant category. Specificity is Level 4 due to the verifiable claim about using an 'outside-in, hacker perspective' via an external service provider, which implies a specific and independently confirmable method of vendor monitoring.


fact: CISO provides a cybersecurity dashboard reviewed by the Board at every regularly scheduled Board meeting

fact: cybersecurity dashboard includes key performance indicators for cybersecurity process maturity, operational performance, and enterprise performance toward Transportation Security Administration (TSA) compliance

fact: CIO and/or CISO presents to the Board bi-annually regarding cybersecurity risks and strategies

fact: presentations include Board's annual long-term strategy session

fact: Audit Committee reviews implementation and effectiveness of cybersecurity risk management protocols

fact: Audit Committee reviews effectiveness of cybersecurity as part of accounting and internal control policies

fact: CIO presents to the Audit Committee bi-annually

fact: CIO presents to the Audit Committee periodically in conjunction with internal audits related to cybersecurity

fact: management has protocols for escalating cybersecurity incidents that meet established reporting thresholds

fact: escalated incidents are reported to the Board

fact: Board receives ongoing updates regarding incidents until resolved

reasoning: The paragraph primarily describes how the Board and its Audit Committee oversee cybersecurity policy, strategy, and risk management, including the frequency and nature of reporting from the CISO and CIO, which directly answers 'How does the board oversee cybersecurity?' The mention of management escalation protocols supports the governance chain and is framed within board-level oversight. Specificity is driven by multiple firm-specific roles (CISO, CIO), named committees (Audit Committee), and specific reporting cadences (bi-annually, at every Board meeting), with verifiable claims about dashboard content including TSA compliance — a concrete regulatory standard.


fact: 2023 third-party vendor cybersecurity incident

fact: MOVEit Transfer software used by vendor

fact: zero-day vulnerability in MOVEit Transfer

reasoning: The paragraph primarily describes actual cybersecurity incidents, including unauthorized access to customer information and systems, with specific details about methods (e.g., compromised credentials) and a named third-party incident involving MOVEit Transfer due to a zero-day vulnerability in 2023 — all centered on what occurred. This directly answers 'What happened in a cybersecurity incident?' Despite mentioning materiality, the dominant frame is incident description, not financial impact. Specificity is driven by the verifiable fact of the 2023 MOVEit incident at a vendor, which is a named event with a specific vulnerability type and software.


reasoning: The paragraph directly addresses whether cybersecurity risks have or are likely to materially affect the company's business strategy, financial condition, or results of operations, which aligns with the definition of Strategy Integration. The specificity is Generic Boilerplate because the content consists of a standard negative assertion about material impact and a cross-reference to risk factors, with no domain-specific terms, firm-specific details, or verifiable facts.


fact: contractually requires suppliers, vendors and other third-parties with access to its information technology systems, sensitive business data or personal information to implement and maintain appropriate security controls

fact: contractually restricts their ability to use the Company's data, including personal information, for purposes other than to provide services to the Company, except as required by law

reasoning: The paragraph primarily answers how third-party cyber risks are managed by describing contractual requirements imposed on vendors with access to systems or data, which is the central topic of Third-Party Risk. The specificity is Level 2 because it includes domain-specific security concepts like 'appropriate security controls' and 'contractually restricts use of data,' demonstrating cybersecurity expertise beyond generic risk management language.


fact: reviewing the cybersecurity practices of such provider

fact: contractually imposed obligations on the provider

reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on evaluation during vendor selection, expectations for cybersecurity programs, and contractual and review processes based on service sensitivity—making Third-Party Risk the clear category. Specificity is Level 2 because it includes domain-adapted terms like 'cybersecurity programs based on industry standards' and 'reviewing the cybersecurity practices,' which reflect cybersecurity-specific knowledge beyond generic risk management language.


fact: Chief Information Security Officer (CISO)

fact: 30 years of information technology experience

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

reasoning: The paragraph primarily describes the role, responsibilities, qualifications, and experience of the CISO, which directly answers the question of how management is organized to handle cybersecurity. This aligns with Management Role. The specificity is driven by the verifiable claims about the CISO's 30 years of IT experience and 17 years focused on information security, which are externally checkable facts.


fact: safeguards sensitive customer data, financial transactions, and our information systems

fact: broader enterprise risk management strategy

reasoning: The paragraph primarily describes what the company does to manage cybersecurity risks—specifically, the establishment of a 'robust cybersecurity risk management program' that safeguards data, transactions, and systems—answering the question of what the cybersecurity program does, which aligns with Risk Management Process. The mention of regulatory compliance and data protection supports this focus on program activities rather than governance structure or financial impact. Specificity is elevated to Level 2 due to the use of domain-specific concepts like 'cybersecurity risk management program' and 'safeguards sensitive customer data, financial transactions, and information systems,' which reflect cybersecurity expertise beyond generic risk language.


fact: CIO reports directly to CEO

fact: Director of Cybersecurity role

fact: CIO has over 20 years of cybersecurity oversight experience

fact: Director of Cybersecurity has over 20 years of cybersecurity oversight experience

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

fact: Director of Cybersecurity has experience developing and implementing cybersecurity programs for multiple manufacturing firms

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity, focusing on leadership roles (CIO, Director of Cybersecurity), their reporting lines, qualifications, and relevant experience—core aspects of Management Role. Specificity is driven by verifiable claims about tenure (over 20 years of experience) and named prior roles, which are externally checkable.


fact: Privacy and Data Governance Committee

fact: composed of a cross-functional group across approximately 20 departments

reasoning: The paragraph primarily describes the organizational structure and leadership of internal cybersecurity and privacy committees, focusing on their composition, chairpersons, and reporting relationships—answering 'How is management organized to handle cybersecurity?' This qualifies as Management Role under Rule 1, as it centers on management-level committees (not board-level) and their membership. Specificity is driven by the mention of a firm-specific committee name ('Security and Technology Risk Leadership Committee') and a specific cross-functional scope ('approximately 20 departments'), which are unique to the company's internal structure.


fact: TPRM program is integrated into procurement process

fact: cybersecurity due diligence reviews on vendors based on risk profile

fact: ongoing monitoring of principal suppliers through periodic reviews

reasoning: The paragraph primarily describes how Unisys manages cybersecurity risks associated with third-party service providers through its Third Party Risk Management (TPRM) program, including due diligence and ongoing monitoring—answering the question of how third-party cyber risks are managed. This constitutes Third-Party Risk as the central topic. The specificity is elevated to Level 4 due to the verifiable claim of maintaining a 'Third Party Risk Management (TPRM) program' with named integration into procurement and specific risk-based review practices, which are concrete and organizationally distinctive processes.


fact: Chief Innovation Officer provides cybersecurity reports to the Audit Committee

fact: Audit Committee reviews cybersecurity risks and controls at least annually

fact: Audit Committee receives periodic reports on notable cybersecurity incidents

reasoning: The paragraph primarily describes the Board and Audit Committee’s oversight role in cybersecurity, including the frequency and scope of reviews with management and reporting on incidents, which directly answers 'How does the board oversee cybersecurity?' The specificity is elevated to Level 3 due to the mention of the Chief Innovation Officer providing reports, a firm-specific leadership role involved in cybersecurity governance.


reasoning: The paragraph primarily addresses whether cybersecurity risks have materially affected the company's business, strategy, or financial condition, which aligns with the 'Strategy Integration' category. It contains a backward-looking materiality assessment stating no material impact has occurred, which qualifies as Strategy Integration under Rule 5. Specificity is Generic Boilerplate because the only potentially elevating claim — 'have not identified any risks... that have materially affected' — is a negative self-assertion that is not externally verifiable, and the cross-reference to Risk Factors does not add verifiable or firm-specific content.


fact: incident response plan

fact: crisis simulation exercises involving shipboard and shoreside employees

fact: incident response team

fact: collaborates with external cybersecurity experts

reasoning: The paragraph primarily describes the company's incident response capabilities, including plan maintenance, testing via simulations, and team structure—answering 'What does the cybersecurity program do?' This aligns with Risk Management Process. The mention of an incident response team and external experts supports this, but the focus is on program activities, not governance or management roles.


reasoning: The paragraph primarily answers 'What happened in a cybersecurity incident?' by describing a specific past event in August 2023 that affected information systems and caused operational disruptions, which qualifies as Incident Disclosure. The mention of materiality and future risks does not override the central focus on a real, disclosed incident. Specificity is Level 1 because all claims are generic or non-verifiable (e.g., 'temporary disruptions,' 'not materially affected,' 'may not be successful') and lack any domain-specific terminology, firm-specific details, or quantified/verifiable facts.


fact: CDO and CISO have collectively over 25 years of prior work experience in information security, cybersecurity strategy, and program implementation

fact: CDO and CISO hold ISACA Certified Information Security Manager (CISM) certification

fact: CDO and CISO hold ISC2 Certified Information Systems Security Professional (CISSP) certification

reasoning: The paragraph primarily describes the leadership roles of the CDO and CISO, their qualifications, experience, and responsibilities in managing cybersecurity, which directly answers 'How is management organized to handle cybersecurity?' This aligns with Management Role. Specificity is driven by verifiable facts about certifications and over 25 years of combined experience, which are externally checkable claims.


fact: Our results of operations and financial condition have not been materially affected by cybersecurity threats or incidents to date

fact: cybersecurity threats and other technological risks involving our systems have materially affected our business strategy and processes

fact: we have invested and expect to continue to invest significant resources to maintain and enhance our information security and controls

reasoning: The paragraph primarily addresses how cybersecurity risks have influenced the company's business strategy and financial planning, stating that such threats 'have materially affected our business strategy and processes' and discussing past and future investment in security — a direct link to financial and strategic impact. Specificity is driven by the verifiable claim about material effect on business strategy, which is a firm-level assertion that could be corroborated through comparative analysis of strategic shifts.


fact: Senior Manager has over 20 years specializing in cybersecurity

reasoning: The paragraph primarily describes the organizational structure and leadership of the cybersecurity function, focusing on the Senior Manager's role, reporting line, experience, and responsibilities—answering 'How is management organized to handle cybersecurity?' This aligns with Management Role. Specificity is driven by the verifiable claim of 'over 20 years specializing in cybersecurity,' which is a quantified and externally checkable fact.


fact: CSO (Chief Security Officer) role mentioned

fact: Program includes assessment, identification, and management of cybersecurity threats

fact: Program covers third-party risk from vendors and suppliers

fact: Designed to identify and respond to security incidents and threats in a timely manner

fact: Focus on confidentiality, integrity, and availability of information

reasoning: The paragraph primarily describes what the cybersecurity program does—assessing, identifying, and managing cybersecurity risks, including third-party vendor risks, and responding to incidents—answering 'What does the cybersecurity program do?' This aligns with Risk Management Process. Specificity is Level 2 because it includes domain-specific terminology like 'confidentiality, integrity, availability,' 'CSO,' and 'third-party risk from vendors and suppliers,' which reflect cybersecurity expertise beyond generic risk management language.


fact: MOVEit Transfer incident involved customer data

fact: Incident did not involve the Bank's internal network or IT systems

fact: Customers using online and mobile banking could have had personal information copied

fact: Vendor implemented recommended patches from Progress Software Corporation

fact: Bank worked with vendor to identify impacted customers and extent of exposure

fact: Bank notified potentially affected customers

fact: Incident did not impact ongoing operations of the Bank

fact: Cyber insurance is expected to cover many costs related to the incident

fact: MOVEit Transfer incident is the only cybersecurity incident that materially affected the Corporation during 2023

reasoning: The paragraph primarily describes a specific cybersecurity incident involving the MOVEit Transfer vulnerability, including its scope, impact on customer data, root cause (third-party vendor), response actions, and confirmation that it was the only material incident in 2023 — all of which directly answer 'What happened in a cybersecurity incident?' The mention of cyber insurance coverage is secondary to the incident narrative. Specificity is driven by verifiable facts such as the named software (MOVEit Transfer), the vendor's patching actions, and the confirmation that this was the only material incident in the fiscal year.


fact: CIO

fact: Vice President of Information Security

fact: Information Technology Senior Leadership Team

fact: at least once each quarter

fact: at least annually

reasoning: The paragraph primarily describes how the Board and Audit Committee oversee cybersecurity risk, including the frequency and scope of reporting, information flow from management, and engagement with leadership (CIO), which directly answers 'How does the board oversee cybersecurity?' This governance-chain structure, with the Board and Audit Committee receiving updates and discussing risk management, is central to Board Governance. Specificity is driven by firm-specific roles (CIO, Vice President of Information Security) and structured cadences (quarterly, annually), which are organizationally distinctive.


fact: Incident Response Team comprised of members from the major business areas in the Bank

reasoning: The paragraph primarily describes Dime's process for assessing and managing cybersecurity threats, including the structure of its Incident Response Team and the evaluation of material impact — which directly answers 'What does the cybersecurity program do?' The mention of materiality assessments is part of the incident evaluation process, not a standalone financial impact analysis, so it supports RMP rather than Strategy Integration. Specificity is driven by the firm-specific detail of a cross-functional Incident Response Team involving major business areas, which distinguishes Dime's organizational approach.


fact: IT vendor risk management policy

fact: third-party risk management program

fact: pre-onboarding security assessments

fact: annual re-assessments of service providers

fact: track and manage third-party security controls based on risk

fact: issues tracked through to remediation

reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on vendor risk policies, pre-onboarding and annual security assessments, and remediation tracking—making Third-Party Risk the dominant category. Specificity is Level 2 due to the use of domain-specific practices like 'pre-onboarding security assessments,' 'annual re-assessments,' and 'tracking controls based on risk,' which reflect cybersecurity-specific vendor risk management processes beyond generic ERM language.


reasoning: The paragraph explicitly addresses whether cybersecurity risks have materially affected or are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which directly aligns with the Strategy Integration category under Rule 5. The reference to Item 1A is a cross-reference, but the core content is a forward-looking materiality assessment, qualifying as Strategy Integration.


fact: CISO

reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing the frequency and sources of cybersecurity briefings (CISO and external experts), which falls under board-level oversight. The mention of the CISO and external experts supports the governance structure, not management roles or specific program details. Specificity is driven by the firm-specific role of CISO, which distinguishes this company's governance structure.


reasoning: The paragraph primarily addresses whether cybersecurity risks have materially affected or are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which directly aligns with the 'Strategy Integration' category under Rule 5. Although it is a cross-reference, it explicitly frames the materiality assessment, making it a substantive assertion rather than a mere pointer. Specificity is Generic Boilerplate because the paragraph contains no verifiable facts, firm-specific details, or domain-adapted terminology—only a reference to other disclosures.


fact: Change Healthcare, a subsidiary of UnitedHealth Group, experienced a cybersecurity incident

fact: Notification date of the incident: February 21, 2024

fact: As of February 28, 2024, no compromise or unauthorized access of Encompass Health's systems was identified

fact: Change Healthcare processes payment claims for all payors for Encompass Health

reasoning: The paragraph primarily answers 'What happened in a cybersecurity incident?' by detailing a real event involving Change Healthcare, including the date of notification (February 21, 2024), the nature of the incident, the response actions taken (severing connections, conducting forensics), and the current status (no compromise found as of February 28, 2024). Specificity is driven by verifiable facts such as the specific date of the incident notification and the named third party (Change Healthcare), which are externally confirmable.


fact: forensic reviews of cybersecurity-related incidents

fact: independent security assessments

fact: stay aligned with industry best practices

fact: evaluate external threats

reasoning: The paragraph primarily describes actions taken as part of the company's information security program—specifically, the use of external assessors for security improvements, threat evaluation, and forensic reviews—which directly answers 'What does the cybersecurity program do?' This aligns with Risk Management Process. The mention of external parties is in service of enhancing internal capabilities, not managing vendor risk, so Third-Party Risk does not apply. Specificity is elevated to Level 2 due to the use of domain-specific practices like forensic reviews and independent security assessments, which reflect cybersecurity expertise beyond generic risk management language.


fact: Core Cybersecurity Management Team (CCMT) composed of CISO, Chief Legal Officer, and Chief Financial Officer

fact: CCMT has oversight of Teradata's CIRP (Cyber Incident Response Plan)

fact: CCMT determines communications to stakeholders including Board, Audit Committee, investors, customers, regulators

reasoning: The paragraph primarily describes the composition and responsibilities of a management-level team (CCMT) in handling cybersecurity incidents and communications, which answers the question of how management is organized to handle cybersecurity. The mention of the CISO, Chief Legal Officer, and CFO as a defined team with specific responsibilities (e.g., determining stakeholder communications) centers on management structure and roles. Specificity is driven by the named team (CCMT), a firm-specific organizational construct, and the defined role in incident response and stakeholder communication.


reasoning: The paragraph primarily addresses whether cybersecurity has or could affect the company's business outcomes, stating that no material incidents have occurred to date but acknowledging future risks could materially affect business strategy, results of operations, or financial condition—this constitutes a materiality assessment under Rule 5. The specificity is Generic Boilerplate because the claims are non-verifiable (e.g., 'no material incidents') and the forward-looking risk reference is standard disclosure language without specific facts.